Card-to-card transfers: rules for business

Card-to-card transfers in 2026: what rules apply to businesses, sole proprietors, and regular clients

As of March 10, 2026, there is no longer a mandatory NBU regulatory limit of UAH 150,000 per month for "card-to-card" transfers by individuals in Ukraine. This limit was temporary: it was introduced on October 1, 2024, for six months, and starting April 1, 2025, the National Bank did not extend it. However, after this regulatory restriction ended, internal rules of banks that joined the Memorandum on ensuring the transparency of the payment services market remained in place. That is why some clients no longer have restrictions, while for others, the bank may continue to apply limits or request documents. (National Bank of Ukraine)

For clients of banks participating in the Memorandum, the key factor is no longer the fact of the transfer itself, but the client's risk profile and the presence of documented income. According to the Memorandum terms published by the NBU, if there is no confirmed income, banks committed to setting limits on operations, including those via IBAN: for high-risk clients — up to UAH 50,000 per month starting February 1, 2025; for medium and low-risk clients — up to UAH 150,000 per month starting February 1, 2025, and up to UAH 100,000 per month starting June 1, 2025. This is not a new law or a separate NBU resolution for all banks, but a market agreement between banks and payment service providers that joined it. (National Bank of Ukraine)

Separately, these bank limits must be distinguished from open banking. Open banking in Ukraine was launched on August 1, 2025, based on the NBU Board Resolution No. 80 and the provisions of the Law of Ukraine "On Payment Services". Its essence is not that every transfer now automatically undergoes "full identification," but that licensed payment service providers can — with the user's active consent — access account information and/or initiate credit transfers. Some technical requirements of this regulation come into force later — starting August 1, 2026. (National Bank of Ukraine)

For businesses, this primarily means the emergence of new payment services, rather than a general tightening of control "over every transaction". The user themselves provides active consent to access the account, such consent is confirmed by strong authentication tools, and can also be revoked through remote service channels. Thus, open banking is a legal mechanism for fintech services and payment providers to operate within NBU rules, not a permission for anyone to view a client's banking information. (Law of Ukraine)

That is why accepting payment from buyers to a personal card is one of the riskiest working models. It creates several problems at once: bank compliance may regard such receipts as atypical or risky behavior; the tax office during an inspection will see a mixing of personal and business funds; and if there are systematic sales, a question arises regarding the proper application of ECR/SECR and income accounting. For a Ukrainian entrepreneur, a safe model is a separate business account, a contract with a bank or a payment provider, a proper description of the purpose of payments, and a full set of primary documents for each type of receipt. (Law of Ukraine)

Regarding financial monitoring, the main mistake is thinking that there is a "safe monthly threshold" of UAH 30,000 for all card transfers. There is no such rule for regular card transfers between already opened accounts. Law No. 361-IX establishes threshold financial transactions at UAH 400,000 or more if there are legally defined signs. Separately, due diligence rules apply to one-time transfers without opening an account starting from UAH 30,000 — this is a different situation than a regular transfer between already identified accounts. The NBU directly clarified that a card-to-card transfer of UAH 10,000 does not require separate identification of the payer, because the bank has already identified the cardholders when opening accounts. (Law of Ukraine)

This does not mean that the bank will not check smaller amounts. The risk-oriented approach allows the bank to stop or additionally verify operations even below threshold values if the client's behavior does not match the declared profile. In practice, this happens when hundreds of thousands of hryvnias pass through an account in a short time, when there is a large number of credits from different individuals, when money is quickly withdrawn in cash, or when actual turnovers significantly exceed the volume that the client declared to the bank when opening the account. In such cases, the bank usually requests explanations and documents regarding the source of funds and the economic essence of the operations. (National Bank of Ukraine)

For an entrepreneur, the set of documents to keep ready depends on the nature of the business, but basically, these should be contracts, invoices, acts, waybills, delivery documents, fiscal checks, tax reports, bank statements, as well as documents confirming the origin of funds if it is not about sales, but about loans, aid, refunds, or other atypical receipts. If the bank sees that operations correspond to the activity profile and are documented, the risk of blocking and refusal to conduct payments is significantly lower. (npu.gov.ua)

A separate block is ECR/SECR. Law No. 265/95-VR applies to business entities conducting settlement operations in both cash and non-cash forms using electronic payment means. A settlement document according to the law can be paper or electronic. If a buyer pays for a product or service with a card, via acquiring, a payment button, QR, internet payment, or another payment instrument, the entrepreneur must issue a settlement document of the established form and content for the full transaction amount, including for orders or payments via the Internet. (Law of Ukraine)

On general grounds, the obligation to use ECR/SECR since January 1, 2022, does not apply only to sole proprietors — payers of the single tax of the first group. For other entrepreneurs who accept payment from buyers within settlement operations, ECR/SECR remains the basic tool of fiscalization. The current version of Law No. 265/95-VR is valid from December 30, 2024; the form and content of settlement documents are determined by the Order of the Ministry of Finance No. 13, which also directly covers cases where an order or payment is made using the Internet. (km.tax.gov.ua)

From a tax point of view, it is important to remember the main thing: it is not the very fact of funds arriving on the card that is taxed, but the legal nature of such receipt. For an entrepreneur, this may be income from business activities; for an individual — salary, a gift, charitable aid, inheritance, or other income. The Tax Code separately regulates non-taxable non-targeted charitable aid, as well as the taxation of gifts and inheritances. In addition, income in the form of the value of inherited or gifted property subject to taxation under the rules of Section IV of the Tax Code is subject to a military tax at a rate of 5%. In 2026, the minimum wage starting January 1 is UAH 8,647, which is important for certain tax limits and benefits tied exactly to this indicator. (Law of Ukraine)

The practice of 2025–2026 shows that pressure on "drop schemes" has already changed market behavior. According to data published on the official portal of the National Police, while 2,194 "drops" were identified in 2020, in the first nine months of 2025, it was already 26,700. It is also noted there that after restrictions on classic P2P transfers, the organizers of shadow schemes began to focus more on sole proprietors. For legal business, this means one thing: any attempts to "simplify" accepting payments via someone else's or personal cards in 2026 have become much more dangerous than a few years ago. (npu.gov.ua)

For a Ukrainian entrepreneur, the working model in 2026 looks like this: accept payments to the account of a sole proprietor or company, not to a personal card; use acquiring, payment services, and ECR/SECR according to the law; generate a fiscal check immediately; keep contracts and primary documents in order; do not mix business and personal funds; do not rely on the old myth of the "NBU limit of 150 thousand," because it no longer exists; and do not confuse open banking with financial monitoring, as these are different legal regimes. (National Bank of Ukraine)

Official Sources