Stronger Financial Markets and Institutions for Ukraine’s Recovery

5. Financial consumer protection and financial literacy in Ukraine

Abstract

This chapter provides recommendations to enhance financial consumer protection and financial literacy policies and practices in Ukraine, with a focus on themes identified as top priorities by Ukrainian authorities. It contains two sections. The first focuses on improving financial consumer protection, by strengthening the complaints handling and redress mechanisms across all financial services, improving consumer protection measures in the field of consumer credit, and aligning with international best practices and standards. The second section focuses on enhancing financial literacy, by better monitoring and evaluating the impact of financial literacy initiatives, by encouraging private and not-for-profit stakeholder participation while avoiding or mitigating conflicts of interest, and by aligning with international standards. The recommendations in this chapter draw on relevant OECD standards and international best practices.

Financial consumer protection and financial literacy are an important part of well-functioning financial markets as they promote fair and responsible treatment of consumers, and informed financial decision-making. This is especially important as individuals and households face financial stress in a war context. Financial consumer protection and financial literacy can help Ukrainians reinforce their financial resilience in the face of wartime pressures and losses.

Ukraine has made good progress towards strengthening its financial consumer protection and financial literacy frameworks, in line with international standards. However, several challenges remain as described in the Report “Mapping Ukraine’s Financial Markets and Corporate Governance Framework for a Sustainable Recovery” (OECD, 2025[1]). This chapter provides recommendations to address such challenges, focusing on priorities identified by Ukrainian authorities. The recommendations draw on the G20/OECD High Level Principles on Financial Consumer Protection, the OECD Recommendation on Consumer Protection in the field of Consumer Credit (the “OECD Credit Recommendation”), and the OECD Recommendation on Financial Literacy.

Table 5.1. List of recommendations in Chapter 5

#	Recommendation	Responsible authorities	Implementation timeline	Priority recommendation
1	Strengthen complaints handling and redress mechanisms in financial services.	NBU, NSSMC	Short	Yes
2	Enhance measures to improve consumer protection in the field of consumer credit.	NBU	Short	Yes
3	Enhance engagement and international collaboration through the OECD and FinCoNet in the field of financial consumer protection and market conduct supervision.	NBU, NSSMC	Medium	No
4	Continue efforts to further align with and consider adhering to the G20/OECD High Level Principles on Financial Consumer Protection, and the OECD Recommendation on Consumer Protection in the field of Consumer Credit.	NBU, NSSMC, other relevant institutions	Medium	No
5	Improve the impact assessment of financial literacy initiatives and take a more systematic approach to monitoring and evaluating financial literacy initiatives.	NBU, Members of the Interagency working group	Short	Yes
6	Continue to enhance the involvement of private and not-for-profit stakeholders in the implementation of Ukraine’s National Strategy for Financial Literacy Development, to avoid conflicts of interest and ensure integrity of financial literacy initiatives.	NBU, Members of the Interagency working group	Short	No
7	Continue efforts to further align with and consider adhering to the OECD Recommendation on Financial Literacy.	NBU, NSSMC other relevant institutions	Medium	No

5.1. Introduction

Over the past decade, Ukraine has made significant improvements to its financial consumer protection and financial literacy policies and practices, improving alignment with relevant Directives and Regulations of the European Union (EU), in accordance with the 2014 EU-Ukraine Association Agreement (EU, 2014[2]). It has also improved alignment with the G20/OECD High Level Principles on Financial Consumer Protection (OECD, 2022[3]), the OECD Credit Recommendation (OECD, 2019[4]), and OECD Recommendation on Financial Literacy (OECD, 2020[5]).

Since the start of Russia’s full-scale invasion, Ukraine has also adapted its financial consumer protection and financial literacy policies and activities, to reflect the priorities and needs of the war. At the same time, Ukrainian stakeholders have emphasised that wartime pressures, as well as limitations due to martial law, have resulted in delays in the adoption of certain laws and regulations, and in the implementation of financial literacy programmes, as well as impacting efforts to address ongoing challenges.

While Ukraine could benefit from addressing all the challenges mentioned in the Mapping Report to ensure full alignment with OECD standards, Ukraine has expressed its interest to prioritise the following key challenges:

• improving the efficiency of out-of-court complaint handling and redress mechanisms

• reinforcing financial consumer protection in consumer credit

• enhancing the impact assessment of financial education initiatives

• increasing the engagement of private and non-profit stakeholders in implementing the National Strategy for Financial Literacy Development until 2030.

This chapter provides policy recommendations on these topics, drawing on feedback from Ukrainian and international experts during an online workshop organised by the OECD on 2 July 2025, as well as the OECD recommendations listed above. International experts contributed by providing perspectives on enhancing financial consumer protection and financial literacy practices in their respective countries, and engaged in discussions with Ukrainian stakeholders, sharing practical examples and insights to address the challenges outlined above.

