The State Tax Service (STS) has published special currency supervision requirements for 2026. The document contains prohibitions during martial law, requirements on the crediting of proceeds and rules on liability for breaches of deadlines.
Prohibitions during martial law
During martial law banks are prohibited from closing currency supervision cases on the basis of documents that record the crediting of reciprocal homogeneous claims (mutual set-off) in respect of ordinary trade in goods. This means that set-off cannot substitute for the actual receipt of payment.
Export proceeds must actually be received from abroad into a Ukrainian company’s account in a foreign currency. In other words, the recording of notional or reciprocal claims does not replace payment from abroad.
Accrual of penalties for breaches of deadline
For breaches of payment deadlines, as confirmed by documentary checks, financial liability is imposed in the form of a penalty of 0.3% for each day of delay on the amount of unpaid proceeds or the value of undelivered goods. The document specifies the penalty rate as 0.3% per day.
The total amount of accrued penalties cannot exceed the sum of unpaid proceeds or the value of goods as of the first day of the breach of the payment deadlines. In other words, the penalty is capped at the actual amount of proceeds unpaid at the start of the breach.
Inspections and declaration of foreign-source income
Documentary ad-hoc inspections of entities involved in foreign economic activity on compliance with currency legislation are organised on the basis of information from the National Bank of Ukraine (NBU), which is provided to the STS on a monthly basis. The NBU supplies data on instances of breaches of the established payment deadlines for export and import transactions in goods.
The guidance also explains that income that tax residents receive from sources outside the country is subject to declaration and taxation in Ukraine, except for income exempted from taxation under the Tax Code or international agreements. Previously we wrote about the specifics of currency transfers during the war.
What to watch in the coming days: the official NBU exchange rate, interbank quotations (the market where banks exchange currency) and cash exchange rates. It is also worth monitoring NBU announcements about the monthly information it provides and the payment deadlines for export-import transactions.
