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UkraineUkraine’s Virtual Assets Law 2074-IX has not entered into force, and bill 10225-d remains pending second reading. It does not establish an available VASP licence. Existing civil, tax, AML, sanctions and transfer rules can nevertheless affect activity. A tokenized offering requires assessment of the represented right and currently applicable financial permissions.
A business issuing a tokenized asset or providing virtual asset services in Ukraine must distinguish civil recognition of those assets from business authorisation. The 2022 sectoral Act remains identified as not yet in force, while tax and market reform is still under consideration.
The project nevertheless faces other requirements: investment, payments, anti-money laundering, taxes, wartime restrictions and sanctions must be assessed for the operation. Initial work should define holder rights and fund flows without assuming that a future licensing procedure is already open.
Why the Act adopted in 2022 is not an operational regime
The Rada legislative database identifies Virtual Assets Law 2074-IX as not yet in force. Enactment in February 2022 did not itself launch the contemplated regime. Commencement was linked to tax amendments. Its authorisation requirements should therefore not be described as an available procedure for establishing a platform.
Bill 10225-d, registered in April 2025, passed first reading on 3 September that year and remains under preparation for second reading. Inclusion in the September 2026 agenda is not final passage. Proposed categories, taxation and transition provisions may change before becoming applicable law.
Existing responsibilities and those proposed by reform
NBU and the National Securities and Stock Market Commission, NSSMC, retain their sectoral financial responsibilities. In its September 2026 position, the Commission proposes assigning electronic-money tokens to NBU and other categories and providers to NSSMC. This is a reform proposal, not a definitive operational VASP allocation.
For existing financial controls, NBU explains identification and transfer-information duties under AML legislation. A reference to virtual assets does not automatically create commercial exchange or custody permission. The responsible authority, compliance obligation and authorisation for the intended activity must be distinguished.
What can be prepared while sectoral licensing remains pending
An operational VASP licensing procedure under Law 2074-IX has not been established. Incorporation, a website or a foreign licence does not demonstrate Ukrainian approval. Models involving investment, securities intermediation or payments require assessment under those functions' existing financial regimes, without waiting for future dedicated legislation.
EY's April 2025 analysis distinguishes the tax proposal from existing rules, although its anticipated 2026 dates were conditional on enactment. They should not be reused as completed deadlines. Project preparation should document customers, countries, fund flows, custody and responsibilities before attributing a regulatory route that remains pending.
How the Civil Code distinguishes digital property and real estate
Civil Code Article 179-1, introduced in 2023, recognises digital things, including virtual assets, applying property rules subject to statutory or nature-based exceptions. This civil recognition is separate from commencement of the sectoral statute. It enables rights analysis without establishing that every token may be publicly offered.
Article 182 retains public registration of land rights. Recording a token on a network therefore does not replace property conveyance or registration. Equity, debt and receivables structures must identify issuers, obligations, formalities and circulation rules. NSSMC also distinguishes these economic functions in its tokenization proposals.
Restrictions and obligations still affecting fund flows
NBU Resolution 18, consolidated through September 2026 amendments, restricts transfers during martial law. Paragraph 14.9 includes cryptocurrency purchases within quasi-cash transactions and defines an exception for personal foreign-currency accounts. It does not establish unrestricted payments or authorise VASP services.
The tax administration's May 2026 guidance treats cryptocurrency-sale receipts under ordinary rules and requires examination of case-specific documents. Proposed exemptions are not assumed. Resolution 4930-IX of 14 July also approves the sanctions amendment under Decree 561/2026, affecting services and assets linked to Russia's financial sector on its specified terms.
What to verify before structuring a Ukrainian project
Preparation must separate current requirements from Bill 10225-d and recheck parliamentary status before deciding on launch. Civil Code recognition of digital property allows rights analysis but does not establish permission to offer it or provide services.
Document clients, countries, accounts, custodians and contracts, checking NBU and sanctions restrictions affecting those flows. Real estate and equity tokenization must respect formalities governing the represented right. Do not build in tax benefits or opening dates dependent on an unenacted reform.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- Enacted legislation is not necessarily in force.
- The Civil Code recognises digital things without creating a VASP licence.
- An absent bespoke tax regime does not remove existing taxation.
- Transfers, sanctions and underlying-asset permissions need separate assessment.
Regulatory milestones
Law 2074-IX enacted
Enactment with conditional commencement; this does not establish an operational regime.
Bill 10225-d passes first reading
Preparation for second reading continues without verified final passage.
Sanctions amendment approved
Resolution 4930-IX approves changes concerning Russia’s financial sector, including virtual assets and services.
Frequently asked questions
Rada’s official record identifies it as not in force. Bill 10225-d remains pending second reading and should not be treated as an available authorisation.
No. The tax administration applies ordinary rules to cryptocurrency transaction receipts. Proposed relief requires enactment and cannot be assumed.
No. The parliamentary record distinguishes agenda inclusion from preparation for second reading. The September 2025 first reading also does not amount to final passage. Rada · Bill 10225-d.
Distinguish digital property from the real estate right. Civil Code Article 182 retains registration of real estate rights; technical recording does not replace that formality. Civil Code · Digital assets.
No. NSSMC’s September 2026 position describes reform and subsequent preparation of rules, registers and systems. It does not establish a guaranteed operational date for the regulated market. NSSMC · September 2026 position.
