Ukraine: launch of the payment services market

06/ 06/ 2026

Прослухати онлайн Зупинити   In brief On 30 June 2021, Verkhovna Rada of Ukraine adopted a new payment services law. The law seeks to: (i) remove certain regulatory barriers for entering the Ukrainian payment services market, and (ii) implement certain European Union (EU) laws applicable to the payment services, such as Directive 2015/2366 (PSD2) and Directive 2009/110/EC (Second E-Money Directive). The law came into force on 1 August 2021 and provides the stakeholders with 12 months to prepare for the launch of the new payment services market. The law may affect many business models in payment services business which were previously essentially unregulated. The chart provided herein contains a list of regulated services and entities. Depending on the service providers individual setup and development plans (i.e., launching a new service or continuing carrying out the current one), the service provider may need to seek authorization or accreditation from the competent authority in Ukraine. Key takeaways Service providers with exposure to payment transactions to/from Ukraine are encouraged to closely review their existing business models to identify whether their service(s) fall under the new regulatory regime and whether any relevant exemptions are available. There are considerable differences between the list of exemptions under PSD2 and the new law. Service providers may not be able to rely on exemptions they are familiar with in the EU and may need to seek authorization or accreditation from the relevant competent authority in Ukraine. For more information, please contact: Serhiy Chorny Managing Partner Baker McKenzie Maksym Hlotov Senior Associate Baker McKenzie

In brief

On 30 June 2021, Verkhovna Rada of Ukraine adopted a new payment services law. The law seeks to: (i) remove certain regulatory barriers for entering the Ukrainian payment services market, and (ii) implement certain European Union (EU) laws applicable to the payment services, such as Directive 2015/2366 (PSD2) and Directive 2009/110/EC (Second E-Money Directive). The law came into force on 1 August 2021 and provides the stakeholders with 12 months to prepare for the launch of the new payment services market. The law may affect many business models in payment services business which were previously essentially unregulated. The chart provided herein contains a list of regulated services and entities. Depending on the service provider’s individual setup and development plans (i.e., launching a new service or continuing carrying out the current one), the service provider may need to seek authorization or accreditation from the competent authority in Ukraine.

Key takeaways

Service providers with exposure to payment transactions to/from Ukraine are encouraged to closely review their existing business models to identify whether their service(s) fall under the new regulatory regime and whether any relevant exemptions are available. There are considerable differences between the list of exemptions under PSD2 and the new law. Service providers may not be able to rely on exemptions they are familiar with in the EU and may need to seek authorization or accreditation from the relevant competent authority in Ukraine.

For more information, please contact:

Serhiy Chorny
Managing Partner Baker McKenzie

Maksym Hlotov
Senior Associate Baker McKenzie