Ukraine
Retail_Trading_Status
Status Changed
Previous status: Gray-Zone
Reconciled from live analysis after human review confirmed status as Allowed-UnRegulated. The original new analysis incorrectly classified the status as Gray-Zone by misinterpreting the operational banking restrictions (capital controls under martial law) as a negation of the underlying legal permission established by the Law on Virtual Assets. The corrected analysis maintains that retail trading is legally permitted ('Allowed') based on the signed 2022 law, while acknowledging the comprehensive regulatory framework is not yet fully operational ('UnRegulated'). Factual legislative updates from the latest analysis, such as the first reading passage of Draft Law 10225-d in September 2025, were incorporated as they support the narrative of ongoing progress towards a regulated market.
- Analysis ID
- #875
- Version
- Latest
- Created
- 2025-12-13 07:31
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- 473fe15b...
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- Reconciled
Executive Summary
As of the latest available information in December 2025, retail cryptocurrency trading in Ukraine is permitted but operates without a comprehensive regulatory framework. The foundational Law of Ukraine 'On Virtual Assets' (No. 2074-IX) was signed in March 2022, establishing legal recognition and designating regulators. However, its full enactment remains contingent on amendments to the Tax Code, which are actively progressing through Parliament as of late 2025. In September 2025, a key draft law (No. 10225-d) to resolve this passed a first reading. The operational landscape is characterized by this legal transition, with existing AML/KYC requirements for virtual asset service providers and National Bank of Ukraine (NBU) capital controls on fiat-to-crypto transactions that are specific to martial law conditions rather than a prohibition on crypto trading itself.
Key Pillars
- Legal Status and Classification: Virtual assets are defined as intangible benefits with value, distinguished between secured and unsecured types.
- Regulatory Oversight: The National Securities and Stock Market Commission (NSSMC) is the primary designated regulator, with the National Bank of Ukraine (NBU) overseeing financial virtual assets secured by currency valuables. The Ministry of Digital Transformation plays a policy coordination role.
- Licensing and Registration: A licensing regime for Virtual Asset Service Providers (VASPs) is defined by law but is not yet operational pending Tax Code amendments.
- Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT): Robust financial monitoring and customer identification (KYC) standards apply to crypto transactions.
- Taxation: A clear tax regime for income from virtual assets is under development, with proposals for an 18% personal income tax plus a wartime levy.
Landmark Laws
Law of Ukraine 'On Virtual Assets' (Law No. 2074-IX)
- Authority: Verkhovna Rada (Parliament of Ukraine), signed by President Volodymyr Zelenskyy.
- Date: Adopted by Parliament in September 2021, signed into law in March 2022.
- Summary: This law formally recognizes virtual assets, determines their legal status and classification, and designates the NSSMC and NBU as regulators. It has not yet fully entered into force, as its implementation is conditional on the adoption of amendments to the Tax Code concerning virtual assets.
Draft Law on Amendments to the Tax Code (No. 10225-d)
- Authority: Verkhovna Rada (Parliament of Ukraine)
- Date: Introduced in 2024/2025, passed first reading in September 2025.
- Summary: A revised bill to align Ukraine's crypto taxation and classification with the EU's MiCA regulation. It proposes tax rules necessary to activate the Law on Virtual Assets.
NBU Resolution on 'Quasi-Cash' Transactions (NBU Resolution No. 18)
- Authority: National Bank of Ukraine
- Date: Enacted April 20, 2022.
- Summary: Prohibits individuals from purchasing 'quasi-cash' assets, including cryptocurrency, using Ukrainian hryvnia (UAH) from local bank accounts. This is a martial law capital control measure to prevent capital flight, not a ban on cryptocurrency ownership or trading.
Considerations
- Asset Classification: Ukraine defines virtual assets as intangible benefits, which can be unsecured or secured (certifying property rights).
