Table of Contents
The following article was produced in a partnership between Ukraine Rebuild Newswire and the top 10 global law firm CMS designed to better inform companies considering helping to rebuild Ukraine. Much of the article was based on a CMS analysis published here.
The Ukrainian central bank's draft Regulation on Open Banking is set to introduce rules for data sharing between banks and third-party providers, making possible a new generation of financial services such as pro-active personal budgeting apps, instant loan approvals, and direct-from-account online payments.
The regulation, to take effect Aug. 1, would let third-party payment service providers, such as account information and payment initiation firms, access bank account data of consumers and initiate payments via standardised digital interfaces.
"Open banking will mark a significant milestone in the development of Ukraine’s digital financial ecosystem," says Ihor Olekhov, Partner and head of Banking & Finance Practice in Kyiv at CMS, who authored an analysis of the regulation. "The regulation is set to usher in a host of new applications and services that are now common in many European Union nations but aren't yet possible in Ukraine."
The regulation can open opportunities in Ukraine for licensed fintechs, budgeting apps, or loan platforms—and allow those service providers to initiate payments on behalf of willing customers. This could open the way to personalized, and competitive financial products—such as tailored loan offers, all-in-one account dashboards, and smarter budgeting tools.
Real-time data access, strong authentication
Open banking, already widely adopted across the European Union, allows third-party providers to access account information or initiate transactions via standardized digital interfaces, known as APIs, with user permission. Ukraine’s draft regulation follows this model and stems from the “On Payment Services” law enacted in 2022, which brought the country’s financial legislation closer to European Union standards.
In the EU, it has enabled a new generation of financial services—from budgeting apps that consolidate account data across banks, to lenders that use real-time banking data for faster, more personalized credit decisions. Other tools automate savings based on spending patterns, while payment services let users pay merchants directly from their bank accounts, bypassing card networks and reducing fees.
Under the Ukrainian draft legislation, banks and non-bank payment service providers will be required to ensure real-time data access, strong authentication, and secure infrastructure. Customers will be able to manage their consent remotely and withdraw it at any time; for account information services, consent can last up to 180 days.
The regulation also imposes obligations on both banks and third parties, including data storage for five years, fraud monitoring, user complaint procedures, and mandatory reporting to the National Bank of Ukraine.
The central bank says the measure will support Ukraine’s digital transformation and align its financial sector with EU best practices. CMS is coordinating stakeholder feedback ahead of final approval.
For further details, contact CMS at: Ihor.Olekhov@cms-cmno.com