The chapter also provides additional recommendations to enhance Ukraine’s engagement with international partners, to support experience-sharing, and align and potentially adhere to two OECD Recommendations.

5.2. Supporting financial consumer protection in Ukraine

Effective financial consumer protection promotes fair and responsible treatment of consumers, increases trust and confidence in the financial system, and supports meaningful financial inclusion. Achieving these objectives can lead consumers to increase their participation in financial activities, such as savings, borrowing and investing, which contribute to economic growth and well-functioning financial markets. This is important given the current low level of investment in many financial instruments, as described in Chapter 2.

Financial consumer protection can foster healthy competition among financial service providers by allowing consumers to make informed decisions and choosing the best product for their needs. Protective measures during challenging times in Ukraine are vital to prevent abusive practices in financial markets, especially against vulnerable consumers, ensure access to clear information for informed decision-making, and promote economic recovery through empowered consumer participation and sound financial choices.

In recent years, Ukraine has made considerable progress in enhancing its financial consumer protection policies and practices, which now align more closely with the G20/OECD High Level Principles on Financial Consumer Protection as described in the Mapping Report. At the same time, the Mapping Report identified several challenges and areas of potential improvements that Ukraine could benefit from addressing.

This section provides recommendations to further improve financial consumer protection policies in Ukraine, with a focus on the areas identified as priorities by Ukraine and informed by discussions with Ukrainian stakeholders:1

• Strengthening complains handling and redress mechanisms in financial services.

• Enhancing measures to improve consumer protection in the field of consumer credit.

• Enhancing engagement and international collaboration through the OECD and the International Financial Consumer Protection Organisation (FinCoNet) working on financial consumer protection and market conduct supervision.

• Continuing efforts to further align and consider potential adherence to the G20/OECD High Level Principles on Financial Consumer Protection and OECD Credit Recommendation.

The OECD has also identified other challenges related to financial consumer protection, as noted in the Mapping Report. These are listed in Box 5.1, which also includes additional measures that could help Ukraine improve its financial consumer protection policies and practices.

5.2.1. Strengthening complaints handling and redress mechanisms in financial services

OECD Financial Consumer Protection Principle 12 stipulates that consumers should have access to adequate complaints handling and redress mechanisms that are accessible, affordable, independent and fair. These mechanisms should use technology where helpful and be designed to meet consumers’ needs. Moreover, financial services providers must have internal complaints handling mechanisms to resolve individual issues and identify systemic risks. When complaints are not resolved with the financial services provider concerned, consumers should have access to independent redress processes. Finally, aggregate information should be made public and available to relevant oversight bodies to support their activity.

In recent years, Ukraine has made considerable progress to enhance complaints handling and redress mechanisms of financial services providers. Consumers in Ukraine can make a complaint either with the financial service provider concerned or with the relevant financial sector regulator, i.e. the National Bank of Ukraine (NBU) or the National Securities and Stock Market Commission (NSSMC). Consumers can also resolve disputes outside the court system via mediation in accordance with the Law of Ukraine about Mediation (Verkhovna Rada of Ukraine, 2021[6]), or pursue legal action through the court system.

Efforts are also underway to align legislation with the EU Directive 2013/11/EU (EU, 2013[7]) which establishes a framework for alternative resolution in consumer disputes across all sectors of the economy, including financial services. The draft Law on Out-of-Court Settlement of Consumer Disputes in Ukraine, is intended to strengthen the complaint handling procedures in Ukraine by establishing a structured, accessible, and legally recognised alternative dispute resolution (ADR) framework for resolving consumer complaints. Its adoption is expected by the end of 2026.

Despite this progress, the effectiveness and consistency of the redress framework could be improved in the following ways.

First, while the NBU has issued guidance on banks’ internal complaints handling and redress mechanisms, such guidance does not apply to non-banks (OECD, 2025[1]). The NBU is developing a draft regulation to introduce requirements for banks and non-banks financial services providers to have complaints handling and redress mechanisms, as part of the Law of Ukraine on Financial Services and Financial Companies (Verkhovna Rada of Ukraine, 2021[8]). However, the draft legislation has not yet been formally adopted. The ongoing war and economic crisis following Russia’s full-scale invasion have led policymakers to delay regulatory reforms that would place additional burdens on financial institutions. In addition, the implementation of new complaint-handling standards would require investments in staff, software, and operational procedures, which are currently not feasible under martial law conditions.

Second, despite ongoing efforts to establish a formal ADR mechanism with the draft Law on Out-of-Court Settlement of Consumer Disputes in Ukraine, it has not yet been adopted. The public consultation on the draft Law on Out-of-Court Settlement of Consumer Disputes closed in June 2025 and the draft legislation will be discussed in Parliament (Verkhovna Rada). However, the draft legislation is unlikely to come into force while martial law is in place. Moreover, following adoption of the legislation, further work will be necessary to ensure that ADR mechanisms are effective, accessible, and widely understood by consumers.