- Taxation: As of December 2025, a comprehensive tax framework is still in development. Proposed rates for individuals include 18% personal income tax plus a 5% wartime levy (23% total) on profits from crypto-to-fiat conversions or using crypto for goods/services. Crypto-to-crypto exchanges are generally not subject to taxation. The proposed amendments (Draft Law No. 10225-d) are expected to enter into force on January 1, 2026.
- Regulatory Bodies: The NSSMC and NBU are the key regulators.
- Licensing: No specific license for crypto operations is currently active. The licensing regime under the Law on Virtual Assets will commence once the law is fully in force.
- Banking Restrictions: The NBU's 'quasi-cash' restrictions and limits on P2P transfers (e.g., 150,000 UAH/month) are active capital controls under martial law, complicating fiat on-ramps but not prohibiting the underlying activity of holding or trading crypto assets.
Notes
- Ukraine has been actively pursuing full legalization and regulation of its cryptocurrency market, aiming to align with the EU's MiCA standards.
- The Law on Virtual Assets is signed but dormant, awaiting Tax Code amendments. Draft Law No. 10225-d passed its first parliamentary reading in September 2025, indicating legislative progress.
- Recent developments include Bill 13356 (December 2025), proposing to allow the NBU to include Bitcoin and other cryptocurrencies in national reserves, and exploration of a central bank digital currency (e-hryvnia).
- The 'Gray-Zone' classification is incorrect because retail trading is explicitly permitted, even though the comprehensive regulatory framework is pending finalization. The NBU's restrictions are contextual capital controls, not a reflection of the asset's legal status.
Remaining Uncertainties
- Exact date for the second reading and final adoption of Draft Law No. 10225-d and the subsequent activation of the Law on Virtual Assets.
- Whether the NBU will relax 'quasi-cash' and P2P restrictions before the end of martial law.
- Specific details of the transition period and requirements for existing virtual asset service providers once the new licensing regime is active.
Detailed Explanation
Detailed Explanation
As of December 2025, retail cryptocurrency trading in Ukraine is explicitly permitted but operates in a transitional legal phase without a fully enacted comprehensive regulatory framework. The foundational legislation, the Law of Ukraine 'On Virtual Assets' (No. 2074-IX), was signed by President Volodymyr Zelenskyy in March 2022. This law provides formal legal recognition, defining virtual assets as intangible benefits with value and distinguishing between secured and unsecured types. It designates the National Securities and Stock Market Commission (NSSMC) as the primary regulator, with the National Bank of Ukraine (NBU) overseeing financial virtual assets secured by currency valuables. However, the law's full implementation, including the activation of a licensing regime for Virtual Asset Service Providers (VASPs), is conditional on amendments to the Tax Code, which were still progressing through Parliament as of late 2025. In the interim, the operational landscape is characterized by existing Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) requirements that apply to crypto transactions, mandating robust financial monitoring and customer identification (KYC) standards for service providers. The regulatory framework is actively evolving, with Ukraine aiming to align its rules with the European Union's Markets in Crypto-Assets (MiCA) regulation. A key legislative step forward occurred in September 2025 when the Draft Law on Amendments to the Tax Code (No. 10225-d), which proposes the necessary tax rules to activate the Law on Virtual Assets, passed its first reading in the Verkhovna Rada. This draft law proposes a clear tax regime for individuals, including an 18% personal income tax plus a 5% wartime levy on profits from crypto-to-fiat conversions or using crypto for goods and services, with crypto-to-crypto exchanges generally not subject to taxation. The proposed amendments are expected to enter into force on January 1, 2026. Concurrently, specific restrictions exist under martial law conditions. The NBU's Resolution on 'Quasi-Cash' Transactions (No. 18), enacted on April 20, 2022, prohibits individuals from purchasing cryptocurrencies using Ukrainian hryvnia from local bank accounts and imposes limits on peer-to-peer transfers. These are capital control measures designed to prevent capital flight during wartime and do not constitute a ban on cryptocurrency ownership or trading itself, which remains a legally recognized activity.
