Bank Account Seizure for a Sole Proprietor or Business: What to Do After the Bank Refuses a Payment

If the bank has refused a payment because funds are seized, obtain the document details, find out who imposed the restriction, and check its amount and scope. The next steps depend on the grounds: an enforcement officer’s order, an interim measure, criminal proceedings, or a court decision following an application by the tax authority. Paying the debt does not by itself restore payment access: a proper document lifting the seizure must be issued and acted on by the bank.

During martial law, separate rules apply to permitted spending from accounts seized by state or private enforcement officers. An individual may designate one account for monthly spending up to twice the minimum wage and for paying taxes and fees. Legal entities and self-employed persons with employees may make the salary, tax, fee, and unified social contribution (USC) payments specified by law. These rules do not give general permission to pay for stock, rent, or other store expenses from seized funds.

What to obtain from the bank after a payment is refused

Ask the bank for a written response or notice through an official service channel. Keep the rejected payment instruction, the refusal notice, and the date you learned of the restriction. That date may matter if you challenge it.

In your request, ask the bank to specify:

• the legal grounds for refusing the payment: seizure of funds, a ban on debit transactions, financial monitoring, or another restriction;
• the name of the authority, court, or enforcement officer that sent the document;
• the order, ruling, or decision number and date;
• the enforcement proceeding or court case number, if stated in the document;
• the amount seized, the currency, and the accounts affected;
• the scope of the ban: which transactions the bank will not process;
• whether there are any other documents restricting transactions with the funds.

Ask for a copy of the document if the bank can provide one. If it cannot, request it from the enforcement officer or court using the details you received. A verbal notice that “the account is blocked” is not enough to choose how to protect your rights.

Who imposed the restriction and where to apply

Financial monitoring and a seizure may apply at the same time. In that case, carrying out an order lifting the seizure does not remove the separate grounds for the bank’s refusal. Check each restriction separately.

How to find enforcement proceedings and a court case

Search using the proceeding number, debtor details, and enforcement officer’s details. Check the Automated Enforcement Proceedings System and the Unified Register of Debtors. To get full access to information about your enforcement proceeding, obtain the relevant access identifier from the enforcement officer.

Use the court case number to check information on the judiciary portal and documents in your electronic cabinet, if available there. A public search does not guarantee access to every document. No search result also does not prove that no seizure exists.

As a party to enforcement proceedings, you have the right to review their file. Ask the enforcement officer for the orders, enforcement instrument, and amount calculation. Check that your identifying details are correct, any previous payment has been credited, and there are no multiple proceedings.

Before paying, also check the special prohibitions and grounds for suspending enforcement under Section XIII of the Law “On Enforcement Proceedings.” In particular, proceedings may not be opened on the basis of notarial writs on loan agreements that have not been notarised. During martial law, restrictions apply to opening proceedings and enforcing decisions in territories on the established list of active hostilities and temporary occupation. For certain loan and leasing agreements specified by law, Clauses 10-7 and 10-8 provide for suspension of enforcement for the duration of the relevant moratorium. Additional special rules apply to certain enterprises and sectors. If such a rule applies to your situation, submit an application to the enforcement officer with evidence and obtain the proper order; suspension of enforcement does not always mean the seizure is lifted.

Why a seizure may affect several accounts

An enforcement officer first seeks recovery from the debtor’s funds. A seizure may cover funds at different banks and may also extend to accounts opened after the order was issued. Opening a new account does not guarantee that payments will resume.

Under the Law “On Enforcement Proceedings,” a seizure is imposed up to the amount to be recovered, taking into account the enforcement fee, proceeding expenses, fines, and the private enforcement officer’s basic fee. Check the actual wording of the order and all restrictions still in force. The principal debt may be less than the total amount needed to complete enforcement.

A sole proprietor’s ordinary business account is not protected from seizure just because store revenue is paid into it. Nor does designating funds for stock purchases or rent automatically prevent recovery.

How to release funds that are protected from recovery

The law protects certain accounts and payments. In particular, Article 48 of the Law “On Enforcement Proceedings” prohibits seizure and recovery of funds held in a single tax account, VAT electronic administration system accounts, electronic excise accounts, and other accounts for which the law establishes such protection.

Article 73 of that Law lists payments that cannot be subject to recovery. These include maternity benefits, childbirth and adoption benefits, certain types of child benefits, medical treatment and funeral benefits, severance pay, and specified compensation payments to employees.

Not every payment described as social assistance has the same protection. Salary is also not entirely exempt: the law provides for deductions from income within specified limits. Seizures imposed as interim relief in civil proceedings are subject to separate prohibitions and exceptions under Article 150 of the Civil Procedure Code of Ukraine. First establish the type of seizure and the specific source of the funds.

