Open Banking in Ukraine: How New Rules Will Change Banks, Business, and Consumers
Starting August 1, 2025, a new Regulation on Open Banking will come into force in Ukraine, effectively launching a financial market reform based on European standards. While the idea of Open Banking has been discussed in expert circles for several years, it is now that Ukraine is formally shifting to a model where the exchange of financial data between banks, clients, and third-party services becomes a reality.
Open Banking is a system in which banks and other account servicing payment service providers (ASPSPs) are required to grant access to clients’ financial data via open APIs based on their consent. The client has the right to decide exactly which data and to whom it can be provided. This enables the integration of financial information from different institutions into a single application, simplifies payments, automates accounting for entrepreneurs, and provides a new level of control over accounts.
The First Stage Regulatory Framework and Market Preparation
The introduction of open banking became possible thanks to the adoption of the Law “On Payment Services” and the corresponding Regulation No. 80, which details the requirements for financial institutions. According to this document, all payment service providers have five months from the effective date to bring their activities in line with the new requirements. This is the first stage of implementation: banks and financial companies must introduce technological solutions for open access to accounts via APIs.
Oleksandr Karpov, Director of the EMA Association, notes:
“Open Banking aims to simplify the financial lives of both ordinary users and entrepreneurs. Thanks to integrated applications, users will be able to control all accounts, analyze expenses, and receive financial advice in one place instead of using multiple banking services.”
He emphasizes that for entrepreneurs, the main advantage is automation. “There will no longer be a need to manually export statements from different banks and upload them into accounting programs or reporting services. Everything will happen automatically via API. This will greatly simplify business operations, save time, and minimize human error,” Karpov explains.
Transition Period and Expected Impact
The first results of the reform will not be felt by users and businesses immediately. According to Karpov, the technical deadline for banks is preliminarily set for January 1, 2026 by this date, APIs must be operational. However, until August 1, 2026, there is an “adaptation period” during which banks will not be sanctioned for late integration.
“Banks are currently mainly facing expenses. Everyone is busy with infrastructure developing their own solutions or choosing a vendor. These are capital investments with no immediate return,” the expert emphasizes.
Karpov believes that those banks which are first to obtain the relevant licenses and ensure API functionality will be able to aggregate clients of other institutions in their apps. This creates risks for competitors: the main financial activity may shift to the “super app” of a more progressive bank, while smaller institutions risk losing direct contact with their own clients.
For the banking system, the true advantage of open banking will appear only for those who choose a proactive strategy. “This is an opportunity to become a financial hub. When a client manages all their accounts through your app, you gain an invaluable tool for cross-selling your own credit, insurance, and investment products. But this is already a first-league players’ strategy,” Karpov explains.
Practical Changes for Business and Entrepreneurs
For entrepreneurs, open banking is not just “new technologies” but a tangible automation of accounting, simplified lending, onboarding, and the emergence of PIS payments. The first such services are expected to appear as early as 2026. They will allow businesses not to store clients’ payment data, with all transactions being conducted directly through secure banking channels.
“The era of manually exporting CSV files and uploading them to 1C or other services is coming to an end. Everything will synchronize automatically. The financial history of a potential client or counterparty will be checked instantly through AIS consent, rather than in a week by submitting certificates,” Karpov summarizes.
For ordinary users, this will mean collecting information about all accounts in a single app, simplified payments, and a new level of financial literacy.
Security and Liability: Who Can Be Trusted
Open banking enhances not only convenience but also user control over their own data. According to senior lawyer at Asters, Inna Bondarenko, “within the framework of Open Banking, users gain control over what data about their accounts is transferred to third-party service providers. Access is granted only to a certain scope of information determined by the user regarding their account, at their request and with their consent.”
Banks are liable for damages in case of violation of security requirements and unlawful disclosure of information. “The regulation provides that banks are liable to the user, including for damages caused in case of non-compliance with the requirements of the regulation and disclosure of information without permission,” the lawyer emphasizes.
Inna Bondarenko points out:
“Banks are obliged to ensure the secure exchange of information and its protection via APIs, to monitor payment operations and requests for account data, and to take measures to prevent fraud or unauthorized access.”
Third-party service providers must be authorized by the NBU and comply with all technical and security requirements, including liability insurance and open banking certificates. Moreover, user data remains under the control of the user and the service provider to whom the user has granted access.
Risks: From Phishing to Unconscious Consent
The main challenge is protection from phishing and fraudulent attacks. Among the key threats, Inna Bondarenko mentions fake apps and malware that mimic the work of banks or financial services, prompting users to disclose their data.
At the same time, the very process of obtaining consent for data processing is detailed and protected by additional authentication layers. “A number of safeguards are provided for users against unconscious consent, such as detailed information about the consent before granting access to account data, enhanced user authentication, the ability to revoke consent at any time, and the possibility for users to monitor their active and inactive consents,” the lawyer summarizes.
How Tariffs and Competition Will Change
Open banking will inevitably affect market competition, but the impact on tariffs will be felt differently by different groups. The head of the project office of the Independent Association of Banks of Ukraine, Dmytro Hlynskyi, believes:
“Competition will primarily intensify in the area of service convenience, while the impact on the cost of services will not be linear.”
On the one hand, new players fintech companies capable of offering cheaper and more innovative services – may enter the market. On the other, European experience shows that when the regulator lowers some tariffs, banks compensate for this with other fees, such as account maintenance or card servicing.
“For large businesses, it is possible to lower acquiring fees thanks to PIS payments. For small and medium-sized businesses the potential reduction in the cost of certain financial services thanks to automation via APIs. For ordinary clients the risk of losing some free basic services, which banks will start charging for to compensate for losses in other segments,” Karpov explains.
New Business Models: Hub Banks, Fintechs, and the Role of Small Banks
After the launch of open banking, three main models will appear on the market:
- Hub banks, which will become “financial supermarkets” and gather all client accounts in a single application;
- Fintech companies specializing in niche products (accounting automation, investing, analytics), operating on a subscription or commission basis;
- Supplier banks, which will focus on servicing basic accounts, conceding the main client activity to competitor apps.
Who will win in this transformation will depend on the quality of service and the ability to create the most convenient ecosystem for the client.
Open banking is not just about implementing a new technology, but a comprehensive transformation of Ukraine’s financial system. In the short term, banks and businesses face a technological challenge and additional costs, while consumers gain new opportunities to manage their finances. However, the real effect and change in the market model will come closer to 2027, when the open banking system will cover not only banks but also non-banking financial institutions.
From an economic perspective, this step has the potential to lower barriers to innovation, activate competition, and create new business models. At the same time, open banking will become a test of the Ukrainian market’s ability to ensure a level of trust, security, and efficiency comparable to European standards. Without this trust and flexibility, the reform will remain a declaration, not a new quality of financial life for millions of Ukrainians.














