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pc nid 92602 May 16, 2026 arahman@vixio.com Ukraine National Bank of Ukraine (NBU) horizon scanning
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Ukraine's National Bank Clarifies Systemic Importance Buffer Requirements for Banks

On May 18, 2026, the National Bank of Ukraine (NBU) clarified requirements for banks and banking groups to establish a systemic importance buffer, adjusting an earlier decision made in March 2026. The NBU deferred the implementation timeline to align with evolving external conditions and support Ukraine's updated Credit Development Strategy, which prioritises maintaining banks' capacity to finance critical infrastructure reconstruction, particularly energy sector assets damaged by sustained aerial attacks. Under the revised framework, banks and banking groups will be designated as systemically important in 2027 and must comply with systemic importance buffer requirements beginning January 1, 2028. The buffer implementation follows a phased approach consistent with European Union directive transposition and aims to strengthen banking system resilience. The NBU adopted the new requirements through Board Resolution 52, effective May 19, 2026, which amends Board Resolution 23 from March 4, 2026. The adjustment reflects the NBU's commitment to balanced regulatory implementation that preserves active credit expansion. The updated Credit Development Strategy, approved by the Financial Stability Council on May 5, 2026, has achieved approximately 60 percent implementation success, driving dynamic credit growth across sustained and elevated rates. This includes expanded access to credit for critical energy sector operations and defence-industrial complex businesses in resilience territories. The NBU continues collaborating with stakeholders on strategy realisation since 2024. **References:** National Bank of Ukraine Board Resolution 52 (May 16, 2026)

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Ukraine's National Bank Clarifies Systemic Importance Buffer Requirements for Banks

On May 16, 2026, the National Bank of Ukraine (NBU) adopted a resolution on the requirements for banks and banking groups to establish a systemic importance buffer, adjusting an earlier decision made in March 2026. The NBU deferred the implementation timeline to align with evolving external conditions and support Ukraine's updated Credit Development Strategy, which prioritises maintaining banks' capacity to finance critical infrastructure reconstruction, particularly energy sector assets damaged by sustained aerial attacks. Under the revised framework, certain banks and banking groups will be designated as systemically important in 2027 and must comply with systemic importance buffer requirements beginning January 1, 2028. Responsible persons of banking groups must: Ensure that the banking group forms a capital conservation buffer starting from the reporting date of January 1, 2027. Ensure the formation of a systemic importance buffer by the banking group. The buffer implementation follows a phased approach consistent with European Union directive transposition and aims to strengthen banking system resilience. The adjustment reflects the NBU's commitment to balanced regulatory implementation that preserves active credit expansion. The resolution shall enter into force on the day following its official publication.