Transfer of funds without opening an account: mandatory payment instruction details have been standardized

The National Bank of Ukraine has specified the mandatory details for a payment instruction generated when providing a payment service for the transfer of funds without opening an account, where the payer has transferred the funds from their own account.

Previously, participants in the payment market were guided by general legal provisions in this matter. Currently, due to the need for such standardization, the National Bank has provided the necessary regulation in Resolution No. 20 of the Board of the National Bank of Ukraine dated February 26, 2026, “On Approval of Amendments to the Instruction on Non-Cash Settlements in the National Currency for Payment Service Users.”

In particular, the National Bank:

• required providers of funds transfer services without opening an account to ensure that the payer can fill in the details of the actual payer, including in cases where payments to the budget are made by one person on behalf of another. This will facilitate the accurate recording by the State Tax Service of Ukraine of payments to the budget under the payer to whom the liability is attributed;
•   granted the provider of money transfer services without opening an account the right to fill in the payment instructions:
  • the payer’s details, using the information available to the provider from the payer and its own technical means. This will allow a payer who is a regular user of a money transfer service provider without opening an account to avoid filling in their details each time and instead use those already available to the provider;
  • details such as the payment purpose, the recipient’s name, their EDRPOU code, and account number when the payer is paying for housing and utility services or making payments to the budget (taxes and fees);
• required the provider of money transfer services without opening an account to execute each payment instruction as a separate payment transaction;
• required the provider of funds transfer services without opening an account to familiarize the consumer with the completed details of the payment instruction and to provide the payer with confirmation information after accepting the payment instruction for execution (to confirm the initiation of the payment transaction);
• provided that the consumer may omit mandatory details such as last name, first name, patronymic (if applicable), and identification code when paying for housing and utility services.

All of this will contribute to improving the efficiency of the payment market and the transparency of non-cash transactions.

The resolution takes effect on March 3, 2026. At the same time, providers of funds transfer services without opening an account will have six months to bring their operations into compliance with the National Bank’s new requirements.