Key Facts for Ukraine
- Primary real-time rails: System of Electronic Payments (SEP).
- Typical settlement times: Up to 10 seconds.
- Common limits: UAH 100,000 per transaction; daily limits vary by institution.
What “real-time payments” means in Ukraine
In Ukraine, real-time payments are defined as “instant credit transfers”—direct account-to-account transactions using an IBAN that settle within 10 seconds. Available 24/7, this system is distinct from card-based P2P transfers. All payment service providers must offer the service to residents for transactions, typically up to UAH 100,000. The legal framework is rooted in amendments to the Law of Ukraine On Payment Services, which aligns the country with EU regulations and mandates that providers offer instant transfers through the same remote channels as standard credit transfers.
The National Bank of Ukraine (NBU) acts as both the lead regulator and the system operator. It manages the core infrastructure, the System of Electronic Payments (SEP), which processes more than 98% of the country’s interbank payments. The SEP functions as the central clearing and settlement mechanism, with no subsidiary clearing houses involved. This system operates on the ISO 20022 messaging standard, modernizing its financial communications and preparing the nation for deeper integration with international payment networks.
By adopting SEPA schemes and the ISO 20022 standard, Ukraine is building a payment architecture designed for future integration with the European market, with adoption rates projected to exceed European peers.
Payment Rail Overview
System of Electronic Payments (SEP)
The System of Electronic Payments (SEP) is Ukraine's state-operated, real-time gross settlement system, processing over 98% of all interbank hryvnia transactions. It facilitates instant credit transfers directly between IBAN accounts, with funds settling in under 10 seconds. The modern, 24/7 version of SEP based on the ISO 20022 standard became operational on April 1, 2023, with the formal “Instant Transfers” initiative launching in December 2024.
- 24/7/365 Availability: The system operates around the clock, allowing for payments at any time, including nights, weekends, and holidays.
- ISO 20022 Standard: It uses the global financial messaging standard, which supports rich data and interoperability with international systems like SEPA.
- Direct Account-to-Account Transfers: Payments move directly from one IBAN to another, bypassing traditional card networks for clearing.
- Rapid Settlement: Transactions are finalized in under 10 seconds, with funds made immediately available to the recipient.
- QR Code and Deeplink Initiation: Payments can be started by scanning a QR code or using a deeplink, simplifying the user experience for retail and peer-to-peer transactions.
- High Transaction Limit: A standard limit of UAH 100,000 per transaction covers the vast majority of individual and small business payment needs.
Pros
- Speed and Availability: Near-instant settlement and constant operation improve cash flow for businesses and individuals.
- Reduced Merchant Costs: The system can operate without payment terminals, lowering acceptance costs for merchants.
- High Reliability: The SEP has proven its resilience, maintaining uninterrupted operation even during wartime conditions.
- EU Integration: Its architecture is designed for future integration with European payment markets.
Cons
- Irreversible Transactions: Once a payment is executed, it cannot be canceled or changed, creating risk if incorrect details are entered.
- Phased Rollout: The service only works if both the sender's and receiver's banks have joined the initiative, which may cause initial inconsistencies as adoption grows.
- Compliance Scrutiny: Transactions may be rejected or suspended for financial monitoring, especially if they appear structured to avoid reporting thresholds.
- Resident-Only: The service is currently limited to residents of Ukraine.
Limits, Fees, and SLAs
- Limits: A per-transaction cap of UAH 100,000 is standard. Daily and monthly limits are determined by individual banking institutions.
- R2P Fees: Fees are set by individual banks and do not exceed the cost of a regular transfer. No additional charges apply for instant payments.
- Operating Hours: The system operates 24/7, including nights, weekends, and holidays, with no specified cut-off times for processing transactions.
- Failures & Returns: Payments are final and cannot be reversed. Banks may reject transfers for compliance checks, prompting users to use regular payment methods instead.
Compliance and Risk
KYC/KYB & AML
Ukrainian law requires a risk-based approach to financial monitoring. Institutions must perform thorough client due diligence, identify beneficial owners, and report suspicious activity or transactions over UAH 400,000. Ongoing monitoring is a foundational part of this framework.
Data Residency & Privacy
To ensure operational continuity, the NBU authorized banks to use cloud services with hardware located in the EU, UK, US, and Canada. This measure allows for the preservation of critical information if domestic infrastructure is compromised, prioritizing system resilience.
Fraud Controls
Payment providers must implement strong risk management frameworks. This includes monitoring for suspicious activity like transaction structuring and screening against sanctions lists. Banks have the authority to suspend payments that trigger these risk-based checks, ensuring system integrity.
Recordkeeping & Audits
Financial institutions must establish dedicated internal audit and compliance departments. They are required to document all transactions, maintain updated client data, and produce reports on suspicious activity for authorities, creating a clear audit trail for regulatory review.