Third, while the NBU is able to obtain data on consumer complaints from financial services providers on request, there are no requirements in place for financial services providers to record and report consumer complaint data to the relevant oversight body. Collection of data about consumer complaints is an important source of information both for financial services providers and regulators and supervisors.

To address these challenges, in line with the G20/OECD High Level Principles on Financial Consumer Protection and specifically with Principle 12 on complaints handling and redress, the following recommendations are proposed for Ukraine, to be implemented when political and institutional conditions allow:

• Require financial service providers to introduce and maintain complaint handling procedures, regardless of their distribution channels. The requirements should establish clear and standardised processes, designate responsible units or personnel within each financial service provider, and require that complaints can be submitted via multiple channels, including in-person, phone, and digital platforms. This is to ensure that the needs of all consumers are met, especially in the evolving digital finance landscape.

• Continue progress towards establishing a comprehensive ADR mechanism that is applicable across all financial service providers. Moreover, there should be mechanisms in place to ensure consumers have clear and timely access to information on how to use the ADR mechanism. ADR mechanisms exist in many countries. For instance, in Portugal, institutions supervised by Bank of Portugal are required to offer access to at least two ADR bodies and must inform consumers of their options. The Bank of Portugal maintains a public portal that lists the ADR bodies available to consumers and supports their use in response to complaints (Bank of Portugal, 2025[9]).

• Require financial services providers to record and report data on consumer complaints to the relevant oversight bodies. Complaints data should be used to inform regulatory, supervisory and enforcement activities.

• Follow the recommendations and guidance of relevant international networks on complaint handling and dispute resolution in financial services. For example, Ukrainian regulators could follow the work of international platforms such as the European FIN-NET or the International Network of Financial Services Ombudsman Schemes (INFO Network). These bodies offer valuable insight into best practices in dispute resolution.

5.2.2. Enhancing measures to improve consumer protection in the field of consumer credit

The OECD Credit Recommendation brings together global best practices regarding policy and regulation of consumer credit markets, to avoid over-indebtedness and promote responsible lending practices. The OECD Credit Recommendation aims to cover the full life cycle of consumer credit transactions by addressing consumer risks through standards on cost disclosure, responsible lending, fair contract terms, protection against abusive practices, oversight of credit reporting agencies, and ensuring access to redress mechanisms and competitive credit markets.

In 2023, to support responsible lending in the country and improve provisions to protect consumers, Ukraine introduced measures to enhance responsible lending practices. These include a ceiling on the cost of consumer credit (OECD, 2025[1]) and requirements on the calculation of the Daily Interest Rate (DIR).

Moreover, the NBU is developing legislation to enhance regulation of credit bureaus and ensure that credit information is accurate and up to date (see draft Law of Ukraine “On Credit History”, discussed in the Parliament in October 2025). The NBU is also developing legislation to introduce additional requirements to i) evaluate consumers' creditworthiness before entering into a credit agreement to ensure consumers are able to repay their debt, ii) limit access to credit for certain categories of individuals (i.e. those experiencing gambling-related problems, those in arrears, and those who repay their debt immediately after entering into the credit agreement to artificially improve their credit rating), and iii) ensure that large incomes are verified before consumers enter into a credit agreement.

Despite this progress, several challenges remain:

• The NBU continues to face challenges in effectively enforcing the regulatory framework and promoting responsible business conduct among consumer credit providers. For example, an off-site inspection of the largest microfinance organisations (MFO) revealed extensive non-compliance with the maximum Daily Interest Rate requirement, with the majority of MFOs using loopholes to circumvent the rule, such as through complex contractual arrangements.

• In relation to creditworthiness assessment, challenges include the unavailability of information about the monthly consumer loan servicing costs, which creates a gap in credit histories, the widespread use of revolving credit to artificially improve credit histories, gambling-related borrowing, and the use of short-term consumer credit products which may increase consumers’ over indebtedness and reduce the accuracy of creditworthiness assessments.2

To address these challenges, Ukraine should continue its efforts to enhance regulatory and supervisory measures, to help prevent and reduce over-indebtedness. This requires a comprehensive approach, with the authorities continuing their efforts to:

• Improve the accuracy and timeliness of credit information and enhance compliance with relevant legislation. For example, once adopted, it will be important to ensure that the draft law of Ukraine “On Credit History” is effectively implemented and enforced.

• Ensure compliance of consumer credit providers with existing regulation, such as on the calculation of the Daily Interest Rate and on the maximum cost of consumer credit.

• Align with the OECD Credit Recommendation. The OECD is currently revising the OECD Credit Recommendation to reflect recent developments and emerging trends in consumer credit markets, including the increasing digitalisation, debt collection practices, enhanced measures to protect consumers experiencing vulnerability, and the emergence of new forms of credit and credit-like products, such as buy now pay later products. Relevant authorities in Ukraine could benefit from the report on the Implementation of the OECD Credit Recommendation that describes how jurisdictions have implemented it.