1. Obtain a bank certificate stating the account’s status and a statement showing the purpose of incoming payments.
2. Attach documents from the payer or authority that granted the protected payment.
3. Ask the bank to send the enforcement officer documents confirming that recovery is prohibited.
4. Submit your own application to the enforcement officer to lift the seizure from the relevant funds or account. Cite the legal provision and attach evidence.
5. Obtain the order and check that it has reached the bank and been acted on.

Under Article 59(2), the enforcement officer must lift the seizure from protected funds no later than the next business day after receiving the relevant documents from a bank or non-bank payment service provider. A different deadline applies to a court decision lifting the seizure: no later than the day after the enforcement officer learns that the decision has entered into force.

One account for an individual’s spending during martial law

An individual debtor, including a sole proprietor acting as an individual, may use the procedure for designating one current account for debit transactions. It applies to seizures imposed by state and private enforcement officers and remains in force until martial law ends or is lifted.

The monthly limit is twice the minimum wage set as of 1 January of the relevant year. In 2026, this is UAH 17,294: UAH 8,647 × 2. Recovery may not be made from the designated account within this amount. The law also allows taxes and fees to be paid from it without regard to the seizure.

This is permission to use funds already available, not a payment from the state or bank. One account and one monthly limit apply across all enforcement proceedings against that individual. The number of banks and enforcement officers does not increase the permitted amount.

How to apply to the enforcement officer

1. Choose one current account and check its IBAN and bank name.
2. Submit a signed application to the enforcement officer who imposed the seizure. State the IBAN and bank name. Include your details and proceeding number so you can be identified.
3. Submit the application in person, by post, or electronically in compliance with the requirements for electronic documents. Keep proof of submission.
4. Obtain the order designating the account and check that it has reached the bank.

The enforcement officer issues the order within two business days after receiving the application. Without delay, and no later than the next business day after issuing it, the officer sends the order to the bank and to other enforcement officers handling proceedings against the debtor. A suspension of enforcement actions or proceedings is not, by itself, grounds for refusing to designate an account.

When the request may be refused or the permission may end

The procedure introduced by Ministry of Justice Order No. 2578/5 provides for refusal if the application does not meet the requirements or is unsigned; an account has already been designated; the IBAN does not match the proceeding file; the proceeding has ended; or the enforcement instrument has been returned to the creditor. A separate ground is a seizure made while enforcing a court ruling on interim relief. If refused, obtain written notice stating the reason.

If you need to change the designated account, apply to the enforcement officer who issued the relevant order. An order designating a different account takes effect on the first day of the following month. Permission may end, for example, if the order is cancelled, another account is designated, or different accounts are found to have been designated at the same time.

If a private enforcement officer’s activity has been suspended, submit the application to the officer acting as their substitute. If no substitute has been appointed or the Ministry of Justice has not been notified of the appointment, contact the Department for Compulsory Enforcement of Decisions of the Directorate for Ensuring Compulsory Enforcement of Decisions whose jurisdiction covers that private officer’s enforcement district. If the private officer’s activity has ended, contact the temporary private enforcement officer or the officer or state enforcement service to which the proceedings were transferred. If a state enforcement service has ended, its successor considers the application. If the state enforcement service that imposed the seizure is located in a territory on the established list of active hostilities or temporary occupation, the relevant actions are taken by the state enforcement service designated by the Ministry of Justice.

Salary, taxes, and USC from a business’s seized accounts

Subclause 2 of Clause 10-2 of Section XIII of the Law “On Enforcement Proceedings” establishes a separate regime for legal entities and self-employed persons who employ staff. If the seizure was imposed by a state or private enforcement officer, debit transactions are permitted solely for paying salaries up to five minimum wages per month for each employee, and for paying taxes, fees, and USC.

In 2026, five minimum wages amount to UAH 43,235: UAH 8,647 × 5. For example, for three employees, the total salary payment limit under this rule is UAH 129,705 per month. The limit must still be observed for each employee. It does not set the amount of salary owed to an employee or discharge unpaid salary debt.

Prepare a salary calculation, employee details, and documents for the relevant tax payments for the bank. Agree on how to submit the documents and account for payments already made. The officials of a legal entity or the self-employed person are responsible for ensuring compliance with the legal requirements.

The limit of twice the minimum wage per calendar month for an individual’s spending and the employer salary regime have different conditions. A legal entity does not receive a UAH 17,294 limit for discretionary expenses. Permitted salary and tax transactions also do not mean the seizure has been lifted in full.

How to repay the debt and have the seizure lifted

Before paying, obtain a written calculation and verified payment details from the enforcement officer. Confirm the principal debt, enforcement fee or private enforcement officer’s basic fee, expenses, and applicable fines. Check whether funds already debited or paid voluntarily have been credited.