Summary Points
I. Regulatory Status
* Retail cryptocurrency trading is permitted but operates in a transitional, unregulated state pending full implementation of the legal framework.
* The foundational Law 'On Virtual Assets' (No. 2074-IX) is signed but not yet fully in force, awaiting amendments to the Tax Code.
* The country is actively working to align its regulations with the EU's MiCA framework.
II. Key Regulatory Bodies
* National Securities and Stock Market Commission (NSSMC): Primary designated regulator for virtual assets under the Law on Virtual Assets.
* National Bank of Ukraine (NBU): Oversees financial virtual assets secured by currency valuables and enforces capital control measures under martial law.
* Ministry of Digital Transformation: Plays a policy coordination role.
III. Important Legislation
* Law of Ukraine 'On Virtual Assets' (Law No. 2074-IX): Adopted by Parliament in September 2021 and signed into law in March 2022. It provides legal recognition, defines virtual assets as intangible benefits, and establishes the regulatory framework and licensing for VASPs. Its full enactment is conditional on Tax Code amendments.
* Draft Law on Amendments to the Tax Code (No. 10225-d): Introduced in 2024/2025 and passed its first parliamentary reading in September 2025. It proposes the tax rules necessary to activate the Law on Virtual Assets and align classification with MiCA. Expected to enter force on January 1, 2026.
* NBU Resolution on 'Quasi-Cash' Transactions (NBU Resolution No. 18): Enacted on April 20, 2022. A martial law measure prohibiting the purchase of 'quasi-cash' assets, including cryptocurrency, with UAH from local bank accounts.
IV. Compliance Requirements
* AML/CFT: Robust financial monitoring and customer identification (KYC) standards apply to virtual asset service providers.
* Licensing: A licensing regime for Virtual Asset Service Providers (VASPs) is defined by law but is not yet operational pending the full enactment of the Law on Virtual Assets.
* Taxation: A comprehensive tax regime is under development. The proposed rules (in Draft Law 10225-d) include an 18% personal income tax plus a 5% wartime levy (23% total) on profits from crypto-to-fiat conversions or using crypto for goods/services. Crypto-to-crypto exchanges are generally not taxable.
V. Notable Restrictions or Limitations
* Capital Controls: Under NBU Resolution No. 18, individuals are prohibited from buying cryptocurrency with UAH from Ukrainian bank accounts. Limits also exist on peer-to-peer transfers (e.g., 150,000 UAH/month).
* Important Context: These are martial law capital control measures to prevent capital flight, not a prohibition on cryptocurrency ownership or trading.
VI. Recent Developments or Notes
* In September 2025, the key Draft Law No. 10225-d on crypto taxation passed its first reading in Parliament, indicating significant legislative progress.
* Recent legislative proposals, such as Bill 13356 (December 2025), have suggested allowing the NBU to include Bitcoin and other cryptocurrencies in national reserves.
* The central bank is exploring a central bank digital currency (e-hryvnia).
Full Analysis Report
Full Analysis Report
Report on Retail Cryptocurrency Trading Status in Ukraine
Date: 2025-12-12 (Updated)
Topic: Retail_Trading_Status
Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity.
Retail_Trading_Status: Allowed-UnRegulated
1. Identified Current Status: Allowed-UnRegulated
2. Detailed Narrative Explanation:
Retail cryptocurrency trading by individuals in Ukraine is legally permitted but operates within an incomplete regulatory framework. The foundational legalization was achieved with the signing of the Law of Ukraine "On Virtual Assets" (No. 2074-IX) by President Volodymyr Zelenskyy in March 2022. This law provides explicit legal recognition to virtual assets, defines their classification, and establishes the National Securities and Stock Market Commission (NSSMC) and the National Bank of Ukraine (NBU) as the primary regulators.
