The National Bank of Ukraine (NBU) announced that it cannot support bill No. 10225-d, the proposed legislation on virtual assets, in its current form and has urged lawmakers to make significant changes before a second reading. This statement follows a parliamentary committee decision to return the bill to the floor for further consideration.
Regulatory concerns and bill timeline
Ukraine’s Committee on Finance, Tax and Customs Policy recently endorsed the draft law for a second reading and full adoption, with 20 members approving the move. Under the bill, the National Securities and Stock Market Commission (NSSMC) would take on the role of primary regulator for the digital asset sector, while the NBU would oversee electronic money tokens. The proposed rules are scheduled to take effect from July 1, 2027.
The NBU stated that it only received the final draft late on November 3 and criticized the lack of transparency throughout the legislative process. According to Deputy Governor Oleksii Shaban, multiple compromises previously reached in working groups involving lawmakers, the NSSMC, industry participants, government representatives, and international partners were omitted from the latest version.
The NBU said the preparation of the draft law lacked sufficient transparency and did not allow for full expert engagement, noting that many agreed compromises were not reflected in the final text.
Key objections from the central bank
One major concern highlighted by the NBU relates to foreign tokens that can function as electronic money within Ukraine. The central bank warned these digital tokens might enter the local market without adequate regulation or oversight from their jurisdiction of origin. The NBU requested the authority to review such foreign tokens and restrict them if necessary, as it already does with tokens issued domestically.
The bank also expressed opposition to any approach that would allow foreign virtual assets to bypass regulations applied to similar Ukrainian products. The NBU cautioned against the risk of regulatory arbitrage, where market participants might exploit disparities between different legal regimes.
Monopoly and licensing risks
Another significant issue raised by the NBU involves potential monopolization and corruption linked to the NSSMC’s role in licensing market participants. Initially, the central bank advocated for unlimited trading platform operators, provided they met statutory requirements. The NBU later accepted an NSSMC compromise to permit three platforms, selected through competitive processes, during the first phase. However, the latest draft does not specify the number of licensed operators for the first five years, leaving this decision solely to the NSSMC.
| Regulatory Body | Draft Role | Central Bank Position | Latest Version Control |
|---|---|---|---|
| NBU | Oversight of e-money tokens | Requests more authority, initially preferred main regulatory role | Limited authority, seeks greater oversight of foreign tokens |
| NSSMC | Main crypto market regulator | NBU raised risks of monopoly and unchecked licensing | Decides number of licensed operators in initial years |
This issue touches on who holds the ultimate power to decide who may enter Ukraine’s digital asset market. While an earlier 2025 draft assigned regulatory responsibility to the NBU, the current text grants the authority to the NSSMC. The split has left the law without unanimous regulatory support as it moves toward a plenary vote.
Legislative path ahead
The Verkhovna Rada first approved the bill in an initial reading on September 3, 2025. However, the second reading was postponed to the autumn due to ongoing disagreements among agencies and insufficient votes, according to parliament member Olha Vasylevska-Smahliuk. Yaroslav Zheleznyak, first deputy chair of the committee, indicated that a plenary vote is expected in November.
The NBU reiterated its support for regulating Ukraine’s virtual asset sector in alignment with the European Union’s Markets in Crypto-Assets (MiCA) framework, and stated it remains committed to constructive engagement with lawmakers to improve the draft law.
Mini dictionary: MiCA — The Markets in Crypto-Assets (MiCA) framework is an EU regulation aimed at establishing harmonized rules for crypto asset markets, providing legal certainty for issuers and service providers, and enhancing investor protection throughout the European Union.
