DeFi Intel

Ukraine Curated

DeFi Intel Research Desk2026-07-14Europe

ISO 3166-1UA
RegionEurope
CapitalKyiv
Population37M
GDP rank (global)~#58 (nominal)
Profile depthCurated

Partially — holding is legal but activity is limited in Ukraine. Current status: Legal to hold — framework not yet in force. Oversight sits with NBU + second regulator to be designated (NSSMC contender) — open question in Bill 10225-d. Full details — governing law, licensing, tax and dated enforcement history — follow below (last reviewed 2026-07-14).

Legal status

Legal to hold — framework not yet in force

Primary regulator

NBU + second regulator to be designated (NSSMC contender) — open question in Bill 10225-d

Stablecoin status

Unregulated — categories defined in pending bill

Framework: Law "On Virtual Assets" No. 2074-IX (adopted 17 February 2022 — never entered force) + Draft Law No. 10225-d (first reading passed 3 September 2025; second reading pending).

Ukraine is the rare jurisdiction that legalised crypto on paper and then never switched the law on. Parliament adopted the Law "On Virtual Assets" (No. 2074-IX) on 17 February 2022 — an earlier version had been vetoed by the president in autumn 2021 — and President Zelensky signed it in mid-March 2022, three weeks into the full-scale Russian invasion. The law defined virtual assets, recognised ownership rights and sketched a licensing regime, but it carried a self-disabling condition: it enters into force only once amendments to the Tax Code establishing how virtual-asset transactions are taxed are adopted. Those amendments were never passed. More than four years later, Law 2074-IX remains adopted-but-inoperative: holding and trading crypto is not prohibited, but there is no licensing regime, no supervised domestic market and no crypto-specific investor protection.

The signing came amid the most consequential state-level crypto fundraising ever recorded. In the first days after the 24 February 2022 invasion tens of millions of dollars in cryptoassets flowed to the Ukrainian government and the NGO Come Back Alive — Elliptic's live tracking put donations to the addresses shared by Ukrainian officials at $54.4 million by 26 February 2022; by 3 March 2022 the total exceeded $54 million across more than 102,000 donations. Elliptic's one-year analysis (published 3 March 2023) counted over $212 million in cryptoassets to Ukrainian causes, of which $83.3 million went to official Ukrainian government wallets — with more than 80% of donations arriving in late February or March 2022. Named contributions included $5.8 million from Polkadot co-founder Gavin Wood and at least $5 million from Vitalik Buterin. The Ministry of Digital Transformation under Mykhailo Fedorov coordinated the effort — including the Aid for Ukraine initiative built with Everstake and Solana — and publicly pressed exchanges to block Russian users. That operational fluency never translated into a domestic framework, even as Chainalysis ranked Ukraine 8th globally in its 2025 adoption index.

The current legalisation vehicle is Draft Law No. 10225-d, registered on 24 April 2025 and modelled on the EU's MiCA regulation with reference to US, Japanese and UK practice. The Verkhovna Rada adopted it at first reading on 3 September 2025 with 246 votes in favour. It takes a technology-neutral approach — virtual assets as a type of digital thing created, stored and transferred using distributed-ledger or similar technology — and sorts tokens into three categories: asset-backed tokens, e-money tokens (pegged to a single official currency) and other virtual assets. Its most contested feature is regulatory architecture: the bill assigns the National Bank of Ukraine (NBU) authority over authorisation rules for services exchanging virtual assets for currency values, plus a second, Cabinet-designated regulator whose identity — the NSSMC being the obvious contender — was still unresolved and, per legal commentary, "should be agreed before the second reading."

The Rada's Finance, Tax and Customs Policy Committee, working with the NSSMC and outside experts, has been finalising 10225-d for second reading, with officials declaring readiness to complete the reform in early 2026. That target has slipped: as of this review (14 July 2026), none of the sources we track records a second-reading vote, and the regulator question remains the visible sticking point. In parallel, the Cabinet's Resolution No. 1238 of 29 October 2024 created a regulatory sandbox for blockchain startups running until October 2026, and the NBU continues piloting an e-hryvnia central-bank digital currency.