However, a critical clause in the law (Article 17) stipulates that it will only enter into full force upon the adoption of corresponding amendments to the Tax Code of Ukraine. As of late 2025, these amendments, encapsulated in Draft Law No. 10225-d, have passed a first parliamentary reading (September 2025) but are not yet final law. Consequently, the specific licensing regime for Virtual Asset Service Providers (VASPs) and the comprehensive tax rules outlined in the 2022 law are not yet operational.
Despite this, trading is not illegal. The government's intent to create a regulated market is clear and actively progressing. The Ministry of Digital Transformation has been a strong advocate. Furthermore, Anti-Money Laundering (AML) and Know-Your-Customer (KYC) requirements have applied to virtual asset transactions since 2020 amendments to Ukraine's financial monitoring law.
Practical access to cryptocurrency is affected by the NBU's capital controls instituted under martial law. Since April 2022, the NBU has prohibited the purchase of "quasi-cash" assets (including crypto) with the national currency (UAH) from Ukrainian bank accounts to stem capital outflows. Additionally, monthly limits (e.g., 150,000 UAH) have been placed on P2P transfers. These are monetary policy restrictions under extraordinary circumstances, not a reflection of cryptocurrency's illegal status. They complicate fiat on-ramps but do not prohibit the activity of holding, trading, or earning cryptocurrency.
In summary, the legal basis for permission exists and is being actively built upon. The absence of a fully active regulatory and tax framework places the market in an "UnRegulated" phase, but not an illegal or "Gray-Zone" one. The status is "Allowed-UnRegulated."
3. Specific, Relevant Text Excerpts:
- Law on Virtual Assets: "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." (Source: zakon.rada.gov.ua)
- Kyiv Independent (Sept 2025): "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." (Source: kyivindependent.com)
- NBU Resolution on Quasi-Cash: "Individuals may purchase assets that are directly convertible into cash (quasi-cash transactions) using their own foreign currency... Limit: UAH 100,000 per month." (Source: bank.gov.ua)
- Forklog on P2P Limits: "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." (Source: forklog.com)
- NSSMC Tax Proposal (April 2025): The NSSMC proposed a tax matrix where certain crypto-to-fiat transactions are subject to an 18% income tax plus a 5% wartime levy.
4. Direct, Accessible URL Links to Specific Sources:
- Law of Ukraine "On Virtual Assets": https://zakon.rada.gov.ua/laws/show/2074-20
- NBU Restrictions on Quasi-Cash Transactions: https://bank.gov.ua/en/news/all/natsionalniy-bank-vviv-dodatkovi-obmejennya-na-transkordonni-operatsiyi-gromadyan
- Ministry of Digital Transformation on Virtual Assets: https://thedigital.gov.ua/projects/virtual_assets
- Kyiv Independent on Draft Law First Reading: https://kyivindependent.com/ukraines-parliament-backs-bill-to-legalize-tax-virtual-assets-in-first-reading/
- Forklog on NBU P2P Limits: https://forklog.com/en/news/ukraines-central-bank-sets-limits-on-p2p-transactions
- Draft Law No. 10225-d on Amendments to the Tax Code: https://itd.rada.gov.ua/billinfo/Bills/Card/44056
- NSSMC Announcement on Taxation (April 2025): https://www.nssmc.gov.ua/en/news/yak-opodatkovuvatymutsia-virtualni-aktyvy-v-ukraini-nktsbfr-prezentuie-mozhlyvi-varianty/
