Legislative Review

December 22 – 26, 2025. Amendments to Rules for Preparation and Submission of Reports by Participants in Non-Banking Financial Services Market made

The Cabinet of Ministers of Ukraine has approved changes to the defense procurement procedure for the period of martial law. The decision was made in accordance with the instructions of the Headquarters of the Supreme Commander-in-Chief's.

From now on, state customers have the right to conclude contracts for the purchase of goods, works, and services from the list of "Weapons of Victory" for the entire production cycle - from development and production to repair and restoration. Needs will be established not only for the current year, but also for the next two budget periods.

The government has updated the approach to prepayment. Its size and terms are now tied to the stages of work. This allows financing production rhythmically, without stops and cash gaps. Thus, conditions will be created for launching new production facilities and developing existing capacities of the defense-industrial complex.

The Ministry of Economy, Environment and Agriculture of Ukraine has prepared a draft resolution of the Cabinet of Ministers of Ukraine “ On Amendments to Certain Resolutions of the Cabinet of Ministers of Ukraine on the Provision of Services in the Field of Employment of the Population through Administrative Service Centers, aimed at optimizing the provision of services in the field of employment of the population and increasing their accessibility for citizens and employers. The draft was developed jointly with the Ministry of Digital Transformation of Ukraine with the participation of the State Employment Center.

The document provides for expanding the possibilities of receiving employment services electronically through the Unified State Web Portal of Electronic Services (Portal Diia), as well as through administrative service centers. In particular, it is planned to gradually transfer 17 administrative services to the network while maintaining the functions of decision-making and payment under the State Employment Service.

The introduction of a new model will allow the State Employment Service to focus resources on providing comprehensive social services - individual support for the unemployed, professional orientation, organization of vocational training, and work with vulnerable categories of the population.

In addition, the draft act provides for improving the mechanisms for paying unemployment benefits during vocational training and strengthening support for employers who employ registered unemployed people from vulnerable categories.

The Cabinet of Ministers of Ukraine has decided launched a pilot project on electronic declaration of the right to commercial fishing and exploratory fishing. The corresponding resolution "On Implementation of a Pilot Project on Some Issues of Declaring the Right to Fishing in Electronic Form" was adopted on December 23, 2025.

According to the document, fishery entities planning to fish on an industrial scale or conduct exploratory fishing are required to declare their right to do so by November 1 each year by submitting a corresponding electronic declaration through the Unified State Electronic System for Fisheries Management.

The implementation of the resolution will ensure:

  • transparent and unified document submission process;
  • simplified business interaction with the state;
  • ability of the state to collect, analyze and summarize data on companies planning to carry out industrial fishing.

The launch of electronic declaration will contribute to the rational use of aquatic biological resources, increase budget revenues, and develop aquaculture and industrial fishing.

The Cabinet of Ministers of Ukraine simplifies the transfer of power equipment to stabilize electricity supply during wartime. The decision, adopted at a meeting of the Government, allows electricity distribution system operators to receive state-owned power equipment for rent without auctions. Transformers, cables and other equipment currently idle on the balance sheet of state-owned enterprises can be used to quickly restore power after shelling. In conditions of constant attacks, these resources must work where they are needed immediately.

The Ministry of Energy will coordinate the accounting of such equipment and the determination of the needs of the power system. After that, the equipment will be promptly transferred to power grid operators for on-site operation.

The new order will be in effect for the period of martial law and for another six months after its end.

The National Bank of Ukraine amended the Rules for the Preparation and Submission of Reports by Participants in the Non-Banking Financial Services Market to the National Bank of Ukraine, approved by Resolution of the NBU Board No. 123 of November 25, 2021 (hereinafter - the Rules).

The purpose of the amendments is to bring the Rules into line with the requirements of the regulatory legal acts of the National Bank of Ukraine in terms of improving the reporting of credit unions, insurers, financial companies, and pawnshops.

The amendments to the Rules provide for:

  • transition to a more regular frequency of submission of individual files of insurers, namely from quarterly (cumulative total from the beginning of the year) to monthly (cumulative total from the beginning of the year) for files IR18 "Data on significant transactions of the insurer", IR25 "Data on components of regulatory capital", IRCF "Data on cash flow (regulatory)", IRN1 "Data on the structure of assets and calculation of compliance with the requirements for the insurer's solvency. Eligible assets, except for non-overdue receivables and technical reserves under outward reinsurance contracts", IRN2 "Data on the structure of assets and calculation of compliance with the requirements for the insurer's solvency. Eligible assets: non-overdue receivables", IRN3 "Data on the structure of assets and calculation of compliance with the requirements for the insurer's solvency. Eligible assets: non-overdue receivables", from annual to quarterly (cumulative total from the beginning of the year) for file IR22 "Insurer's performance ratios";
  • introduction of two new files for insurers (IR27 “Data on the largest counterparties of the insurer” and IRFR “Data on the financial statements of the insurer”, with the simultaneous cancellation of the FR0 file “Data on financial statements” for insurers);
  • introduction of two new files for financial companies and pawnshops (LRF071 "Data on agreements for raising funds and counterparties from which funds were raised" and LRF072 "Data on transactions under agreements for raising funds", with the simultaneous cancellation of files LRF06 "Data on subordinated debt" and LRF07 "Data on raised funds");
  • changes in individual files regarding the list, names of indicators, directories, metrics, parameters, unclassified details of indicators;
  • changes in the submission frequency for six credit union files from monthly to monthly (cumulative total from the beginning of the year);
  • changes in the submission deadline for seven files submitted by non-bank financial groups (responsible persons of non-bank financial groups) from the last business day of the second month following the reporting period to the second business day of the third month following the reporting period.

