Lawyer
Expert in corporate and international corporate law. Has extensive experience in supporting the acquisition of financial licenses in Ukraine, as well as business incorporation in the EU, the United Kingdom, Switzerland, the UAE, and key Asian jurisdictions.
License (authorization) for the provision of payment services in Ukaraine
The financial services market in Ukraine has undergone significant transformation following the entry into force of the Law of Ukraine “On Payment Services,” which implemented modern European approaches to the regulation of payment infrastructure.
The key regulator in this area is the National Bank of Ukraine, which carries out licensing, authorization, and supervision, and also applies enforcement measures to market participants.
In this overview, the specialists of Prikhodko & Partners explain the legal nature of authorization, the procedure for obtaining it, the requirements for applicants, the types of payment services, and the practical risks that businesses often overlook.
Authorization subjects
NBU authorization is mandatory for non-bank financial institutions and other legal entities intending to provide payment services on a professional basis. In particular, this applies to:
- payment organizations;
- financial companies;
- electronic money institutions;
- payment infrastructure operators;
- branches of foreign payment institutions.
Banks conduct the relevant activities under a banking license, while non-bank entities must undergo a separate authorization procedure and be entered into the Register of Payment Infrastructure.
Types of payment services
Ukrainian legislation provides several categories of payment services, including:
- money remittance services without opening an account;
- opening and servicing payment accounts;
- issuance of payment instruments (including electronic ones);
- acquiring of payment instruments;
- payment initiation services (PIS);
- account information services (AIS);
- issuance and circulation of electronic money.
The selected type of services determines the scope of regulatory requirements, minimum capital thresholds, internal control structure, and the list of documents to be submitted to the NBU.
Key requirements for obtaining authorization
Among the core requirements:
- sufficient own capital (depending on the type of services);
- impeccable business reputation of owners and managers;
- transparent ownership structure;
- proper risk management system;
- implemented AML/financial monitoring procedures;
- IT infrastructure compliant with security requirements.
Failure to meet even one of these criteria may result in refusal.
Authorization procedure
The authorization process conditionally consists of several stages.
Preliminary preparation
At this stage, the following is carried out:
- business model analysis;
- determination of the list of payment services;
- ownership structuring;
- fit & proper assessment of managers and qualifying shareholders;
- preparation of internal policies (AML, compliance, risk management, cybersecurity).
The NBU pays particular attention to ownership transparency and the absence of nominee beneficiaries.
Document package preparation
The applicant submits to the NBU:
- authorization application;
- business plan with financial projections;
- internal policies and procedures;
- documents confirming the source of funds;
- information on IT systems and data protection;
- details of managers and key personnel.
Insufficient substantiation of the business plan is one of the most common grounds for leaving the application without consideration or issuing comments.
NBU review
The regulator assesses:
- the applicant’s financial capacity;
- the realism of the business model;
- adequacy of internal control systems;
- availability of financial monitoring procedures;
- the level of cybersecurity.
If necessary, the NBU sends requests to remedy deficiencies or provide additional documents. Only after a positive decision is the applicant entered into the relevant register and granted the right to provide payment services.
Why it is important to engage the Prikhodko & Partners team
Obtaining NBU authorization is not merely a formal filing exercise but a комплексный project covering corporate structuring, financial planning, IT audit, and the build-out of a compliance system.
Our law firm provides full-cycle support of the authorization process, including:
- comprehensive legal and regulatory analysis of the business model against NBU requirements;
- development and preparation of a full turnkey document package tailored to the selected payment services;
- design and adaptation of AML, risk management, and financial monitoring policies;
- legal support in approval of managers and key officers;
- structuring of agreements with banks, payment organizations, processing centers, and IT providers;
- structured communication support with the NBU, including responses to regulator queries;
- post-authorization compliance support and assistance with regulatory reporting and supervision.
We treat authorization not as a standalone step but as a strategic milestone that shapes the regulatory resilience, reputational reliability, and long-term stability of a financial business.
If you are planning to enter the payment services market, professional legal support is not an expense — it is an investment in regulatory safety and long-term business stability.
Calculate the cost of services
1 question
Does your company have the status of a non-bank financial institution?
2 question
Have you determined what type of payment services you will provide?
3 question
Do you plan to provide payment services only for residents of Ukraine?
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