On October 13, 2026, the Board of the National Bank of Ukraine (NBU) approved Resolution No. 121, amending the Instruction on the Regulation of Banks' Activity in Ukraine. The document was officially published on October 14, most of its provisions took effect on October 15, and the headline figure everyone is talking about kicks in on January 3, 2027: the minimum regulatory capital a bank must hold rises from UAH 200 million to UAH 250 million.
At first glance this looks like a purely technical rule change that concerns a bank's accountants, not ordinary customers. In reality it is directly tied to how safely your money sits on a card, in a term deposit, or in a savings account, so it is worth unpacking what actually changed and why.
What the NBU changed on October 13
Resolution No. 121 updates several core requirements for banks at once.
- The minimum regulatory capital rises from UAH 200 million to UAH 250 million, with no separate transition period carved out for this specific rule.
- Banks must now meet capital adequacy ratios and the Liquidity Coverage Ratio (LCR), across all currencies, continuously rather than only on the reporting date, as before. In practice this closes the loophole of temporarily dressing up the numbers just for the snapshot date.
- If paying dividends to shareholders would breach the higher ratios, the bank is barred from paying them.
- The NBU now has a more explicit legal basis to impose stricter, individual capital and liquidity requirements on specific banks based on its supervisory assessment.
In plain terms, the regulator wants banks to carry a solid safety margin every single day, not just tick a box once a quarter, and it wants weaker or riskier institutions to strengthen their own balance sheet before paying out profit as dividends.
Where this requirement came from
The higher capital floor did not appear out of nowhere. On September 2, 2026, Ukraine's parliament passed a law raising banks' minimum statutory capital to the same UAH 250 million, giving existing banks six months to bring their capital in line. NBU Resolution No. 121 is the regulator's technical implementation of that requirement: it spells out exactly how compliance will be checked and what happens if a bank falls short.
According to research by the analytics platform VKURSI, as of mid-September, seven out of 59 solvent Ukrainian banks had statutory capital below the new threshold, with a combined shortfall of roughly UAH 302 million. The smallest gap belonged to Bank Avangard, which needed only about UAH 18.2 million more to reach the new minimum. The list also includes banks that are 100%-foreign-owned, such as Citibank, for which recapitalization is really a decision for the parent group rather than a sign of market weakness. The remaining 52 banks, roughly 88% of the system, already meet the new threshold.
What this means for your wallet
For an ordinary bank customer, this change in the rulebook is not a reason to panic or rush to withdraw money, but it is a good occasion to refresh a few financial habits.
First, a bigger capital cushion and continuous, rather than paper-only, liquidity monitoring mean a bank has a thicker buffer against losses or a sudden outflow of clients before depositors themselves get hurt. This is an extra layer of protection on top of the state deposit guarantee run by the Deposit Guarantee Fund (DGF), not a substitute for it: the DGF guarantee still only covers a set limit per person per bank, so keeping your entire savings in a single institution, however well-capitalized, is always risky.
A telling example of why capital and liquidity matter long before a problem becomes public is the case of JSC Motor-Bank. The NBU declared it insolvent on February 19, 2026, introduced temporary administration, and on April 6 revoked its license and began liquidation. Depositors received guaranteed compensation through the DGF, but the episode is a reminder that a bank with an insufficient capital cushion can end up under supervisory restrictions long before customers hear about it in the news.
Second, if you are choosing where to open a term deposit or a savings account for an amount above the guaranteed limit, look beyond the headline rate and check whether the bank meets the new capital rules. Small niche banks on the list of seven will most likely recapitalize or get support from their parent structures soon, but until that process is finished it is wise to treat their unusually high rates with some caution and compare offers across several institutions rather than chasing the single highest percentage.
Third, the ban on dividend payouts for banks that fail to hold the increased buffer is actually a good signal for customers: the regulator is directly forcing bank owners to strengthen capital first and only then take out profit, which reduces the temptation to drain a bank at the expense of its own stability.
Finally, if you are planning to open a new personal current or salary account, checking a bank's financial resilience, including whether it meets NBU capital rules, is just as natural a step as comparing fees or how convenient its app is.
What to do right now
- Check which bank holds your main savings and whether it appears among the institutions with a capital shortfall.
- Do not keep an amount significantly above the DGF-guaranteed limit in a single bank, even if its rate looks attractive.
- Compare several banks' offers on more than one criterion at once: rate, early-withdrawal conditions, capital strength, and reputation.
- Keep an eye on news about NBU supervision of specific banks: individual regulatory requirements often signal heightened attention to an institution well before any problem becomes public.
Bottom line
NBU Resolution No. 121 is a step toward stricter, continuous oversight of banks' capital and liquidity that brings Ukrainian banking supervision closer to European standards while giving customers an extra benchmark of reliability. The regulator's message is clear: UAH 250 million is the new entry threshold for the banking business, meeting the ratios is a daily obligation rather than a reporting-day formality, and dividends can only be paid once the higher requirements are met. For you as a customer, that is a good reason to check, every few months, where and how your money is kept, and to use BankSorter's comparisons of deposits, savings accounts, and personal accounts to pick a bank not just for the highest rate, but for its financial strength too.