5.2.3. Enhancing international engagement and co-operation through the OECD and FinCoNet

Relevant oversight bodies in Ukraine currently have limited engagement with the OECD and FinCoNet on financial consumer protection and market conduct supervision at the international level, which limits opportunities to share experiences and learn from international best practices in this area.

Ukraine is encouraged to continue participating in OECD work on financial consumer protection through the Working Party on Financial Consumer Protection, Education and Inclusion (Working Party), a forum for the exchange of best practices and expertise on financial consumer protection. In particular, the Working Party is responsible for monitoring and maintaining the G20/OECD High Level Principles on Financial Consumer Protection, the OECD Credit Recommendation, and the OECD Recommendation on Financial Literacy. This would allow Ukraine to stay abreast of relevant policy developments, as well as benefit from research, analysis and guidance, including, for example, the Compendium of Effective Approaches for Financial Consumer Protection, a living document designed to support the implementation of G20/OECD High Level Principles on Financial Consumer Protection , and the Consumer Finance Risk Monitor, which offers an international analysis of emerging risks to financial consumers and a practical toolbox that can guide Ukrainian institutions in designing and refining their financial consumer protection policies and practices.

Additionally, relevant Ukrainian institutions responsible for market conduct supervision, such as the NBU, could consider applying to become a Member of FinCoNet, the international network of market conduct supervisory authorities with responsibility for financial consumer protection. The goal of FinCoNet is to promote sound market conduct and enhance financial consumer protection through efficient and effective financial market conduct supervision, with a focus on banking and consumer credit. Membership of FinCoNet would allow Ukraine to benefit from the experience of peer organisations and exposure to good practices in undertaking market conduct supervision and enforcement initiatives, including on developing market supervisory capacity, consumer credit and complaint handling.

5.2.4. Further aligning with and considering adherence to the G20/OECD High Level Principles on Financial Consumer Protection and OECD Credit Recommendation

Ukraine is not an Adherent to the G20/OECD High Level Principles on Financial Consumer Protection and the Credit Recommendation, but it has expressed its commitment to further align and potentially adhere to these recommendations as part of the OECD Country Programme for Ukraine (OECD, 2023[10]) and as outlined in the Action Plan for its implementation (Verkhovna Rada of Ukraine, 2023[11]). Ukraine should thus further align its financial consumer protection policies and practices with the G20/OECD High Level Principles on Financial Consumer Protection and the OECD Credit Recommendation and consider potential adherence.

Box 5.1. Financial consumer protection: Other key challenges and potential measures

In 2024, as part of the Mapping Report, the OECD identified additional specific areas for attention in terms of alignment with the G20/OECD High Level Principles on Financial Consumer Protection. This box summarises these areas under the relevant Principle.

• Principle 3: Access and inclusion. Ukraine could consider implementing measures supporting vulnerable consumers to access basic financial services, (such as basic accounts with low-cost accessible account providing essential payment services), improving comparability of fees related to payment accounts, and facilitating payment account switching and access to payment accounts with basic features. To do so, Ukraine could continue its efforts to implement the Directive 2014/92/EU of the European Parliament and of the Council of 23 July 2014 on the comparability of fees related to payment accounts, payment account switching and access to payment accounts with basic features.

• Principle 5: Competition. Ukraine could consider strengthening measures to promote fair and efficient competition in financial markets, for example, by implementing measures to help consumers compare and switch financial products. To do so, Ukraine could continue to develop digital tools to help consumers access, assess and compare information about financial products and services.

• Principle 8: Quality Financial Products. Ukraine could consider strengthening measures to improve the provision of quality financial products, such as introducing product oversight and governance requirements. For example, Ukraine could introduce requirements for financial services providers to have appropriate systems to design, approve, manage, and monitor financial products through their life cycle. This would help to ensure that financial products and services meet the interests of target consumers, and support their financial well-being, and comply with the relevant regulatory requirements.

• Principle 9: Responsible Business Conduct and Culture of Financial Services Providers and Intermediaries. Ukraine could consider implementing standards relating to responsible business conduct and culture of financial services providers and intermediaries. For example, in addition to requirements relating to creditworthiness assessments, Ukraine could consider introducing requirements for financial services providers to assess the financial capabilities, needs and circumstances of potential customers before agreeing to provide financial services.

• Principle 10: Protection of Consumer Assets against Fraud, Scams and Misuse. In Ukraine, measures to protect consumers' assets in the event of the bankruptcy of a financial services provider, only exist for the banking sector. Ukraine could consider extending such measures to other financial services providers, such as insurance and pension products providers. Moreover, Ukraine has conducted an ad hoc nationwide survey on financial frauds and scams, which have been used in awareness raising campaigns. Ukraine could consider promoting regular data collection about scams to ensure regular monitoring and timely interventions.

