Transfer Limits for Sole Proprietors from November 14, 2026: Who Will Be Affected and How to Remove the Bank’s Restriction

In Brief

• From November 14, 2026, banks are lowering the monthly limit on outgoing payments for new and “dormant” sole proprietors: Group 1 — up to UAH 400,000 (previously 600,000), Groups 2–3 — up to UAH 1 million (previously 3 million).
• The limit does not apply to all sole proprietors, only to those the bank has classified as higher-risk: new ones (usually during the first 6–12 months), inactive ones, and those with suspicious transactions.
• This is not a ban. The bank will process a payment above the limit after you provide documentary proof of the source of the funds.
• Taxes and utility payments are not included in the limit. Sole proprietors on the general taxation system do not receive a limit, only more in-depth monitoring.
• The best tactic is to submit documents before a payment to a supplier gets “stuck.”

If you registered as a sole proprietor in 2026 or resumed operations after a pause, November may bring an unpleasant surprise: a payment to a supplier does not go through, and the bank asks you to “confirm the economic substance of the transaction.” The reason is the new sole proprietor limits from November 14, the second phase of the updated Memorandum on Transparency in the Payment Services Market. Below is what exactly is changing, who it affects, and how to restore normal turnover.

What will change on November 14, 2026

The updated version of the Memorandum was signed by the banks on May 14, 2026, within the framework of the Independent Association of Banks of Ukraine (NABU) and the Association of Ukrainian Banks (AUB), and around 30 financial institutions joined it. The document introduces limits in two stages: the first took effect on August 14, and the second begins on November 14.

It is important to understand the nature of this document. The memorandum is not a law, but an agreement among banks on a unified approach to risk. It does not introduce any new legislative bans, but participating banks apply it uniformly, so “moving to the bank next door” with the same transaction volumes usually does not help.

Who will be affected by the new limits

The mere fact of registering as a sole proprietor does not mean an automatic limit. The bank looks at the client’s profile and the nature of the transactions. The risk group includes:

• New sole proprietors. Each bank decides for itself how long a sole proprietor is considered “new” — usually from 6 to 12 months. The closest scrutiny is applied to the first six months of operations.
• “Dormant” sole proprietors. Entrepreneurs who did not conduct business for a long time and then suddenly resumed turnover.
• Sole proprietors with risky indicators in their transactions. According to Mind, these include:
  • a sharp increase in incoming payments from many different individuals and sole proprietors;
  • a zero balance in the account at the beginning and end of the day;
  • frequent incoming transfers from individuals throughout the day;
  • splitting payments to one counterparty, especially into round amounts;
  • a connection to a legal entity: the same registration address, the same accountant or authorized representative, or “financial assistance” from the company.

If your business looks like a transit hub — money comes in and goes out again the same day — the bank will almost certainly impose a limit, even if the sole proprietorship has been registered for a long time.

Who is not affected by the limits

• Sole proprietors on the general taxation system. There are no limits for them under the Memorandum, but transaction monitoring is more thorough.
• Transparent sole proprietors with a track record. If you pay taxes on time, officially employ staff, and can confirm where the money came from, your turnover should not run into the limit.
• Taxes and utility payments. They are not included in the limit.
• Incoming funds. The limit is calculated based on outgoing transactions. This is not an income restriction and should not be confused with the single-tax payer’s maximum income limit.

For ordinary individuals, nothing changes: without confirmed income, they retain limits on outgoing transfers of UAH 50,000 (high risk) and UAH 100,000 per month (low and medium risk).

How the bank calculates the limit

1. The bank totals all outgoing payments from sole proprietor current accounts on a cumulative basis for the month.
2. As long as the total remains within the limit, payments are processed as usual.
3. Once the limit is exhausted, the next payment is automatically declined. The bank will process it only based on your payment instruction and after documentary confirmation of the source of funds.

Each bank calculates the limit based on its own accounts. Keeping accounts with two banks is a normal practice for a business. But do not use this as a way to bypass the restriction: banks are expanding client data sharing, and issues with one bank can complicate service at another.

How to tell that you have hit the limit

• In the app or by email, you receive a request to confirm your income, line of business, or source of funds.
• A payment to a supplier is stuck in the “under review” status or has been declined with a reference to financial monitoring.
• The bank asks you to “explain the economic substance of the transaction.”

Don’t wait until this happens on the day you need to pay a large bill. Write to support chat in advance: “Is a Memorandum limit set on my sole proprietor account? What is my remaining limit for this month, and what documents are required for it to be reviewed?”

