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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. 


Serhiy Chorny is a co-managing partner of the Kyiv office of Baker McKenzie and head of the Kyiv office's Banking, Finance and Capital Markets Group. He is highly ranked by leading international and Ukrainian legal directories, including Chambers Global, Chambers Europe, The Legal 500 EMEA and IFLR1000, in various practice areas, including banking and finance, capital markets, structured finance, securitization, restructuring and insolvency, and financial services.


Maksym Hlotov is an associate in Baker McKenzie's Kyiv office.

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