Lightning Network Integration as a Solution
The Lightning Network is a second-layer protocol built on Bitcoin that creates off-chain payment channels for fast, inexpensive transactions. While domestic RTP rails like Ukraine’s SEP offer impressive speed for local payments, they are confined by national borders. The Lightning Network complements these systems by acting as a global settlement layer, extending real-time payment capabilities across international boundaries without requiring direct integration between country-specific systems.
Lightning transactions settle nearly instantly with fees of mere fractions of a cent, making micropayments practical. In comparison, Ukraine’s RTP settles in under 10 seconds with bank-determined fees. The most significant distinction is reach; while the SEP is restricted to Ukrainian residents, the Lightning Network offers borderless money movement to anyone with an internet connection, creating a truly global payment infrastructure.
- Cross-Border Complexity: The Lightning Network bypasses the high fees, delays, and intermediary banks typical of international transfers, offering a direct path for global payments where domestic RTP systems are limited.
- Micropayment Inefficiency: With its extremely low transaction costs, the network makes it economically viable to process high volumes of small payments, such as for content streaming or online gaming, which are often impractical on traditional rails.
- Limited Interoperability: It functions as a universal payment layer, connecting different regions and currencies without needing formal agreements between national banking systems, overcoming the walled-garden nature of many domestic RTPs.
For businesses with global ambitions, the Lightning Network presents a clear path toward a more open and interconnected financial future.
B2B Enterprise Use Cases
- Supplier Payments – Instantly pay international suppliers directly over the network, bypassing correspondent banks and SWIFT delays.
Business value: Reduces cross-border transaction fees and settlement times from days to seconds. - Merchant Settlement – Consolidate global customer payments in real-time and settle funds directly to corporate accounts without intermediaries.
Business value: Improves cash flow and eliminates costly interchange fees and chargeback risks. - Treasury Optimization – Move liquidity between international subsidiaries instantly, 24/7, to manage working capital and respond to market opportunities.
Business value: Provides real-time global cash management and reduces foreign exchange conversion costs. - Global Payroll – Automate salary and wage payments to a global workforce, including freelancers and remote employees, with instant settlement.
Business value: Simplifies global payroll operations and offers employees immediate access to their earnings. - API Monetization – Charge for API calls on a per-use basis, collecting micropayments automatically as services are consumed.
Business value: Creates new revenue models by monetizing data and services at a granular level.
Cross-Border Transactions and Remittances to Ukraine
Cross-border real-time payments into Ukraine are complicated by regulatory friction and capital controls. Sending funds internationally often requires extensive paperwork and navigating strict currency rules designed to maintain financial stability. Reaching Ukraine financially involves bridging different payment rails—connecting traditional banking systems with modern networks—and managing complex FX paths for currency conversion. These hurdles create delays and add operational overhead, limiting the efficiency of global money movement for businesses and individuals alike.
- European Union: Ukraine’s path to SEPA integration aims to simplify euro transfers for businesses and non-profits. Currently, these transactions can be slowed by complex payment orders and paperwork.
- Personal Remittances: Individuals face a monthly limit of UAH 100,000 on P2P transfers to prevent capital flight. However, the NBU allows unlimited transfers for specific needs like tuition and medical expenses.
- Corporate Finance: Ukrainian businesses can make cross-border payments to non-residents for loan and interest repayments. These transfers are permitted under specific NBU decrees, often involving international financial organizations or foreign state-backed agencies.
The Lightning Network offers a global settlement layer that bypasses these traditional bottlenecks. It transforms multi-day, high-fee international wires into instant, low-cost payments, settling transactions in real-time across borders and turning a common friction point into a competitive advantage.
How Lightspark Makes Integration Easy
Lightspark helps fintechs, digital banks, wallets, and exchanges connect to the Lightning Network by managing the operational complexities. Our enterprise-grade platform handles real-time liquidity, optimized routing, and built-in compliance screening, all accessible through comprehensive developer tooling and APIs. This allows you to offer customers sub-second settlement globally for a fraction of a cent, extending your payment capabilities far beyond domestic rails. If you're ready to build on a truly global payment infrastructure, Talk to our team.
Sources and Further Reading
- https://aub.org.ua: Ukraine instant transfer adoption projections.
- https://bank.gov.ua: NBU clarifies cross-border transaction limits.
- https://bank.gov.ua: NBU overview of instant payments.
- https://www.deloitte.com: Deloitte analysis of currency restrictions.
- https://www.europeanpaymentscouncil.eu: Ukraine's wartime payment system resilience.
- https://www.lightspark.com: Contact the Lightspark sales team.
- https://www.lightspark.com: Legality of cryptocurrency in Ukraine.
- https://www.lightspark.com: Explaining the Lightning Network's purpose.
- https://www.lightspark.com: Introduction to Lightning Network payments.
- https://www.transfi.com: How Ukraine's payment rails work.
- https://ukrsibbank.com: Bank details on instant transfers.
