New limits on card-to-card transfers: what restrictions are set to be implemented for Ukrainians starting February 1st.

Starting February 1, Ukrainian banks will impose limits on money transfers from card to card and based on account details. These new restrictions will affect clients without verified income.

For more details on the changes in banking operation rules, visit RBC-Ukraine.

Why banks are imposing restrictions

In December 2024, several major banks in Ukraine and associations signed a Memorandum to ensure transparency in the functioning of the payment services market.

The document outlines the introduction of limits on money transfers, classification of clients by risk groups, checks on individual entrepreneurs, etc. However, these innovations only apply to users of banking services who cannot verify the legitimacy of their income.

The NBU and the signatories of the Memorandum explain that the goal of this initiative is:

• to reduce the shadow economy;
• to combat fraudulent financial schemes, particularly the use of "drop" accounts (clients who provide access to their cards or accounts for dubious transactions in exchange for compensation);
• to align the Ukrainian banking sector with unified standards and requirements of EU legislation.

As of January 27, 2025, the Memorandum has been joined by 44 banks and 2 payment systems (Oschadbank, PrivatBank, Raiffeisen Bank, PUMB, Universal Bank, Sense Bank, NovaPay, RozetkaPay systems, etc.).

Limits starting February 1: which transfers, amounts, and other innovations

Since October last year, a limit from the NBU on money transfers between individuals from card to card (P2P) has been set at 150,000 UAH per month for Ukrainians.

According to the Memorandum, starting February 1, 2025, there will be restrictions not only on P2P transfers but also on outgoing transfers based on IBAN details in both national and foreign currencies.

These will be imposed for clients without verified income, depending on which risk group they belong to:

• clients in the "high" risk group – limit of 50,000 UAH per month;
• clients in the "medium" and "low" risk groups - limit of 150,000 UAH per month (from June 1 - 100,000 UAH).

However, the Memorandum does not define the degree of "riskiness." Each bank will apply its own assessment criteria when opening an account and during the ongoing servicing of the client.

At the same time, the document stipulates that enhanced verification measures must be applied in each specific case for clients in the "high" risk group. Clients in the "low" and "medium" risk groups will undergo simplified verification procedures.

Photo: banks establish three "risk groups" for clients (Vitaliy Nosach, RBC-Ukraine)

Banks will also impose limits on the number of accounts (credit, deposit, and accounts for government program payments are not included). A client without verified income sources may have no more than 3 accounts in one currency.

Financial institutions will conduct in-depth studies of the business activities of newly established individual entrepreneurs (up to 6 months) in the first tax group and monitor account operations based on the average monthly income. Individual entrepreneurs in the general or simplified system of tax groups 2-3 will be checked according to their own risk-oriented criteria.

Banks will conduct round-the-clock monitoring of payment operations with particular attention to transactions during night hours (from 00:00 to 06:00) to identify cases of atypical financial behavior and counteract fraudulent schemes.

Who will not be subject to limits

The restrictions on transfers will not apply to clients of banks with verified income (salary clients and others), as well as to volunteers whose activities are documented (in accordance with NBU Resolution No. 18 dated February 24, 2022, "On the Operation of the Banking System During Martial Law").

Limits will not apply to operations involving the transfer of funds between two accounts opened by the client in the same bank.

As explained by NBU head Andriy Pyshnyy, banking restrictions will affect no more than 1% of the client base. This specifically includes those clients who have not provided documented proof of their income, especially those identified as "high-risk."

"If you work officially, receive a legitimate salary, or can otherwise document your income, nothing will change for you. Just as it did not change for you in October 2024 when the NBU took the first step to address the issue with drop accounts by defining a general framework for all clients," noted Pyshnyy.

Photo: limits will not apply to salary clients (Vitaliy Nosach, RBC-Ukraine)

The head of the National Bank added that the successful implementation of the Memorandum could pave the way for the early lifting of the temporary limit on P2P transfers, which was introduced in October 2024 for a period of six months.

Documents for income verification

The innovations starting February 1 do not require clients to update their income data.

"The Memorandum does not contain any requirements for additional identification, as this was already done when opening the account," explained Andriy Pyshnyy.

However, if a client wishes to carry out a transaction exceeding the established limit, they must provide documented proof of the source of funds.

This could include electronically generated certificates OK5 and OK7, tax returns, payroll records, confirmations of deposits from government bodies, documented income of family members, or confirmation of volunteer activities.

In preparing this material, the text of the Memorandum on ensuring transparency in the functioning of the payment services market, publications from the Association of Ukrainian Banks, and a statement from NBU head Andriy Pyshnyy on Facebook were used.