Changes to the Rules are approved by Resolution of the Board of the National Bank of Ukraine No. 153 of December 22, 2025, which enters into force on April 1, 2026 (hereinafter - Resolution No. 153).

Resolution No. 153 also determines the first reporting dates for submitting individual files with reporting indicators, taking into account the approved amendments to the Rules.

The President of Ukraine signed a Law simplifying the import of defense goods by establishing tax and customs benefits (No. 4709-IX).

The Law entered into force on December 26, 2025.

The Law applies to components for drones, mechanized demining vehicles, counterintelligence equipment, and other products necessary for the modernization and repair of weapons.

The document also provides for VAT exemption on the import of modern combat simulators for training centers and training grounds, which will allow improving the quality of military training in safe and as realistic as possible conditions.

The Cabinet of Ministers of Ukraine has amended Resolution No. 1102 of October 20, 2023, which provides that the new National List of Waste and the Procedure for Classification of Waste for Taxation Purposes will apply from January 1, 2027.

The extension will allow for the completion of the preparation and adoption of amendments to the Tax Code, which will harmonize the classification of waste with tax rates. This will ensure the correct calculation of the environmental tax for waste disposal, reduce the risks of abuse in determining the hazard class of waste, and maintain the stability of budget revenues.

The implementation of this decision will also contribute to the proper implementation of waste management reform, creating conditions for reducing waste accumulation, developing processing and recycling, and reducing the negative impact of waste on the environment, taking into account the interests of business, the state, and communities.

The Ministry of Finance of Ukraine, by order No. 537 of October 27, 2025, approved new rules regulating the procedure for granting a permit to operate a free customs zone (FCZ) and further control over the activities of enterprises that have received such a permit.

The document approved:

  • procedure for granting permission to operate a free customs zone and controlling the activities of the enterprise;
  • application form for granting a permit to operate the FCZ;
  • form of a report on the movement of goods in the free customs zone.

From the date of entry into force of Order No. 537, the following shall cease to be valid:

  • Order of the Ministry of Finance No. 633 of May 30, 2012, which regulated the procedure for opening and operating commercial and service-type FCZ;
  • Order of the Ministry of Finance No. 434 of July 30, 2021, which approved the form of the report on the movement of goods in a FCZ.

The New Procedure defines the procedure for obtaining a permit to operate a commercial or service-type free customs zone, as well as mechanisms for controlling the activities of the enterprise.

In particular, a list of documents and information that are submitted with the application has been established. If the relevant information is already contained in state registers, customs authorities will receive it independently through the Trembita electronic interaction system, without involving the applicant.

To register a FCZ, an enterprise must meet a number of technical and organizational requirements, including:

  • territory of a FCZ must be fenced and equipped with video surveillance systems, access control, lighting, weighing systems, security and fire alarms;
  • for road transport, automatic reading of license plates and electronic registration of vehicles are mandatory;
  • the enterprise is obliged to ensure accounting and control of goods in the zone and submit reports on their movement in the approved form.

Consideration of an application for registration of a FCZ involves a two-level check:

  • analysis of submitted documents;
  • actual inspection of the objects by a commission of the customs authority.

The preliminary review lasts up to 10 days, and the decision to grant a permit is made within 20 days with the possibility of extension in cases provided for by the Customs Code of Ukraine. In case of detection of non-conformities, the enterprise is guaranteed the right to be heard.

After receiving the permit, the enterprise is included in a special register of a FCZ. Its activities will be under constant monitoring using a risk-based approach, which should minimize interference in economic activities.

Enterprises are required to regularly submit reports to customs authorities on the movement of goods in the free customs zone.

The permit to operate a FCZ may be suspended or revoked in the event of violation of customs legislation or failure to comply with the conditions of the permit, in particular in the event of refusal of access by customs authorities or failure to provide necessary documents.

Permits for the opening and operation of FCZs issued before the new Procedure comes into force remain valid for 12 months from the date of entry into force of Law of Ukraine No. 3926-IX of August 22, 2024. The Law comes into force on April 19, 2025, so the validity period of such permits gradually expires.

At the same time, the activities of enterprises with "old" permits are carried out taking into account the following features:

  • requirements for the development of territories are applied according to the rules in force at the time of issuing the permit;
  • customs control, accounting of goods and reporting are carried out in accordance with the norms of the Customs Code of Ukraine;
  • transactions with goods are carried out within the limits permitted on the date of receipt of the permit, insofar as this does not contradict Article 73-6 of the Customs Code;
  • old permit is canceled simultaneously with the receipt of a new permit for the operation of the FCZ.
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