Ukraine focuses on collaboration between banks and technology companies

06/ 06/ 2026

Прослухати онлайн Зупинити   On 16 January 2021, the National Bank of Ukraine (NBU) introduced a specific oversight with respect to compliance of Ukrainian banks with data protection and cybersecurity requirements. Banks will now be subject to either remote or on-site inspections in these areas. In addition, banks will be required to submit the respective annual self-assessment reports. The template report form, approved by the NBU, indicates that banks will have to disclose all of their cloud and outsourcing projects with third-party vendors. Key takeaways The Ukrainian market is seeing an increased amount of emerging partnerships between banks and technology companies. Such collaboration arrangements have now attracted the regulators attention. Accordingly, banks and their technology vendors should dedicate more care to the regulatory aspects of their cooperation (and related technology transactions), to ensure a smooth oversight experience. Background The new oversight regime aims to implement the evolving regulatory framework for data protection and cybersecurity in the banking industry. According to its Fintech Strategy 2025, the NBU will also adopt bespoke rules for banks governing IT outsourcing and cloud projects by the end of 2022 and 2024, respectively. For more information, please contact: Serhiy Chorny Managing Partner Baker McKenzie   Maksym Hlotov Senior Associate Baker McKenzie

On 16 January 2021, the National Bank of Ukraine (NBU) introduced a specific oversight with respect to compliance of Ukrainian banks with data protection and cybersecurity requirements. Banks will now be subject to either remote or “on-site” inspections in these areas. In addition, banks will be required to submit the respective annual self-assessment reports. The template report form, approved by the NBU, indicates that banks will have to disclose all of their “cloud” and “outsourcing” projects with third-party vendors.

Key takeaways

The Ukrainian market is seeing an increased amount of emerging partnerships between banks and technology companies. Such collaboration arrangements have now attracted the regulator’s attention. Accordingly, banks and their technology vendors should dedicate more care to the regulatory aspects of their cooperation (and related technology transactions), to ensure a smooth oversight experience.

Background

The new oversight regime aims to implement the evolving regulatory framework for data protection and cybersecurity in the banking industry. According to its Fintech Strategy 2025, the NBU will also adopt bespoke rules for banks governing IT outsourcing and cloud projects by the end of 2022 and 2024, respectively.

For more information, please contact: