NBU publicly refuses to back Ukraine crypto bill 10225-d in current form, flags foreign‑token and licensing risks

Opening: what happened

On or immediately before 2026-11-05 the National Bank of Ukraine (NBU) published a formal position saying it cannot support Draft Law No. 10225-d in its current version (bank.gov.ua).

The NBU set out three core objections: the draft would allow uncontrolled admission of foreign tokens that function like electronic money; it contains regulatory gaps and unequal requirements that could enable regulatory arbitrage; and it leaves discretion in the licensing/authorization process that the NBU says could lead to monopolisation and corruption.

Industry outlet Cryptopolitan reproduced the NBU statement and reported that the draft had already cleared the Verkhovna Rada Committee on Finance, Tax and Customs Policy for a second reading (cryptopolitan.com, published 2026-11-05T17:30:41Z).

Confirmed developments — on‑record NBU objections

The NBU’s published statement is the primary source for these confirmed developments (bank.gov.ua).

Key confirmed points from the NBU publication:

• The NBU cannot support Draft Law No. 10225-d in its current form and says previously agreed compromises were omitted from the final recommended text it received late the prior evening.
• The bank warned the draft would admit foreign tokens that operate like electronic money without ensuring supervisory alignment with the tokens’ jurisdictions and requested authority to assess and, if necessary, restrict such foreign tokens’ circulation in Ukraine.
• The NBU said simplified admission rules could permit regulatory arbitrage, letting foreign virtual assets avoid requirements applied to Ukrainian assets and creating market segments outside adequate oversight.
• The NBU objected that the draft leaves the National Securities and Stock Market Commission (NSSMC) discretion over how many trading‑platform operators may be authorised in the first five years, removing an earlier compromise to limit initial operators to three chosen via competition; the NBU said open discretion could invite monopolisation and corruption.

Context — NBU stance and international alignment

The NBU framed its position as supportive of building regulated crypto markets aligned with the EU’s Markets in Crypto‑Assets (MiCA) framework and International Monetary Fund recommendations, but it said any law must protect monetary sovereignty, price and financial stability (bank.gov.ua).

The NBU also said it participated in the working group that prepared the draft, but received the final recommended text only shortly before publication and found that key compromises had been excluded, constraining the opportunity for full professional debate (bank.gov.ua).

Reporting and timing

Cryptopolitan reproduced the NBU statement and summarised the bank’s objections, noting the publication date and that the draft had been cleared by the parliamentary finance committee for second reading (cryptopolitan.com).

Observable action date: the NBU published its position and made the statement public on or immediately before 2026-11-05 (Cryptopolitan timestamp 2026-11-05T17:30:41Z).

Why this matters

If the NBU’s concerns are unresolved, the central bank’s public refusal to back the draft may increase political and legislative pressure to amend the text before a parliamentary second reading.

The specific issues flagged—cross‑border admission of tokens, parity of regulatory requirements, and the method and discretion for authorising trading platforms—affect who can operate in Ukraine and how foreign virtual assets would be treated relative to domestic issuers.

The NBU’s demand for the authority to assess and, if necessary, restrict foreign tokens speaks to monetary‑stability and consumer‑protection priorities that central banks typically prioritise in payments and e‑money regulation.

Analysis (clearly labelled)

Confirmed facts indicate the NBU is not opposed to regulated crypto per se, but insists the law must include safeguards that preserve monetary sovereignty and consistent oversight. That line mirrors prior central‑bank concerns in other jurisdictions when e‑money‑like tokens cross borders without matching supervisory arrangements.

The NBU’s complaint about omitted compromises and late delivery of the final recommended text suggests either procedural friction in the working group or late edits by sponsors or committee staff — but the supplied evidence does not identify who made the changes or why.

The concern about open discretion for platform authorisations is procedural but consequential: leaving the NSSMC free to choose numbers and methods without a clear competitive process, the NBU argues, increases corruption and monopolisation risk. The evidence does not show any instances of corruption or monopolisation, only the NBU’s stated risk assessment.

Questions to watch and current status

Will the Verkhovna Rada amend the bill in response to the NBU’s public objections, and if so, what specific textual changes will be proposed? (Unconfirmed: parliamentary actions not supplied.)

Will NSSMC, the bill’s sponsors or the parliamentary committee formally reply to the NBU’s position? (Unconfirmed: no responses provided in the supplied evidence.)

What concrete measures would the NBU request to control foreign tokens’ admission — for example, criteria for supervisory alignment or a formal assessment power? (Unconfirmed: amendment language not supplied.)

Current status: the NBU’s public position is confirmed; subsequent legislative replies, sponsor statements and any amendment texts were not supplied and remain outstanding.

Sources

National Bank of Ukraine public statement: bank.gov.ua — ‘Position of the National Bank of Ukraine regarding draft Law No. 10225-d on circulation of virtual assets’ (on record).

Cryptopolitan summary and reproduction of the NBU statement: cryptopolitan.com (published 2026-11-05T17:30:41Z).