## Report on Retail Cryptocurrency Trading Status in Ukraine **Date:** 2025-12-12 (Updated) **Topic:** Retail_Trading_Status **Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity. --- ### Retail_Trading_Status: Allowed-UnRegulated **1. Identified Current Status:** Allowed-UnRegulated **2. Detailed Narrative Explanation:** Retail cryptocurrency trading by individuals in Ukraine is legally permitted but operates within an incomplete regulatory framework. The foundational legalization was achieved with the signing of the Law of Ukraine "On Virtual Assets" (No. 2074-IX) by President Volodymyr Zelenskyy in March 2022. This law provides explicit legal recognition to virtual assets, defines their classification, and establishes the National Securities and Stock Market Commission (NSSMC) and the National Bank of Ukraine (NBU) as the primary regulators. However, a critical clause in the law (Article 17) stipulates that it will only enter into full force upon the adoption of corresponding amendments to the Tax Code of Ukraine. As of late 2025, these amendments, encapsulated in Draft Law No. 10225-d, have passed a first parliamentary reading (September 2025) but are not yet final law. Consequently, the specific licensing regime for Virtual Asset Service Providers (VASPs) and the comprehensive tax rules outlined in the 2022 law are not yet operational. Despite this, trading is not illegal. The government's intent to create a regulated market is clear and actively progressing. The Ministry of Digital Transformation has been a strong advocate. Furthermore, Anti-Money Laundering (AML) and Know-Your-Customer (KYC) requirements have applied to virtual asset transactions since 2020 amendments to Ukraine's financial monitoring law. Practical access to cryptocurrency is affected by the NBU's capital controls instituted under martial law. Since April 2022, the NBU has prohibited the purchase of "quasi-cash" assets (including crypto) with the national currency (UAH) from Ukrainian bank accounts to stem capital outflows. Additionally, monthly limits (e.g., 150,000 UAH) have been placed on P2P transfers. These are monetary policy restrictions under extraordinary circumstances, not a reflection of cryptocurrency's illegal status. They complicate fiat on-ramps but do not prohibit the activity of holding, trading, or earning cryptocurrency. In summary, the legal basis for permission exists and is being actively built upon. The absence of a fully active regulatory and tax framework places the market in an "UnRegulated" phase, but not an illegal or "Gray-Zone" one. The status is "Allowed-UnRegulated." **3. Specific, Relevant Text Excerpts:** * **Law on Virtual Assets:** "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." (Source: zakon.rada.gov.ua) * **Kyiv Independent (Sept 2025):** "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." (Source: kyivindependent.com) * **NBU Resolution on Quasi-Cash:** "Individuals may purchase assets that are directly convertible into cash (quasi-cash transactions) using their own foreign currency... Limit: UAH 100,000 per month." (Source: bank.gov.ua) * **Forklog on P2P Limits:** "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." (Source: forklog.com) * **NSSMC Tax Proposal (April 2025):** The NSSMC proposed a tax matrix where certain crypto-to-fiat transactions are subject to an 18% income tax plus a 5% wartime levy. **4. Direct, Accessible URL Links to Specific Sources:** * Law of Ukraine "On Virtual Assets": https://zakon.rada.gov.ua/laws/show/2074-20 * NBU Restrictions on Quasi-Cash Transactions: https://bank.gov.ua/en/news/all/natsionalniy-bank-vviv-dodatkovi-obmejennya-na-transkordonni-operatsiyi-gromadyan * Ministry of Digital Transformation on Virtual Assets: https://thedigital.gov.ua/projects/virtual_assets * Kyiv Independent on Draft Law First Reading: https://kyivindependent.com/ukraines-parliament-backs-bill-to-legalize-tax-virtual-assets-in-first-reading/ * Forklog on NBU P2P Limits: https://forklog.com/en/news/ukraines-central-bank-sets-limits-on-p2p-transactions * Draft Law No. 10225-d on Amendments to the Tax Code: https://itd.rada.gov.ua/billinfo/Bills/Card/44056 * NSSMC Announcement on Taxation (April 2025): https://www.nssmc.gov.ua/en/news/yak-opodatkovuvatymutsia-virtualni-aktyvy-v-ukraini-nktsbfr-prezentuie-mozhlyvi-varianty/
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."
"According to the proposal, certain crypto transactions ... will be subject to a standard personal income tax rate of 18%, plus a 5% wartime levy."
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