How to remove or increase the limit: step by step

1. Find out your status and remaining limit balance. Ask the bank in chat whether they classify you as a high-risk customer and how much of your limit remains until the end of the month.
2. Prepare your document package in advance. What exactly to prepare is shown in the table below. It is important for the bank to understand what you do, where the money comes from, and why you make large payments.
3. Submit a request to review the limit. Do this via chat or through your personal manager. Describe your business in 3–5 sentences: what you sell, to whom, the average ticket size, and your expected monthly turnover.
4. Explain every non-standard payment. Attach the contract and invoice or completion certificate to any large amount. The payment purpose should refer to the contract or invoice number.
5. Check your KVED. If your actual business activity does not match the activity types listed in the register, add the required KVED through Diia or the CNAP. A mismatch between actual activity and the declared profile is one of the main triggers for a review.
6. Keep transactions within the declared profile. The revised limit remains in effect as long as your turnover matches what you showed the bank. A sharp spike will trigger another review.

What documents to prepare

How to work without falling under restrictions

• Pay taxes on time and file your returns. A clean tax history is the main argument when dealing with a bank.
• Write a meaningful payment reference. “Payment under invoice No. 15 dated 03.10.2026 for website development” is better than “services.”
• Do not split payments or zero out the account every evening. For a bank, these are classic signs of transit activity.
• Accept payments from individuals through acquiring or a payment link, not via card transfers. This way, the bank sees merchant transactions rather than a stream of P2P payments from unfamiliar people. A comparison of providers is available in the review of acquiring in Ukraine.
• Do not transfer sole proprietor turnover to the cards of unrelated individuals without supporting documentation.
• Do not give anyone access to a sole proprietor account. Handing over an account to third parties is the main sign of a money mule scheme. Banks close accounts for this, and the Verkhovna Rada is preparing criminal liability for money mules.

If clients pay from abroad

Foreign currency proceeds under a foreign economic contract are one of the most understandable sources of funds for a bank. A contract with a non-resident, an invoice, and an incoming payment via SWIFT or SEPA immediately answer the question “where did the money come from.” We covered which channels work for Ukrainian sole proprietors in 2026 in the guide how sole proprietors can receive payments from abroad. If you accept payments through Wise, our Wise Business review will be useful — it also explains how to avoid getting your account blocked.

Risks and pitfalls

• Bank practices vary. Each bank sets its own criteria for what counts as a “new” sole proprietor, the list of documents, and review timelines. Check with your own bank rather than relying on other people’s reviews.
• Verification takes time. A payment to a supplier may be delayed by several business days. Plan large payments in advance, especially at the end of the month.
• A problem at one bank can affect you at another. Banks are expanding data sharing and income verification through state registries.
• The rules will continue to change. A single limit on all outgoing transactions for individuals is being discussed, and the money mule registry requires a separate bill (No. 14161), which the Rada has not yet considered.
• The Memorandum limit is not the same as the single-tax payer income limit. These are different mechanisms: the first restricts outgoing payments at a specific bank, while the second determines whether you can remain under the simplified tax system.

FAQ

When do the new limits for sole proprietors take effect?

From November 14, 2026. This is the second stage of the updated Memorandum on Transparency in the Payment Services Market: since August 14, transitional limits of UAH 600,000 for Group 1 and UAH 3 million for Groups 2–3 had been in effect; from November 14, they are reduced to UAH 400,000 and UAH 1 million per month.

Is the 400,000 hryvnia limit for income or for expenses?

For expenses. The limit applies to outgoing payments from sole proprietor current accounts per month. It does not restrict incoming funds and is not related to the maximum income threshold under the single tax regime.

How does a bank determine that a sole proprietor is “new”?

Each bank decides this independently, usually during the first 6–12 months after registration. Registration itself does not automatically mean a limit: the bank assesses the business model, turnover, and the nature of the transactions.

Is it possible to make a payment above the limit?

Yes. The limit does not prohibit paying more. The bank will process a payment above the limit based on your payment instruction after you provide documentary proof of the source of funds and the nature of the transaction.

Do the limits apply to sole proprietors on the general taxation system?

No. The Memorandum limits are set for sole proprietors in Groups 1–3 of the single tax system. Sole proprietors on the general taxation system do not receive them, but the bank reviews their transactions more thoroughly.

Are taxes and utility payments included in the limit?

No, payment of taxes and utility bills is not included in the limit.

Will opening an account at another bank help?

Only formally. Each bank calculates the limit based on its own accounts, but most major banks have signed the Memorandum and apply the same rules. In addition, banks are expanding data sharing, so it is more reliable to verify your income than to spread transactions across accounts.