Ukraine's Central Bank Just Sided Against Its Own Crypto Bill. Draft 10225-d Hangs on Three Clauses.

The National Bank of Ukraine is right, and it's right for reasons it doesn't quite want to say out loud. On Nov. 4 the central bank declined to support Draft Law No. 10225-d, a virtual-asset bill that the Verkhovna Rada's Committee on Finance, Tax and Customs Policy had just recommended for a second reading and for adoption as a whole. The public argument is about monetary sovereignty. The subtext is about who actually writes crypto rules in Kyiv.

Both matter. Both will decide whether Ukraine ends up with a MiCA-shaped regime that works, or a licensing regime that becomes a favor bank.

The Three Objections, Ranked

Here's what the filing actually says, stripped of the diplomatic padding.

Objection one is the foreign-token hole. Under the committee text, tokens issued abroad that function like electronic money could circulate in Ukraine without any matching supervision in the country that issued them. The NBU wants the same authority over those assets that it holds over domestically issued ones, meaning the power to assess them and, when necessary, restrict their circulation. That isn't a turf grab. That's a central banker looking at a stablecoin minted in a jurisdiction with no reserve rules and asking who eats the loss when it breaks. The answer, historically, is the payment system of the country that let it in.

Objection two is parity. Simplified admission of foreign virtual assets can't become a side door around the rules that apply to comparable Ukrainian assets. Fair. If a token issued in Kyiv faces reserve and disclosure requirements and a token issued elsewhere doesn't, the market doesn't get more efficient, it just gets more lopsided.

Objection three is licensing, and this is the one that smells.

The NBU originally opposed numerical caps on trading-platform operators. It then agreed, as a compromise, to limit the first wave to three legal persons picked through competitive selection. The final draft, according to the bank, drops a clear five-year cap and hands the number to the National Securities and Stock Market Commission's discretion without adequate antitrust safeguards. Three licensed platforms is a market. Thirty is a different market. If the securities commission can move that number without a statutory anchor, licensing turns into a negotiating table, and Ukraine has enough history with licensing-as-negotiation to know how that ends.

So who's actually writing crypto policy in Kyiv? Right now, nobody's sure. That's the problem.

The Part Nobody's Talking About

Buried under the procedural fight is a tax package that, frankly, is the most competitive thing in the bill. Personal income from virtual-asset trades would face Ukraine's standard personal income tax, with a reduced 5% rate through the end of 2028 for assets acquired before the law takes effect. Crypto-to-crypto swaps wouldn't be taxed. Virtual-asset deals would sit outside VAT entirely.

From a compliance standpoint, that's the headline. A 5% window through 2028 on pre-existing holdings is an amnesty wearing a suit. It tells everyone sitting on 2017-vintage bags that Kyiv would like them back inside the formal system, please, and won't charge much for the privilege. Untaxed crypto-to-crypto means churn doesn't get taxed twice on the way through. No VAT means the tax authority isn't pretending a token swap is a goods sale.

Tax treatment moves adoption. Licensing rules move headlines. Guess which one gets amended first.

The Case for Just Passing It

Now the steelman, because there's a real one.

Ukraine legalized virtual assets in 2022 and then, largely, didn't build the machinery underneath. Four years of drafts. Every month of delay is a month the securities commission has no legal basis to supervise anything, a month volume routes to jurisdictions that do have rules, and a month Ukraine's standing with the IMF and with global AML bodies gets harder to defend. The bill is meant to align with MiCA and with IMF recommendations. The NBU says it supports that direction in principle. It said so in writing.

And there's a war on. Parliament's bandwidth is finite and the queue is long. The NBU received the final text late the evening before the committee vote and called the process not sufficiently transparent. Deputy Governor Oleksii Shaban raised objections in the room, and the bank says the format didn't allow a full debate. Those are legitimate complaints. They're also unfalsifiable, and you can't build a supervisory regime on them.

Then the substantive counter: the NBU already has macroprudential tools. It can cap exposures. It can lean on payment channels. It doesn't obviously need a bespoke veto over individual foreign tokens to protect the hryvnia. Monetary sovereignty is a heavy phrase to hang on a market whose footprint in Ukraine is small next to the money supply.

Except e-money tokens are exactly how a small footprint becomes a large one. Ask anyone who watched dollar stablecoins eat a currency's payment rails from the inside. The NBU has watched that movie in other countries. That's why it's being difficult.

The Verdict

The bill passes. Not in this form, though.

My read: the licensing cap gets restored on the floor, because three operators with a five-year anchor is a compromise the central bank already swallowed once, and reverting to open discretion is precisely the kind of clause that gets fixed when a bill hits a full chamber and every member starts hearing from constituents about who got a license and who didn't. The foreign-token provisions get some form of home-country supervisory test or registration requirement. Neither of those is a radical ask. Both are things a finance ministry can draft in a week.

And the calendar buys room. If adopted, the rules take effect July 1, 2027, with supervision split between the NBU and the securities commission. That's more than eighteen months of runway before a single license is issued. Plenty of time for a second amendment round. Plenty of time, also, to keep expectations low enough that nobody notices how much gets decided before the market opens.

The precedent here's important. Ukraine would be the first country fighting a war to attempt a full MiCA-style build-out while simultaneously negotiating its financial sector with the IMF. If it delegates token licensing to a securities regulator with no statutory number attached, other smaller jurisdictions will copy the structure and quietly skip the antitrust language. That's how a template becomes a loophole.

One more thing worth tracking. Lawmakers introduced a separate bill last year that would let the NBU hold virtual assets, bitcoin included, in its foreign-exchange and gold reserves. Permission, not obligation. The bank wouldn't have to use it. But a central bank that's currently arguing it can't police foreign tokens because the bill is too loose is also a central bank that may soon be allowed to hold the stuff on its own balance sheet. That's not a contradiction, exactly. It's a hedge.

Watch the floor vote in late November, not the committee. And watch whether the licensing number comes back with a statute behind it. If it does, Ukraine gets a workable framework. If it doesn't, the framework works for whoever gets the first three calls.