WHAT IS FINANCIAL INCLUSION?

Financial inclusion means ensuring that individuals and businesses have access to basic financial services on a non-discriminatory basis. This refers not only to the ability to open a bank account, but also to accessing payment, deposit, credit, and insurance services, as well as digital payment tools and advice on financial management.

The concept of financial inclusion takes on particular significance in today’s context: a full-scale war, internal displacement, the growing role of digital services, and the uneven development of banking infrastructure across different regions of Ukraine create objective barriers to financial access for millions of citizens.

According to the definition used by international organizations such as the World Bank, financial inclusion encompasses measures aimed at reducing barriers to accessing financial services for vulnerable groups and small businesses, particularly in rural, de-occupied, and frontline areas.

REGULATORY REGULATION IN UKRAINE

Financial inclusion in Ukraine is becoming subject to legislative regulation. In May 2025, the Verkhovna Rada of Ukraine adopted, in the second reading and as a whole, Bill No. 13018-d “On the Development of Financial Inclusion”. This document establishes the key principles governing the operation of so-called financial inclusion banks—new players in the financial services market with a narrow focus and simplified requirements.

According to the draft, a financial inclusion bank is a financial institution that operates under a limited banking license issued by the National Bank of Ukraine. The purpose of this license is to provide basic banking and payment services to specific categories of customers.

The right to operate as a financial inclusion bank will be granted to both newly established legal entities and existing banks that convert their full banking licenses to limited ones.

Regulatory provisions, capital adequacy standards, risk limits, and transparency requirements for such institutions will be determined by the National Bank of Ukraine in a separate regulation. It is expected that the requirements will be simplified to stimulate the development of local and specialized financial services.

WHO CAN BECOME A CLIENT OF THE FINANCIAL INCLUSION BANK?

In accordance with the provisions of the bill, clients of banks for financial inclusion may include:

·       individuals (Ukrainian citizens, internally displaced persons, people with disabilities, the elderly, etc.);

·       small business entities;

·       civic and charitable organizations;

·       state and local government bodies — only with regard to the provision of basic services.

At the same time, legal entities (businesses and organizations) will be able to receive services from a financial inclusion bank provided that their annual income does not exceed the threshold set by the NBU.

This will make it possible to serve socially vulnerable customers who were previously denied access to banking products due to a lack of branches, complicated procedures, and low levels of financial literacy.

WHAT OPPORTUNITIES DOES THE FINANCIAL INCLUSION SYSTEM OFFER?

The introduction of a financial inclusion mechanism by banks is expected to have a number of positive effects:

·       Expanding geographic access to financial services — especially in de-occupied, border, and rural areas where traditional banks do not have branches.

·       Reducing the shadow economy — the ability to legalize the flow of funds through accessible bank accounts.

·       Financial inclusion for vulnerable populations — simplified access to social benefits, subsidies, and assistance programs.

·       Small Business Support — opening accounts, processing payments, and access to financial advice.

·       Improving financial literacy — through accompanying educational projects that financial inclusion banks will be able to implement in partnership with the government.

In addition, the creation of such institutions will help reduce the regulatory burden on traditional banks and attract new, highly specialized players (such as digital platforms, mobile operators, payment companies, etc.) to the financial sector.

LEGAL LITERACY—THE KEY TO SAFETY

It is worth emphasizing that financial inclusion is not just about opening accounts, but also about protecting the rights of financial services consumers. In this regard, it is important to ensure:

·       users’ legal awareness of their rights and obligations;

·       the existence of effective mechanisms for handling complaints and resolving disputes;

·       transparency of the terms for the provision of services;

·       preventing abuse by service providers.

The specialists at the international law firm ARMADUM LAWYERS provide support for the establishment of financial inclusion banks, develop internal policies, conduct legal reviews of customer interaction procedures, and help foster a culture of compliance in the new financial sector.

CONCLUSIONS

Financial inclusion is a strategic priority for Ukraine’s financial development. It creates the conditions for more equitable access to resources, promotes social integration, and enhances the financial resilience of citizens and small businesses.

The introduction of financial inclusion banks is not merely a matter of simplifying procedures, but rather building a new model of interaction between the government, financial institutions, and citizens, taking into account contemporary challenges and digital transformations. And the role of lawyers in this process is no less important—both in terms of lawmaking and in providing practical legal support to these new financial institutions.

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