• Principle 11: Protection of Consumer Data and Privacy. Ukraine could pursue its efforts to align its Personal Data Protection Law with the EU General Data Protection Regulation (GDPR), as part the EU-Ukraine Association Agreement.

Source: OECD (2025[1]), Mapping Ukraine’s Financial Markets and Corporate Governance Framework for a Sustainable Recovery, https://www.oecd.org/en/publications/mapping-ukraine-s-financial-markets-and-corporate-governance-framework-for-a-sustainable-recovery_866c5c44-en.html.

Recommendation 1: Strengthen complains handling and redress mechanisms in the sector of financial services sector in accordance with the G20/OECD High Level Principles on Financial Consumer Protection.

Recommendation 2: Enhance measures to improve consumer protection in the field of consumer credit in accordance with the OECD Credit Recommendation.

Recommendation 3: Enhance engagement and international co-operation through the OECD and FinCoNet on financial consumer protection and market conduct supervision.

Recommendation 4: Continue efforts to further align with and consider adhering to the G20/OECD High Level Principles on Financial Consumer Protection and the OECD Credit Recommendation.

5.3. Enhancing financial literacy in Ukraine

Financial literacy is essential to support a safe and informed use of financial services, to strengthen the financial resilience of the Ukrainian population in the face of wartime pressures and to contribute to their financial well-being in the longer term (OECD, 2020[5]; 2025[1]).

Ukraine has well-developed financial literacy policies and initiatives, which are mostly in line with the OECD Recommendation on Financial Literacy, as described in the Mapping report (OECD, 2025[1]). There are well established institutional foundations for improving financial literacy in the country. The Interagency Working Group approved the National Strategy for Financial Literacy Development until 2030 (NFLS) in March 2024 for the period 2024-2030 (NBU, 2024[12]). The Interagency Working Group is led by the NBU and composed of the following institutions: the Deposit Guarantee Fund; the NSSMC; the Ministry of Education and Science; the Ministry of Economy, Environment and Agriculture; the Ministry of Digital Transformation; and the State institution "Entrepreneurship and export promotion office". Each member of the Interagency Working Group also adopted the NFLS through a separate official decision.

Consistent with the OECD Recommendation on Financial Literacy, the NFLS constitutes a comprehensive document, that guides institutions involved in implementing financial literacy initiatives in the country. It includes clearly defined objectives, governance and co-ordination mechanisms, target groups, methods for resources and funding, as well as monitoring and evaluation of the effectiveness of the NFLS’ and financial literacy initiatives.

The NFLS also includes a roadmap, which defines the programmes and activities, and the responsibilities of different stakeholders in achieving its objectives. Several initiatives are implemented for children and young people; teachers and educators; adults; and owners of micro-enterprises (OECD, 2025[1]). Since 2024, the NBU and members of the Interagency Working Group have advanced significantly in implementing the measures defined in the roadmap, as reported by the NBU.

While significant progress has been made, the NBU and other stakeholders can further strengthen the design and implementation of financial literacy initiatives. In line with the OECD Recommendation on Financial Literacy, this section provides recommendations, with a focus on priority areas identified by national stakeholders in Ukraine:

• Improving the impact assessment of financial literacy initiatives and fostering a more systematic approach to monitoring and evaluating financial literacy initiatives.

• Continuing to enhance the involvement of private and not-for-profit stakeholders in the implementation of the National Strategy for Financial Literacy Development until 2030 in Ukraine to avoid conflicts of interest and ensure integrity of financial literacy initiatives.

• Continuing efforts to further align and consider potential adherence to the OECD Recommendation on Financial Literacy to strengthen financial literacy through comprehensive policy frameworks.

5.3.1. Improving the impact assessment of financial literacy initiatives and fostering a more systematic approach to monitoring and evaluating financial literacy initiatives

The OECD Recommendation on Financial Literacy highlights the importance of monitoring and evaluation to assess the progress of the NFLS and its initiatives and propose improvements.

Currently, most financial literacy programmes in Ukraine are assessed using basic monitoring indicators such as number of participants, number of messages delivered by information campaigns, and satisfaction surveys among participants. However, evidence from pilots and impact assessments of financial literacy programmes is limited in Ukraine and it appears that no financial education programmes in Ukraine are rigorously evaluated. Additionally, the NFLS does not promote the impact evaluation of the effectiveness of initiatives under the NFLS. Ukraine, as many other countries, faces challenges related to the availability of resources, and in encouraging stakeholders to assess the impact of their financial literacy initiatives.

Monitoring and evaluation of financial literacy activities can provide benefits for stakeholders in Ukraine and contribute to more effective programme delivery, including by:

• helping to determine whether objectives are being achieved, identifying areas for improvement to enhance impact, as well as generating insights that inform future activities and guide other stakeholders, reducing the risk of repeating inefficiencies.

