Ukraine
Retail_Trading_Status
- Analysis ID
- #813
- Version
- Archived
- Created
- 2025-12-12 05:21
- Run
- 473fe15b...
- History
- View all versions
- Workflow Stage
- Step 1
Executive Summary
Cryptocurrency in Ukraine currently occupies a legal gray zone. While the landmark 'Law on Virtual Assets' was signed by President Zelenskyy in March 2022, it remains legally dormant because its entry into force is conditional on the passage of specific amendments to the Tax Code, which have not yet been finalized as of late 2025. Consequently, there is no active licensing regime for Virtual Asset Service Providers (VASPs), and the National Bank of Ukraine (NBU) strictly limits fiat-to-crypto on-ramps (via 'quasi-cash' restrictions and P2P transfer caps) to preserve financial stability during martial law.
Key Pillars
National Securities and Stock Market Commission (NSSMC) (Designated primary regulator for VASPs once law is active)
National Bank of Ukraine (NBU) (Regulates stablecoins/asset-backed tokens and enforces capital controls)
Ministry of Digital Transformation (Policy advocate and developer of the virtual assets ecosystem)
State Financial Monitoring Service (AMLA enforcement for high-risk financial transactions)
Landmark Laws
Law on Virtual Assets (No. 2074-IX) (Law No. 2074-IX) - Enacted: 2022-02-17
- Establishes the legal status of virtual assets as intangible goods and outlines a regulatory framework. However, the law explicitly states it will not enter into force until amendments to the Tax Code are adopted.
- Source
Draft Law on Amendments to the Tax Code (No. 10225-d) (Bill No. 10225-d)
- A revised bill introduced in 2024/2025 to align Ukraine's crypto taxation and classification with the EU's MiCA regulation. As of late 2025, it has passed the first reading but is not yet law.
- Source
NBU Resolution on 'Quasi-Cash' Transactions (NBU Resolution No. 18) - Enacted: 2022-04-20
- Prohibits individuals from purchasing cryptocurrency (quasi-cash) using national currency (UAH) from Ukrainian bank accounts to prevent capital flight during martial law.
- Source
Considerations
Legal Vacuum: Until the Tax Code amendments pass, the VASP licensing regime is non-operational.
Banking Blockade: Direct purchases of crypto with UAH cards are largely blocked by the NBU's 'quasi-cash' restrictions.
P2P Restrictions: The NBU has imposed limits on P2P transfers (e.g., 150,000 UAH/month) to curb tax evasion and 'drop' schemes, complicating peer-to-peer crypto trading.
Martial Law: Capital controls are strict; crypto is often viewed by the central bank as a vehicle for capital flight.
MiCA Alignment: New draft laws are explicitly modeled on the EU's Markets in Crypto-Assets (MiCA) regulation.
Notes
The analysis assumes the current date is December 12, 2025. Recent reports indicate the parliament advanced the tax bill in September 2025, but final enactment is pending. The 'Gray-Zone' status is heavily influenced by the disconnect between the 2022 Law (passed but inactive) and the operational reality of banking bans.
Remaining Uncertainties
- Exact date for the second reading and final adoption of Draft Law No. 10225-d.
- Whether the NBU will relax 'quasi-cash' restrictions before the end of martial law.
- Specifics of the transition period for existing gray-market exchanges once the new law is active.
Full Analysis Report
Full Analysis Report
As of December 2025, the regulatory status of cryptocurrency in Ukraine is best classified as a 'Gray-Zone'. Although the country is widely recognized for high adoption rates and a pro-innovation government stance, the legal framework remains in a state of suspended animation. The 'Law on Virtual Assets', signed in early 2022, was designed to launch a fully regulated market. However, a specific clause within the law dictates that it cannot enter into force until the parliament adopts corresponding amendments to the Tax Code. These amendments have faced significant delays and revisions, leaving the market without a functional licensing regime or clear tax rules.
Operationally, retail trading faces significant friction due to martial law measures enforced by the National Bank of Ukraine (NBU). Since April 2022, the NBU has prohibited the purchase of 'quasi-cash' assets (including cryptocurrency) using the national currency (UAH) to prevent capital outflows. This effectively blocks direct fiat on-ramps via local bank cards. While users initially shifted to Peer-to-Peer (P2P) platforms, the NBU further tightened controls in late 2024 and 2025 by imposing monthly caps on P2P transfers (e.g., 150,000 UAH limits) and pressuring banks to sever ties with high-risk payment processors used by exchanges.