Tax treatment

Because Law 2074-IX never took effect, there is no crypto-specific tax regime in force — gains realised by individuals fall under general income-tax rules of 18% personal income tax plus the 5% military levy (23% combined). The tax design attached to Bill 10225-d applies the same securities-style logic: committee chair Danylo Hetmantsev described it as taxing "profits from transactions with crypto assets during the year." The bill's transitional sweetener is the number to watch: virtual assets acquired before the law takes force and sold within the first year would be taxed at a preferential 5% personal income tax plus the 5% military levy — Hetmantsev framed it as a one-time charge of 10% of the amount, without expense deduction — after which the standard 18% + 5% applies. Crypto-to-crypto trades would be untaxed, annual sales up to one statutory minimum monthly wage tax-free, and mining rewards and airdrops not treated as taxable income at receipt.

Travel rule applicability

Status: partial — legislated intent, no operational licensing perimeter. Ukraine's AML framework treats virtual-asset service providers as reporting entities, and the 2026 Global Legal Insights chapter records Travel Rule compliance incorporated into the framework, with KYC required for transactions above roughly EUR 600 and suspicious-transaction reporting above roughly EUR 8,000. In practice, however, no licensing regime is operational until Bill 10225-d passes: there are no authorised Ukrainian VASPs to originate standardised originator/beneficiary data, and most retail flow runs through offshore venues and P2P channels. Foreign compliance teams should treat Ukraine-linked transfers as coming from outside a fully supervised perimeter until the new law and its secondary regulation land.

Notable events and enforcement

Public licensed CASP list

None — and none can exist yet: with Law 2074-IX inoperative and Bill 10225-d awaiting second reading, Ukraine has no authorisation regime and no register of licensed virtual-asset providers. Once the new law passes, authorisation registers are expected from the NBU and the second designated regulator; DeFi Intel will mirror any official register when it is published.

Comparison to neighbours

Ukraine's western neighbours already operate under the EU's MiCA regime that Bill 10225-d is modelled on — so passage would effectively synchronise Ukraine with Poland and Romania rather than differentiate it. Compare Ukraine crypto regulation with three geographically adjacent jurisdictions:

Poland Romania Russia

Doing business in Ukraine — practical notes

Holding and trading crypto is lawful, and Ukraine has a deep talent and user base — 8th in Chainalysis's 2025 global adoption index — but there is no licence a crypto business can currently obtain, so firms serving Ukrainian users typically operate from foreign licences while monitoring 10225-d. Three things are worth tracking before committing capital: the second-reading vote and final text (especially which agency becomes the second regulator alongside the NBU); the companion Tax Code amendments, since the one-year 5%+5% transitional window for pre-law holdings will define the onboarding wave; and secondary regulation on authorisation, which the NBU will write for exchange services. The Cabinet's blockchain sandbox (Resolution No. 1238, to October 2026) offers a limited testing route in the interim. Wartime realities cut both ways — the state has proven crypto-operational capacity since 2022's $212M fundraising effort, but reform bandwidth in parliament remains constrained, which is exactly why the "early 2026" completion target has already slipped.

Methodology and sources

This profile was researched and updated by DeFi Intel's research desk on 2026-07-14 from the primary and secondary sources listed below. Claims that could not be verified against a source are omitted or marked pending — we do not republish unverified third-party datasets. Submit corrections and primary-source links to [email protected].

Sources

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Frequently asked questions

Is crypto legal in Ukraine in 2026?

Partially — holding is legal but activity is limited in Ukraine. The framework is not yet in force.

What is the primary regulator for crypto in Ukraine?

Oversight sits with NBU plus a second regulator to be designated, with NSSMC as a contender — this is an open question in Bill 10225-d.

When was the Law 'On Virtual Assets' No. 2074-IX adopted and why has it not entered force?

It was adopted on 17 February 2022 and signed in mid-March 2022, but it enters force only once Tax Code amendments on virtual-asset taxation are adopted, which were never passed.

Entities mentioned