• allowing for testing and comparing different approaches to identify those that are most effective or cost-efficient. This helps identify gaps in financial education provision and informs the development of more targeted and effective programmes.

• promoting knowledge sharing and cross-learning among stakeholders with similar goals, fostering innovation.

• strengthening the case for financial literacy programmes, which can help secure funding or scale up successful initiatives.

In this respect, Ukraine could foster a more systematic approach to monitoring and evaluating financial literacy initiatives. In enhancing the monitoring and evaluations of financial literacy initiatives, the NBU and other stakeholders of the NFLS could draw on approaches in line with the OECD Recommendation on Financial Literacy and lessons learnt and good practices from members of the OECD International Network of Financial Education (OECD/INFE) (OECD, 2022[13]) (as described in Box 5.2). These include:

• Prioritising resources for key impact evaluations. Since it may not always be possible to set aside resources to monitor and evaluate each programme, resources could be dedicated to evaluating the impact of key financial literacy programmes, i.e. stakeholders could identify those programmes that are expected to have the most impact and ensure they can be evaluated adequately.

• Evaluating impact on knowledge, attitudes, and behaviours. Measuring improvements in financial knowledge is often more straightforward than assessing changes in financial behaviours (e.g., saving rather than spending) and attitudes (e.g. adopting a long-term budgeting mindset), which tend to develop over time. However, financial attitudes and behaviours considerably affect individuals’ financial well-being and should therefore not be overlooked when evaluating the impact of financial literacy programmes.

• Collaborating with academia. Involving academic institutions in the design and evaluation of financial literacy programmes can enhance the quality of monitoring by leveraging their expertise, methodologies, and analytical skills. This partnership can also offer valuable research opportunities for scholars and students, creating a mutually beneficial relationship.

• Fostering a culture of evaluation. Building a community of practitioners involved in implementing and evaluating financial literacy programmes, consistently sharing results of evaluations after they are undertaken and promoting common approaches can be effective ways to encourage stakeholders to evaluate their financial literacy programmes.

Box 5.2. International examples on facilitating the impact assessment of financial literacy initiatives.

Austria adopted its first National Financial Literacy Strategy (NFLS) in 2021, which defines a range of specific goals with the aim of enhancing the financial well-being of the population. Numerous institutions are contributing to the NFLS through their financial literacy initiatives. One of the policy priorities of Austria’s NFLS is increasing the effectiveness of financial literacy initiatives through dialogue, coordination and evaluation (OECD, 2021[14]).

Building on this, Austria’s Central Bank (OeNB) published a “Financial Literacy Evaluation Series” to addresses topics related to financial literacy and its evaluation (OeNB, 2025[15]). This series provides a comprehensive guide that aims to inform researchers, policymakers, and educators about the current state of evaluation research on financial literacy and education. The series provides an overview of the literature addressing the effectiveness of financial education programmes and presents guidelines for designing and implementing comprehensive evaluation studies. Further articles in the series will be published on the OeNB website.

In the United Kingdom, the Money and Pensions Service (MaPS) is responsible for the UK Strategy for Financial Wellbeing 2020–2030, a ten-year framework to help individuals make the most of their money and pensions. To support UK stakeholders in assessing the impact of their financial education initiatives, and ultimately to improve people’s financial wellbeing, MaPS developed a Financial Wellbeing Evaluation Toolkit and an Evidence Hub. The Toolkit and Hub:

• help organisations evaluate their programmes, understand their impact, and generate useful evidence about financial well-being, and

• offers a space for organisations to share their findings, for the benefit of others.

The Financial Wellbeing Evaluation Toolkit, developed with academics and other experts, can be used by any organisation that wishes to measure and understand changes in people’s financial well-being, behaviour or capability (UK MaPS, 2025[16]). For example:

• For programme providers: it can help to plan and carry out evaluations of their programmes; to generate more evidence that can be used to refine activity; or to demonstrate impact to funders.

• For funders: it can help to improve programme design and application process (e.g. using a Theory of Change); to develop resources which can support delivery partners, applicants and grant holders; to support to plan and carry out evaluations of funded programmes.

• For researchers and evaluators: it can provide a set of evidence-based, tried-and-tested outcomes frameworks and question banks to assist with measuring financial well-being outcomes.

The Financial Wellbeing Evidence Hub aims to help organisations design their interventions, funding programmes and policies, by making evidence, insight and learning easier to find and understand (UK MaPS, 2025[17]). It contains two areas:

• Evidence summaries, which include research studies, evaluations and reviews of findings from the UK and around the world.

• Thematic reviews, which bring together findings from multiple research and evaluation studies on specific topics, to highlight practical learning for funders, practitioners and researchers.

Source: OeNB and MaPS.