As a general rule, the state enforcement fee for recovery of property is 10% of the amount subject to compulsory recovery. Article 27 provides for exceptions, including seizure as interim relief and enforcement by a private enforcement officer. If the decision was fully complied with before proceedings were opened and the proceedings are terminated on the relevant legal grounds, no enforcement fee is charged.

A private enforcement officer charges a basic fee under separate rules. Ask for the order showing its calculation. If the fee is set as a percentage, it is paid proportionally to the amount actually recovered in cases of partial recovery, subject to statutory provisions for maintenance payments. An additional fee agreed with the creditor may not be recovered from the debtor.

1. Pay the amount confirmed by the documents or provide evidence that the decision was fully complied with earlier.
2. Give the enforcement officer proof of payment with an application to credit it and take the appropriate decision.
3. Obtain an order terminating the proceedings and lifting the seizure, or a separate order lifting the seizure.
4. Check that it has been sent to every bank that implemented the seizure.
5. Obtain confirmation from the bank that it has acted on the document and check that the required payments can be made.

Under Article 40, an order stating that the seizure is lifted is sent to the relevant institutions on the day it is issued. However, there are exceptions to terminating proceedings, including interim relief and unpaid enforcement fees, expenses, or a private enforcement officer’s basic fee. The return of an enforcement instrument to the creditor should not be treated as an unconditional release of all funds.

If several seizures apply, lifting one does not cancel the others. A payment receipt confirms payment, but the bank needs a document that changes or ends the relevant restriction.

How to challenge an unlawful seizure or an enforcement officer’s inaction

First establish what is infringing your rights: mistaken identification of the debtor, seizure of protected funds, an uncredited payment, an incorrect calculation, or failure to lift a seizure after a legal ground arose. Attach documents supporting your position.

For enforcement of a civil or commercial court decision, a party to the proceedings submits the relevant complaint to the court that heard the case as a court of first instance. Challenges to actions enforcing decisions of other authorities are brought in an administrative court through the proper procedure. Choose the court based on the document being enforced and the subject of the claim.

Do not confuse deadlines under different laws. Article 74 of the Law “On Enforcement Proceedings” sets a period of 10 business days, while Article 449 of the Civil Procedure Code and Article 341 of the Commercial Procedure Code set a ten-day period for applying to court. Shorter deadlines apply to challenges to the postponement of enforcement actions.

During martial law, Clause 10-2 interrupts deadlines set specifically by the Law “On Enforcement Proceedings.” This does not automatically interrupt procedural deadlines under the Civil Procedure Code or Commercial Procedure Code. Apply without delay. If you missed a procedural deadline, submit a motion to renew it along with the complaint and evidence of valid reasons.

For a civil or commercial complaint, state the court, participant details, information about electronic cabinets, the enforcement officer, case number, enforcement instrument details, access identifier for the proceeding, date you discovered the violation, relevant circumstances, provisions breached, and the relief you seek. Attach proof that copies were sent to other participants and documents confirming a representative’s authority, unless those documents have already been filed.

A debtor does not have a general right to complain to the head of a state enforcement service department under Article 74(3). However, the law provides for a head’s oversight of unlawful orders by a state enforcement officer and correction of errors. During martial law, a special mechanism allows an authorised head of a Ministry of Justice unit to cancel an unlawful document issued by a private enforcement officer. It has restrictions, including where the applicant has initiated court proceedings between the same parties on the same subject and grounds.

What to do when interim relief has been ordered

Interim relief may be granted before a dispute is decided. A seizure in this case does not prove that a debt has been finally established. Check whether the restriction is proportionate to the claimant’s demands and prepare documents showing its impact on the store.

In a civil case, submit a reasoned application to the court to cancel interim relief under Article 158 of the Civil Procedure Code; in a commercial case, use Article 145 of the Commercial Procedure Code. As a general rule, the application is considered at a court hearing no later than five days after it is received. A refusal does not prevent a new application if circumstances change. Obtain the ruling cancelling interim relief and check that, after it enters into force, it is sent to the bank and to the enforcement officer, if one implemented the seizure.

Do not assess the closure of a case, dismissal of a claim, or completion of enforcement proceedings separately from the rules governing interim relief. In particular, in a commercial case where the claim is upheld, interim measures may remain in force for 90 days after the decision enters into force; if enforcement proceedings are opened during that period, they may remain in force until the decision is fully enforced. Obtain the relevant ruling and check that every institution affected by the seizure has acted on it.

How to cancel a seizure in criminal proceedings

During the pre-trial investigation, an investigating judge considers an application to cancel a seizure; during court proceedings, the court does so. Under Article 174 of the Criminal Procedure Code, you must show that the seizure is no longer necessary or was imposed without justification. You may seek full or partial cancellation.

