In February 2026, the Ukrainian legal landscape was shaken by the registration of Draft Law No. 15009. This ambitious proposal introduces the “Free Hryvnia” (Вільна гривня) special fiscal regime—a radical departure from traditional taxation that could redefine how foreign investors manage liquidity and compliance in Ukraine.
What is the “Free Hryvnia” Regime?
Unlike the traditional system that taxes income or profit, the “Free Hryvnia” regime is based on the concept of a monthly automated levy on idle capital. It is a voluntary alternative designed to eliminate the administrative burden of reporting, auditing, and manual tax calculations.
How It Works: The “Special Account” Model
To enter the regime, a legal entity or individual (resident or non-resident) opens a Special Fiscal Account at a participating bank.
- The Levy: On the last day of each month, the bank automatically deducts a fixed percentage from the account balance.
- The Rate: During the 36-month pilot phase, the rate is set by the Cabinet of Ministers between 1% and 3%.
- The Benefit: Once the deduction is made, the taxpayer is deemed to have fulfilled all obligations for Corporate Income Tax (CIT), Personal Income Tax (PIT), VAT, and Military Tax for all transactions conducted through that account.
3 Pillars of the New Regime
1. Zero Reporting & No STS Audits
The most significant “hook” for foreign investors is the promise of total administrative freedom. Because the tax is deducted automatically by the bank based on transparent balance data, there is no need to file monthly VAT declarations or annual profit reports for in-regime operations. Furthermore, participants are exempt from routine audits by the State Tax Service (STS).
2. The “Exit Fee” Mechanism
To prevent the regime from being used simply to “park” money and then withdraw it tax-free, the law introduces an Exit Fee.
- This fee is triggered when funds are withdrawn as cash or transferred to a regular bank account outside the “Free Hryvnia” system.
- This ensures that the capital either remains within the digital, taxable loop of the regime or pays a “toll” to enter the traditional economy.
3. The 2026–2029 Kyiv Pilot
As of now, the regime is not nationwide. To test its impact on budget predictability, the pilot project is restricted to taxpayers whose legal address is in Kyiv. If successful after three years, it is expected to roll out across all regions of Ukraine.
Comparison: Traditional Tax vs. Free Hryvnia
| Feature | General Tax System | Free Hryvnia (Draft 15009) |
| Tax Base | Profit, Revenue, or Added Value | End-of-month Bank Balance |
| Reporting | Monthly/Quarterly Filings | None (Automated) |
| Audit Risk | Regular STS Inspections | Exempt for in-regime operations |
| VAT Compliance | Complex Invoice Registration | Included in the monthly levy |
| Flexibility | High administrative friction | High liquidity/High speed |
Strategic Considerations for Foreign Investors
While the simplicity is enticing, the “Free Hryvnia” regime requires a shift in financial strategy:
- Inventory vs. Cash: Since the tax is on balances, companies with high cash reserves at the end of the month will pay more than those who reinvest quickly into assets or inventory.
- Hybrid Operations: Foreign firms must carefully track which transactions are “In-Regime” and which are “General,” as mixed operations will still require partial reporting.
- Security: A self-regulatory organization (SRO) will be established by the participants themselves to represent their interests and propose improvements to the government, giving investors a direct voice in the system’s evolution.
The “Free Hryvnia” is a bold experiment in digital-first governance. For foreign tech companies, service providers, or investment funds with high transaction volumes, this could drastically lower the “cost of doing business” in Ukraine. However, until the Cabinet of Ministers finalizes the exact rates (1% vs 3%), a comparative tax simulation is essential.
