State Policy on Banking Regulation Amid the Development of FinTech Technologies and Growing Digital Risks to National Security (OpenAlex (recherche mondiale))

Summary

• Total Ukrainian banking sector net assets grew by 70.1% from UAH 2,352 billion in 2022 to UAH 4,001 billion in 2025.p.8
• Privately owned banks recorded net asset growth of 95.5%, rising from UAH 470 billion in 2022 to UAH 919 billion in 2025.p.8
• State-owned banks excluding PrivatBank increased their net assets by 84.6%, expanding from UAH 638 billion in 2022 to UAH 1,178 billion in 2025.p.8

Key insights

1. State policy on banking regulation in Ukraine operates across financial regulation, risk-based supervision, technological regulation, and digital resilience.p.6
2. The National Bank of Ukraine designated 15 banks as systemically important as of 1 January 2025.p.9
3. Digital risks in banking comprise five primary categories: cyber risks, data protection risks, technology risks, third-party risks, and business continuity risks.p.12
4. The asset share of banks belonging to foreign banking groups in Ukraine declined from 29.5% in 2022 to 25.0% in 2025.p.9
5. Resolution No. 178 of the Board of the National Bank of Ukraine dated 12 August 2022 established the organisational framework for cybersecurity in banks and interaction with CSIRT-NBU.p.11
6. Effective FinTech regulation requires transitioning traditional supervision toward integrated digital supervision using RegTech and SupTech tools.p.15