The legislative landscape is currently focused on Draft Law No. 10225-d, which aims to overhaul the stalled 2022 framework and align it with the European Union's MiCA regulation. This bill proposes an 18% tax on crypto investment income (plus a military levy) and establishes the National Securities and Stock Market Commission (NSSMC) as the primary supervisor. In September 2025, the parliament passed this bill in the first reading, signaling progress, but until it passes the second reading and is signed into law, the 'legal vacuum' persists.
Despite these restrictions, holding and trading cryptocurrency is not a criminal offense. Citizens are free to own digital assets, and the government actively uses crypto for fundraising (e.g., Aid For Ukraine). However, the lack of a live licensing regime means that no 'Allowed-Regulated' status exists, and the active banking prohibitions prevent an 'Allowed-UnRegulated' classification. Thus, the environment is one of tolerated ownership but restricted access and regulatory uncertainty.
As of December 2025, the regulatory status of cryptocurrency in Ukraine is best classified as a 'Gray-Zone'. Although the country is widely recognized for high adoption rates and a pro-innovation government stance, the legal framework remains in a state of suspended animation. The 'Law on Virtual Assets', signed in early 2022, was designed to launch a fully regulated market. However, a specific clause within the law dictates that it cannot enter into force until the parliament adopts corresponding amendments to the Tax Code. These amendments have faced significant delays and revisions, leaving the market without a functional licensing regime or clear tax rules. Operationally, retail trading faces significant friction due to martial law measures enforced by the National Bank of Ukraine (NBU). Since April 2022, the NBU has prohibited the purchase of 'quasi-cash' assets (including cryptocurrency) using the national currency (UAH) to prevent capital outflows. This effectively blocks direct fiat on-ramps via local bank cards. While users initially shifted to Peer-to-Peer (P2P) platforms, the NBU further tightened controls in late 2024 and 2025 by imposing monthly caps on P2P transfers (e.g., 150,000 UAH limits) and pressuring banks to sever ties with high-risk payment processors used by exchanges. The legislative landscape is currently focused on Draft Law No. 10225-d, which aims to overhaul the stalled 2022 framework and align it with the European Union's MiCA regulation. This bill proposes an 18% tax on crypto investment income (plus a military levy) and establishes the National Securities and Stock Market Commission (NSSMC) as the primary supervisor. In September 2025, the parliament passed this bill in the first reading, signaling progress, but until it passes the second reading and is signed into law, the 'legal vacuum' persists. Despite these restrictions, holding and trading cryptocurrency is not a criminal offense. Citizens are free to own digital assets, and the government actively uses crypto for fundraising (e.g., Aid For Ukraine). However, the lack of a live licensing regime means that no 'Allowed-Regulated' status exists, and the active banking prohibitions prevent an 'Allowed-UnRegulated' classification. Thus, the environment is one of tolerated ownership but restricted access and regulatory uncertainty.
Source Evidence
Primary and secondary sources cited in this analysis
"This Law shall enter into force on the day of entry into force of the Law of Ukraine on Amendments to the Tax Code of Ukraine regarding the peculiarities of taxation of transactions with virtual assets."
"Individuals may purchase assets that are directly convertible into cash (quasi-cash transactions) using their own foreign currency... Limit: UAH 100,000 per month."
"The launch of the virtual assets market requires changes to the Tax Code."
"Ukraine's parliament passed in the first reading on Sept. 3 a draft law to legalize the country's virtual assets market... The foundational 'On Virtual Assets' law... remains inactive pending crucial amendments."
"Starting October 1, the National Bank of Ukraine will impose restrictions on outgoing P2P transfers... The limit is set at 150,000 hryvnias per month."
Web Sources (8)
Sources discovered via web search grounding
Search queries used (5)
- legal status of cryptocurrency in Ukraine 2025
- National Bank of Ukraine crypto restrictions P2P transfers 2024
- NSSMC Ukraine crypto regulation update 2025
- Ukraine crypto tax code amendments status 2024 2025
- Ukraine Law on Virtual Assets entry into force status 2024 2025
https://www.tradingview.com/news/coinpedia:f21a44f8d094b:0-crypto-regulations-in-ukraine-2025/
https://www.lightspark.com/knowledge/is-crypto-legal-in-ukraine
https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/ukraine/
https://www.fedoryshyn.com/en/virtual-assets-and-cryptocurrencies-whats-new-in-tax-regulation-in-2025/
https://kyivindependent.com/parliament-backs-draft-law-to-legalize-tax-virtual-assets-in-first-reading/
https://golaw.ua/insights/publication/novij-etap-regulyuvannya-virtualnih-aktiviv-v-ukrayini-shho-zminyuyetsya-dlya-biznesu-ta-investoriv/
https://sk.ua/ukraines-central-bank-introduced-stringent-restrictions-on-crypto-purchases-and-other-quasi-cash-transactions-using-local-currency/
https://www.kyivpost.com/post/50071