NBU extends settlement deadlines for exports

The National Bank of Ukraine (NBU) continues to adapt foreign‑exchange restrictions to the realities of the wartime economy and the needs of specific export sectors. Its latest decision concerns an extension of statutory settlement deadlines: for some exporters, the period for receiving export proceeds increases from 180 to 270 days.

Based on government proposals, NBU Board Resolution No. 18 of 26 February 2026 sets a 270‑day settlement period for export operations involving agricultural and specialised machinery (UKTZED codes 8424, 8428, 8432, 8716) under contracts concluded from 1 March 2026. The standard 180‑day limit remains in place for most operations, so the change effectively creates an “extended window” specifically for machinery exporters.

Reasons for the change
The initiative to lengthen settlement periods came from the Ministry of Economy, reflecting requests from businesses and industry associations: exports of complex machinery involve long production, delivery and installation cycles, so 180 days is often insufficient. War‑related logistical challenges — damaged infrastructure, blocked routes, dependence on ports and railways — further prolong the gap between shipment and payment, especially on new markets with deferred payment or sophisticated financing schemes.

Expected impact on the sector
According to the regulator, the longer deadlines are intended to:

• support growth in exports of agricultural and specialised machinery;
• stimulate higher production and investment in machinery‑building companies;
• help preserve human capital and create new jobs;
• expand access to new export markets and increase foreign‑currency inflows.

In practice, the NBU is using FX rules as a tool of industrial policy: by easing repatriation deadlines for capital‑intensive sectors, the state gives them more room to manoeuvre in negotiations with foreign buyers.

Implications for exporters
For companies exporting machinery under the specified UKTZED codes, the key practical effect is the ability to include longer payment terms in contracts without automatically breaching FX regulations. This enables them to:

• offer buyers more flexible payment terms (deferrals, instalments);
• work more comfortably with foreign banks and export‑finance schemes;
• reduce the risk of transactions being blocked solely due to exceeding the 180‑day limit.

The extension does not cancel basic requirements: if proceeds are received late, supervisory authorities may still impose fines, and companies must document the reality of transactions and take steps to recover overdue receivables. At the same time, the new rules apply only to operations from 1 March 2026; earlier contracts are assessed under the previous regime, so exporters must carefully track the actual export date to avoid misapplying the deadlines.

Risks and limitations
From an FX‑control perspective, longer settlement periods increase the risk of non‑payment: the more time between shipment and receipt of funds, the higher the probability of commercial, political or force‑majeure problems on the buyer’s side. For that reason, the NBU maintains a stricter regime for these operations than for some goods where the limit reaches 365 days or is removed altogether. For businesses, the main task is not to treat 270 days as an “indulgence”, but to build a robust receivables‑management system: clearly worded payment schedules, security mechanisms (advance payments, guarantees, letters of credit) and documented claims work to demonstrate due diligence during inspections.

What accountants and compliance officers should do
Accountants and CFOs need to update internal policies and contracts so that commercial terms match the new statutory deadlines. In particular, they should:

• verify whether a specific product falls within the list of UKTZED codes eligible for the 270‑day period;
• adjust standard foreign‑trade contract templates (payment terms, delivery conditions, penalties for delay);
• revise internal procedures for monitoring FX proceeds and controlling settlement dates;
• coordinate the changes with servicing banks to prevent payment blocks caused by differing interpretations of the rules.

Compliance officers should assess how the new deadlines fit into the company’s overall risk‑management framework, including concentration of receivables on individual counterparties or markets.

Prospects for further liberalisation
The NBU’s move on technical exports fits into a broader policy of targeted easing of FX restrictions for sectors that are critical for economic recovery: the regulator has already extended settlement periods for some agricultural exports from 90 to 120 days. Future changes are likely to remain selective and will depend on the balance between supporting exports and safeguarding FX inflows, so businesses should not only monitor new resolutions but also engage through industry associations, whose advocacy helped shape the current decision.

If you have questions or issues related to applying the new settlement deadlines in foreign‑trade contracts, structuring export deals or mitigating FX risks, you are welcome to seek individual advice — we will help adapt your operations to the updated NBU requirements.

Author: Ihor Yasko, Managing Partner at JSC “WINNER Law Firm”, PhD in Law.