5.3.2. Enhancing the involvement of private and not-for-profit stakeholders in the implementation of the NFLS

Stakeholder co-ordination is vital for all financial literacy policies and programmes, as emphasised by the OECD Recommendation on Financial Literacy. The NBU has expressed a strong interest in expanding its collaboration with private sector and not-for-profit organisations, whose enhanced participation could support financial literacy through the implementation of initiatives as well as by contributing funding, expertise, educational materials, and access to consumers during key life moments, thereby strengthening the reach and impact of public efforts.

Ukraine already has a well-functioning, collaborative and centralised approach in place. The NBU develops financial education content and provides it to private and not-for-profit stakeholders, who may use it and distribute it under strict conditions. Materials must remain unaltered unless formally approved. Advertising of financial products and services is prohibited, apart from stakeholder logos, and stakeholders are required to report on outreach results. For larger initiatives, a memorandum of co-operation may be signed.

Despite this structured approach, Ukraine faces challenges in continuing existing partnerships or attracting new partners, particularly international donors. The war context also means that financial education may fall down the list of national priorities. Moreover, such partnerships may raise challenges, such as conflicts of interest, the potential misuse of financial education content for commercial purposes, or a focus on segments of the population that are more profitable or already financially included.

Building on the existing foundation for the co-ordination and implementation of the NFLS through the Interagency Working Group, Ukraine could continue enhancing its collaboration with private and not-for-profit stakeholders, as well as international donors. In doing so, the NBU and other stakeholders could apply the following approaches, drawing on the good practices and experiences of OECD/INFE members (examples provided in Box 5.3), and the OECD Recommendation on Financial Literacy:

• Promote effective co-ordination across stakeholders as part of the NFLS in Ukraine. This requires fostering a collaborative approach where all stakeholders work towards shared objectives. Additionally, effective co-ordination can also ensure that when private sector and NGO representatives are implementing financial education programmes in school or among children and youth, their interventions are aligned with the school curriculum.

• Implement mechanisms that reduce and address conflicts of interest. Encouraging the participation of private sector stakeholders through national industry associations or self-regulatory bodies can help foster accountability and transparency as well as avoid the marketing of specific financial products or services. Moreover, promoting the development and adherence to codes of conduct by industry associations, financial institutions and NGOs, can strengthen ethical standards. Ukraine could also ensure compliance by setting up certification or accreditation processes, combined with adequate monitoring.

• Ensure that criteria of impartiality, objectivity, quality, and fairness are adhered to when stakeholders carry out financial education initiatives. Clear distinctions should be made between commercial interests and educational content, and the promotion of financial products and services within educational activities should be avoided.

Box 5.3. Examples of governance measures for private and non-for-profit stakeholder participation in financial literacy initiatives

In Ireland, the Financial Literacy Executive Board, as the co-ordinating body of the National Financial Literacy Strategy, developed guidelines to provide financial education in schools (Department of Finance of Ireland, 2025[18]).

These guidelines aim to build quality partnerships between schools and the financial services industry in delivering financial education programmes, to improve financial literacy, financial resilience and overall financial well-being of children and young people.

In Austria, the Ministry of Finance has developed a “Code of Conduct for Board Members and Interested Stakeholders of the National Financial Literacy Strategy” (Ministry of Finance of Austria, 2025[19]). The code of conduct provides a shared framework and core values that all stakeholders are required to uphold to participate in the implementation of the National Financial Literacy Strategy.

The code of conduct outlines seven principles that should guide ethical behaviour and collaboration within financial literacy initiatives. For example, these principles aim to ensure that financial education programmes contain no political or ideological content, remain separate from commercial activities, and avoid any advertising, product placement, or endorsement of financial services.

Sources: OeNB; questionnaire on the implementation, dissemination and continued relevance of the OECD Recommendation on Financial Literacy.

5.3.3. Further aligning with and considering adherence to the OECD Recommendation on Financial Literacy

Ukraine has well-advanced financial literacy policies and initiatives, mostly in line with the OECD Recommendation on Financial Literacy. Ukraine has also taken steps to strengthen its co-operation with the OECD in this policy field, as a Full Member, through the NBU, of the OECD/INFE and by actively participating in the Technical Assistance Project on Financial Education in the Constituency Programme of the Ministry of Finance of the Netherlands, which the OECD is implementing in ten Eastern and South Eastern European countries.

At the same time, Ukraine is not an Adherent to the OECD Recommendation on Financial Literacy. The authorities have expressed a commitment to further align with the OECD Recommendation on Financial Literacy and consider potential adherence, as part of the OECD Country Programme for Ukraine (OECD, 2023[10]) and as outlined in the Action Plan for its implementation (Verkhovna Rada of Ukraine, 2023[11])

Ukraine could strengthen its commitment by formally adhering to the OECD Recommendation on Financial Literacy, which would highlight its willingness to align its financial literacy framework with OECD policies and practices. This would also reinforce its co-operation with the OECD. Importantly, in 2025-26, the OECD Committee on Financial Markets, via its Working Party on Financial Consumer Protection, Education and Inclusion and the OECD/INFE, is undertaking an assessment of the implementation, dissemination, and continued relevance of the OECD Recommendation on Financial Literacy. This assessment is informed by the responses to a questionnaire to which Ukraine responded to.

