New format: Protection of banking secrecy in a new way. What the NBU initiative changes and why risks for clients are absent
Recent initiatives by the National Bank of Ukraine regarding the procedure for storing, protecting, and disclosing banking secrecy are drawing significant interest among financiers, lawyers, and bank clients. At first glance, the changes appear technical, but in reality this is an important step toward digitalizing the financial sector, strengthening security, and improving convenience for users.The National Bank has proposed allowing requests and permissions concerning the disclosure of banking secrecy to be signed with an advanced electronic signature with a qualified certificate. This decision supports the implementation of the “paperless” concept replacing paper carriers with electronic document flow. “Editorial changes that supposedly improve the security of the process. In fact a simple clarification with other regulatory acts,” comments Oleksandr Karpov, Director of the Ukrainian Interbank Association of Payment Systems Members.
The essence of the changes is that written requests and permissions to disclose banking secrecy may be signed using either a qualified electronic signature (QES) or an advanced electronic signature (AES) with a qualified certificate. This aligns with modern practice in public electronic services, tax and customs legislation, and electronic identification standards. The approach, under which citizens and businesses can sign official documents electronically, has long been active in related areas from social services to financial services.
Importantly, neither the list of persons entitled to access banking secrecy nor the scope of information that may be disclosed according to the law changes. Access to banking secrecy remains limited to legally authorized entities state authorities, courts, law enforcement, the Ministry of Justice, and others who obtain permission following established procedures. Additionally, the draft NBU regulation allows private enforcement officers to submit requests for such information using QES. The technical nature of the changes is underscored by the NBU press service: “Including the AES with a qualified certificate in the list of electronic signatures that may be used to sign requests (permissions) that constitute the secrecy of a payment service provider, in electronic form by owners of such information, corresponds to the nationwide approach.” Thus, this is not about expanding access to confidential information, but rather simplifying the procedure for signing and submitting requests, ensuring unity with other state online services.
It is also important to consider the broader context. This summer, several laws and government decrees expanded the powers of state authorities regarding access to banking secrecy to protect Ukraine’s interests in international courts and in matters of factoring. In particular, the Ministry of Justice obtained the right to directly request such information for international legal representation. The new mechanism allows for quicker responses and ensures full legal protection of Ukraine’s interests internationally.
For clients of banks and non-bank financial institutions, the question of risks remains crucial. The National Bank responds unequivocally: “Such risks are absent.” All changes are technical, do not affect the volume or list of confidential information, do not violate personal data protection guarantees, and instead enable secure and convenient electronic document flow fully compliant with legislation.
The NBU’s initiative to improve electronic signature procedures and electronic submission of requests for banking secrecy disclosure is a logical next step in the digitalization of Ukraine’s financial sector a process long active in other areas of public administration. It significantly simplifies bureaucratic procedures for clients, lawyers, private enforcement officers, and state authorities. At the same time, the changes bring no real risks to bank clients, since neither access rights nor the scope of information changes.
Financial institutions must continue to ensure the highest level of protection for banking secrecy, and the modernization of signature instruments is simply a modern tool that enhances convenience and security. In today’s financial ecosystem, initiatives like this build the foundation for progress, trust, and efficiency in working with confidential information in the interests of both clients and the state.
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