NBU Tightens Bank Capital Requirements While Easing Lending to Strategic Industrie

In October, the National Bank of Ukraine adopted a series of regulatory decisions introducing new requirements for banks' capital, liquidity, and risk management. At the same time, the regulator continued to ease certain lending conditions for enterprises in the defense industry, energy sector, and critical infrastructure.

This is stated in a review of changes to the NBU's regulatory framework for September, prepared by the Financial Pulse Center for Economic Research and Forecasting.

According to Diliara Mustafaeva, Head of the Analytical Department at Financial Pulse, the October decisions demonstrate two parallel directions in the development of banking regulation: gradual alignment with European standards and the creation of additional opportunities to finance the economy during wartime.

“At first glance, tightening requirements for banks and easing lending conditions may seem like opposing processes. In reality, they complement each other. On the one hand, the banking system must be adequately capitalized and protected against risks. On the other hand, its financial resources must support the economy. This is particularly important for enterprises on which the country's defense capabilities, energy resilience, and restoration of damaged infrastructure currently depend”, — the expert noted.

Higher Capital and Liquidity Requirements for Banks

One of the key decisions was NBU Resolution No. 121 of October 13, 2026, which provides for an increase in the minimum regulatory capital requirement for banks from UAH 200 million to UAH 250 million. The new requirement will take effect on January 3, 2027.

In addition, the regulator established the possibility of imposing higher capital adequacy and liquidity requirements on individual banks. It also emphasized the need for continuous compliance with capital, credit risk,  and  investment limits and strengthened supervision of banks' liquidity.

Another important step toward alignment with European standards was the increase in the multiplier applied to certain types of risks in the formula for calculating total risk exposure, from 10 to 12.5. The relevant Decision No. 338-rsh of October 7 will take effect on December 31, 2026.

This means that banks' calculated capital adequacy ratios will decline even without an actual reduction in their capital. The new requirements may create an additional burden, primarily for institutions with smaller capital buffers. 

In addition, Resolution No. 120 of October 13 updated certain technical aspects of identifying systemically important banks. However, the basic criteria and numerical assessment thresholds remained unchanged. The updated methodology will be applied using data as of January 1, 2027, and the NBU is expected to publish the new list of systemically important banks by July 1, 2027.

Additional Lending Opportunities for the Defense Industry and Energy Sector

Alongside tightening regulatory requirements, the NBU continued to adapt lending rules to the needs of the wartime economy.

In particular, Resolutions No. 118 of October 11 and  No. 123 of October 28  introduced another package of measures to support financing for enterprises operating in frontline  and war-affected areas, as well as  companies in the defense industry, agricultural producers, and  critical infrastructure enterprises (primarily those involved in restoring electricity, heating, water supply, and wastewater services).

The changes provide for easing  credit risk assessment requirements for certain categories of borrowers and specific types of  collateral. This is intended to expand banks' ability to lend to enterprises that are important to the country but, due to the war, face difficulties in achieving planned profitability targets and/or lack sufficient tangible  collateral to secure loans.

“Under current conditions, even financially viable enterprises may face difficulties obtaining loans, especially if their assets have been damaged or their production facilities are located in areas exposed to heightened war-related risks. Therefore, changing approaches to collateral valuation and creditworthiness assessment is an important step toward supporting businesses. In effect, the regulator is seeking to reduce the barriers that prevent banks from fully financing strategically important enterprises”, — the expert emphasized.

However, according to her, easing regulatory requirements does not automatically translate into increased lending. Each bank will continue to assess borrowers' solvency, business prospects, and ability to service their debt on time.

“It is fundamentally important that support for lending should not come at the cost of uncontrolled risk accumulation. The objective is different: to give banks greater opportunities to finance enterprises that have economic potential but operate under extremely challenging circumstances. In the longer term, this could positively affect not only lending volumes but also the pace of recovery in production and infrastructure”, — Diliara Mustafaeva stressed.

Financial Monitoring 

In October, the regulator also continued to improve financial monitoring requirements. Through Resolution No. 116 of October 7, the NBU clarified the procedures for interaction between non-bank financial institutions and the specially authorized financial monitoring body, as well as certain financial monitoring procedures applicable to banks and non-bank institutions.

“Taken together, the October decisions demonstrate the regulator's efforts to combine the long-term objectives of banking system reform with the urgent needs of the economy”, — Diliara Mustafaeva summarized.

According to her, Ukraine's banking system is gradually transitioning toward a European regulatory model. However, this process is taking place during wartime, when conventional approaches do not always reflect the real needs of businesses. Therefore, finding a balance between banks' financial resilience and their ability to lend to the economy is particularly important.

“After all, a strong banking system is not only about sufficient capital and regulatory compliance but also about the ability to provide financial support to enterprises whose operations are essential to the country's economic resilience”, — Diliara Mustafaeva concluded.