Recommendation 5: Improve the impact assessment of financial literacy initiatives and take a more systematic approach to monitoring and evaluating financial literacy initiatives.

Recommendation 6: Continue to enhance the involvement of private and not-for-profit stakeholders in the implementation of the National Strategy for Financial Literacy Development until 2030 in Ukraine (NFLS) to avoid conflicts of interest and ensure integrity of financial literacy initiatives.

Recommendation 7: Continue efforts to further align and consider adhering to the OECD Recommendation on Financial Literacy.

References

[9] Bank of Portugal (2025), Disputes on banking products and services, https://clientebancario.bportugal.pt/en/resolucao-litigios-instituicoes?.

[18] Department of Finance of Ireland (2025), Financial Education in Schools: Guidelines for the Financial Services Industry, https://www.gov.ie/en/department-of-finance/publications/financial-education-in-schools-guidelines-for-the-financial-services-industry/?.

[2] EU (2014), Official Journal of the European Union; Association agreement between the European Union and its Member States, of the one part, and Ukraine, of the other part; L 161/3, https://publications.europa.eu/resource/cellar/4589a50c-e6e3-11e3-8cd4-01aa75ed71a1.0006.03/DOC_1.

[7] EU (2013), Directive 2013/11/EU of the European Parliament and of the Council of 21 May 2013 on alternative dispute resolution for consumer disputes and amending Regulation (EC) No 2006/2004 and Directive 2009/22/EC (Directive on consumer ADR), https://eur-lex.europa.eu/eli/dir/2013/11/oj.

[19] Ministry of Finance of Austria (2025), Verhaltenskodex für Organmitglieder und interessierte Akteurinnen und Akteure der Nationalen Finanzbildungsstrategie, https://finanznavi.gv.at/media/733/download/Verhaltenskodex%20der%20Nationalen%20Finanzbildungsstrategie_Mai%202025.pdf?v=1&inline=0.

[12] NBU (2024), National Strategy for Financial Literacy Development until 2030, https://bank.gov.ua/en/about/strategy-fin-literacy.

[1] OECD (2025), Mapping Ukraine’s Financial Markets and Corporate Governance Framework for a Sustainable Recovery, OECD Publishing, Paris, https://doi.org/10.1787/866c5c44-en.

[10] OECD (2023), Ukraine Country Programme, https://www.oecd.org/en/about/programmes/oecd-ukraine-country-programme.html.

[13] OECD (2022), Evaluation of National Strategies for Financial Literacy, https://www.oecd.org/financial/education/evaluation-of-national-strategies-for-financial-literacy.htm.

[3] OECD (2022), Recommendation of the Council on High-Level Principles on Financial Consumer Protection, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0394#committees.

[14] OECD (2021), A National Financial Literacy Strategy for Austria, https://www.oecd.org/en/publications/a-national-financial-literacy-strategy-for-austria_f6d11a4b-en.html.

[5] OECD (2020), Recommendation of the Council on Financial Literacy, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0461 (accessed on 28 April 2022).

[4] OECD (2019), Recommendation of the Council on Consumer Protection in the field of Consumer Credit, https://legalinstruments.oecd.org/en/instruments/oecd-legal-0453.

[15] OeNB (2025), OeNB Financial Literacy Evaluation Series, https://www.oenb.at/Publikationen/finanzbildung/financial-literacy-evaluation-series.html.

[16] UK MaPS (2025), The Financial Wellbeing Evaluation Toolkit, https://www.fincap.org.uk/en/articles/evaluation-toolkit.

[17] UK MaPS (2025), the Financial Wellbeing Evidence Hub, https://www.fincap.org.uk/en/articles/financial-capability-evidence-hub.

[11] Verkhovna Rada of Ukraine (2023), Some issues of cooperation between the Cabinet of Ministers of Ukraine and the Organization for Economic Cooperation and Development in the context of the dialogue on joining the Organization; Resolution of the Cabinet of Ministers of Ukraine; No. 1165, https://zakon.rada.gov.ua/laws/show/en/1165-2023-%D0%BF?lang=uk#Text.

[6] Verkhovna Rada of Ukraine (2021), Law of Ukraine about Mediation; Document 1875-IX, https://zakon.rada.gov.ua/laws/show/1875-20#Text.

[8] Verkhovna Rada of Ukraine (2021), Law of Ukraine on Financial Services and Financial Companies, No. 1953-IX, https://zakon.rada.gov.ua/laws/show/1953-20#Text.

Notes

← 1.  These challenges were discussed by the National Bank of Ukraine during the workshop on Financial Consumer Protection and Financial Literacy in Ukraine organised by the OECD on 2 July 2025.

← 2.  Ibid.