Attach documents about ownership of the funds, their source, business transactions, and the specific consequences of the restrictions. Article 173 of the Criminal Procedure Code requires the least burdensome form of seizure that will not halt or excessively restrict lawful business activity. Explain exactly which restrictions are excessive and why.

An application under Article 174 is considered no later than three days after receipt. Spending limits during martial law for seizures by enforcement officers do not automatically grant the right to spend funds seized in criminal proceedings.

In urgent cases, a preliminary seizure may be imposed by the Director of NABU or the Bureau of Economic Security (BES), or a deputy, based on a decision approved by a prosecutor. Part 9 of Article 170 of the Criminal Procedure Code permits this solely to preserve material evidence or secure possible confiscation or special confiscation in proceedings concerning a serious or especially serious crime. Such a seizure may last up to 48 hours. The prosecutor must apply to the investigating judge without delay, no later than 24 hours after the decision. If the prosecutor does not apply within that period or the court refuses the application, the preliminary seizure is considered cancelled, and the funds or property seized must be returned immediately.

Seizure at the tax authority’s request: why a court decision is required

Under Article 94 of the Tax Code, an administrative seizure of property is an exceptional means of securing tax obligations. For a retail business, grounds may include, in particular, refusing a lawful inspection or inventory, violating the rules for disposing of property under a tax lien, lacking mandatory licences, or lacking a registered cash register (RRO) or software cash register (PRRO).

Funds in an account may be seized only by a court decision following an application by the supervisory authority. The bank also releases such funds only by court decision. Obtain the court document and evidence of the grounds for seizure, then choose the appropriate way to challenge or end the restriction.

The rule requiring a court to review the justification within 96 hours applies to an administrative seizure of property ordered by the head of a supervisory authority. It is not a universal deadline for automatically unblocking bank funds.

Grounds for ending an administrative seizure may include repayment of the tax debt, resolving the reasons for the seizure, presenting required licences and documents confirming RRO or PRRO registration, completing an inventory, or cancellation of the decision. For the cases specified in Clause 94.20, the supervisory authority decides to release the property within two business days following the day it learns of the relevant grounds. The requirement for a court decision remains in place for funds in an account.

How to keep the store operating until the seizure is lifted

The owner or manager should appoint someone responsible for documents and communications with the bank, enforcement officer, and lawyer. Ask the accountant to list payments: salaries, taxes, USC, rent, suppliers, and customer refunds. For each payment, establish whether the particular restriction regime allows it.

• Keep separate records of permitted payments and monthly limits used.
• Agree on realistic payment dates with counterparties and keep a record of the arrangements.
• Check that you can meet your obligations to a customer before accepting a new order or prepayment.
• Keep account statements, payment documents, applications, proof of receipt, and all orders and rulings.

Do not route revenue through other people’s accounts to conceal funds or make transactions in breach of an established ban. The law provides for liability for unlawful actions involving seized property and failure to comply with lawful demands by an enforcement officer. A debtor’s cash may also be subject to recovery.

A seizure of bank funds does not by itself change the requirements for an RRO or PRRO, licences, or recording sales. After receiving a document lifting the seizure, check not only that it exists but that the bank has actually acted on it: check the available balance, whether the required payment can be made, and whether any other restrictions remain in force.

Official sources

• Law of Ukraine “On Enforcement Proceedings” of 02.06.2016 No. 1404-VIII: Articles 18, 26–27, 39–40, 48, 56, 59, 70, 73–74; Clause 10-2 of Section XIII.
• Law of Ukraine “On Bodies and Persons Enforcing Court Decisions and Decisions of Other Authorities” of 02.06.2016 No. 1403-VIII: Article 31.
• Civil Procedure Code of Ukraine of 18.03.2004 No. 1618-IV: Articles 149–150, 447–451.
• Commercial Procedure Code of Ukraine of 06.11.1991 No. 1798-XII: Articles 136–137, 145, 339–341.
• Criminal Procedure Code of Ukraine of 13.04.2012 No. 4651-VI: Articles 170–174.
• Tax Code of Ukraine of 02.12.2010 No. 2755-VI: Article 94, in particular Clauses 94.6, 94.10, and 94.19–94.20.
• Order of the Ministry of Justice of Ukraine of 17.07.2023 No. 2578/5: amendments on designating an individual’s current account for debit transactions, including Clauses 1–7 of the added Section XIX of the Instruction on the Organisation of Compulsory Enforcement of Decisions.
• Law of Ukraine “On the State Budget of Ukraine for 2026” of 03.12.2025 No. 4695-IX: Article 8.