According to the Memorandum on ensuring transparency in the operation of the payment services market, the banking community has introduced transitional and permanent limits on monthly automatic transfers for some individual entrepreneurs (FOP) and companies: the transitional limit applies from 14 August, the permanent limit from 14 November.
The transition to the new classification of economic activities NACE 2.1‑UA begins on 1 January 2027; preparation by state bodies will continue until the end of 2026, and from 2028 only the new classification of types of economic activity (KVEDs) will be used.
New limits on monthly transfers and consequences of exceeding them
From 14 August a transitional monthly limit on automatic transfers applies, and from 14 November the permanent limit will come into force. The limit is the total monthly amount of transfers, not a cap on a single payment.
Transactions above the limit are subject to enhanced scrutiny by authorised financial institutions. Banks and non-bank financial institutions do not automatically execute over‑limit payments: they are carried out only on the basis of a payment instruction from the account holder, and the entrepreneur must documentarily confirm the source of the funds.
At the first stage, financial institutions will assess clients according to risk criteria; exceeding the limit has become a separate risk criterion for some FOPs and legal entities. If a transaction or a client gives rise to suspicion, the bank may request explanations and supporting documents.
Digitalisation of financial monitoring and automatic checks
The memorandum provides for deep digitalisation of controls: banks will obtain automatic access to data on citizens’ incomes, the existence of court cases and other relevant information. This means manually collecting certificates will no longer be necessary - the system will verify the information itself.
If a client is entered into a register at one institution, other banks will automatically step up monitoring of their accounts. Banks, the State Financial Monitoring Service, the Ministry of Justice and the State Tax Service will join efforts to identify related financial networks and create a shared blacklist of risky clients.
A payment instruction means an order from the account holder to the bank to carry out a specific operation; financial monitoring is the process of checking transactions for suspicion of illegal schemes or splitting of business. If there is suspicion, the bank has the right to request documents and explanations regardless of the amount of the transfer.
Transition to NACE 2.1‑UA, KVED updates and related changes
From 1 January 2027 the transition to the NACE 2.1‑UA classification will begin, preparation by authorities will continue until the end of 2026, and from 2028 only the new KVEDs will be applied. There is no automatic transfer: individual entrepreneurs (FOP) and legal entities must update their KVEDs themselves.
Once the relevant service is launched, sole proprietors will be able to submit an application to update their KVEDs through the state registrar or via Diia. The government is also considering reforming the simplified taxation system for sole proprietors in the second and third groups, and the Ministry of Finance is working on updating the rules for administering value-added tax (VAT) in line with European standards.
