NBU updates payment infrastructure oversight procedure, requirements for its participants

The National Bank of Ukraine (NBU), by Resolution No. 37 of April 9, updated the procedure for implementing the oversight of payment infrastructure. Specifically, it excluded the provisions on the oversight of payment service providers that are not subjects of payment systems, and expanded the requirements for business continuity and third-party risk management.

According to the regulator's announcement, the amendments also expand the list of organizational and technical measures to ensure the continuity of operations of all oversite facilities, update the procedure for determining the importance of payment systems and payment service technology operators, improve approaches to assessing payment infrastructure, and update terminology in accordance with legislation in the field of information security and electronic communications.

The resolution also stipulates that oversight entities must bring their activities and documents into compliance with the new requirements within three months of its entry into force.

The document itself stipulates that the oversite entity's obligations and responsibilities for complying with the requirements of the regulation do not change if it engages a technology operator or third parties.

In addition, critical process operators are required to have a backup work area, provide alternative communication channels, and the individuals or departments responsible for these areas must report to the manager or governing body at least once every six months.

The National Bank also clarified that the decision to designate a technology operator as important, and a payment system as important or systemically important, will be made by the Committee for the Supervision and Regulation of Banking Activities, Oversight of Payment Infrastructure, and that the regulator will determine the importance of payment systems and technology operators in February of this year based on their performance in the previous year.

Resolution No. 37 was published on April 13 and comes into effect on April 14, 2026.

As reported, the NBU did not change the list of important payment service technology operators by the end of 2025, which includes ACDC Processing LLC, Ukrainian Processing Center PJSC, and TAS Link LLC.