Stronger Financial Markets and Institutions for Ukraine’s Recovery

1. Recommendations and roadmap

Abstract

This chapter lists the OECD’s recommendations to build stronger financial markets and institutions in Ukraine, as discussed in detail in Chapters 2-6. The recommendations are organised into a roadmap to support effective implementation, based on the level of importance (priority versus supporting recommendations), the timeframe (short, medium and long term), and the proposed allocation of responsibility across government agencies.

1.1. Overview of the report and objectives

This report provides a package of recommendations to support Ukraine’s economic recovery from Russia’s full-scale invasion. It focuses on measures relating to Ukraine’s financial markets and corporate governance framework, building on the key challenges and priority areas identified in the OECD report Mapping Ukraine’s Financial Markets and Corporate Governance for a Sustainable Recovery (hereafter the “Mapping Report”) (OECD, 2025[1]).

The report and recommendations are also informed by inputs and dialogue with the Ukrainian government, experts from OECD countries and international organisations, as well as private sector stakeholders and academia. A series of consultations and virtual workshops were carried out over the course of 2025, culminating in the OECD Roundtable on strengthening Ukraine’s financial markets and corporate governance held in December 2025, during which this report and the list of recommendations were discussed with senior Ukrainian and international representatives.

This work has been carried out as part of the OECD’s Review on improving financial markets and corporate governance for Ukraine’s recovery, a two-year project led by the OECD Capital Markets and Financial Institutions Division and carried out within the framework of the OECD Country Programme for Ukraine (OECD, 2023[2]).

The overall objectives of the recommendations are to enhance corporate governance and ensure well-functioning financial markets and institutions. Both are essential and complementary to support Ukraine’s strong, swift and sustainable recovery:

• Corporate governance ensures that businesses are efficient and well-managed. This is crucial for creating value and contributing to the country’s economic development.

• Financial markets and institutions need to be resilient and well-functioning. They play a key role in efficiently allocating public and private capital to the most productive uses.

Ukraine’s success in strengthening its business and finance framework is also dependent on continued work to eradicate corruption and improve integrity in business and governance. Without greater transparency and anti-corruption measures, market efficiency and business confidence will continue to suffer, and measures will fail to deliver sustainable, inclusive economic development. During the two years of the OECD project, many stakeholders have emphasised that low confidence in institutions and the rule of law is preventing market development, with many businesses preferring to carry out activities abroad where possible.

1.2. OECD recommendations to strengthen financial markets and institutions for Ukraine’s recovery

This chapter brings together all OECD recommendations to strengthen Ukraine’s financial markets and corporate sector. The chapter provides a roadmap for implementation, developed in consultation with Ukrainian authorities. The priority recommendations are listed in Table 1.1, while the other supporting recommendations are listed in Table 1.2.

The recommendations should be considered as a single package that should be implemented in parallel, according to the timeframe proposed in the roadmap below. However, given capacity constraints caused by the ongoing war, some recommendations should be addressed as a top priority. These are classified in the report as “priority recommendations”, based on the following criteria:

• Systemic importance: priority recommendations will have a significant impact on the structure of Ukraine’s markets, on consumers, and on business activity.

• Economic impact: priority recommendations will have a significant impact on Ukraine’s economic development and prosperity.

Table 1.1. List of priority recommendations

Priority recommendations		Responsibility	Timeframe
Chapter 2: Financial System
	Once security and macroeconomic conditions have stabilised, gradually ease foreign exchange restrictions to encourage foreign investment and rebuild market confidence.	NBU	Medium
	Redesign legislation on venture collective investment institutions to increase transparency and achieve targeted frameworks for different investment purposes.	NSSMC, NBU	Medium
	Finalise and implement the alignment of capital market regulations with IOSCO standards, strengthening supervisory capacity and enforcement mechanisms to build investor confidence.	NSSMC, NBU	Short
	Progressively narrow the scope of state subsidies for business loans and carry out a cost-benefit analysis in the medium term to determine whether they can be phased out.	MEEA, MoF	Medium
	Consider a wider use of credit guarantees to stimulate corporate lending, while carefully calibrating coverage ratios, eligibility criteria and risk sharing in line with best practices.	MEEA, MoF	Medium
	Consider better targeting or phasing out the eOselya programme while addressing other barriers to the development of the mortgage market.	MEEA, MoF	Medium
	Address housing‑market supply constraints by increasing public investment in social housing, expanding access to war‑risk insurance, and developing mortgage lending.	MEEA, MoF, NBU	Medium
Chapter 3: Corporate Governance
	Advance towards an integrated or well-coordinated capital market infrastructure with adequate related services for companies.	NSSMC, MoF	Long
	Reinforce the NSSMC’s regulatory capacity to draft secondary legislation required for supervision and enforcement procedures.	NSSMC, CMU	Short
	Enhance the NSSMC’s independence by reforming its appointment processes and governance.	NSSMC, CMU	Short
	Enhance implementation of corporate governance standards by applying a national code to all listed companies and clarifying the scope of its application and related disclosure.	NSSMC	Medium
Chapter 4: Public Debt Management
	Focus on building and extending a liquid and smooth local currency curve.	MoF	Short
	Pursue the renegotiation of outstanding external public and publicly guaranteed debts and contingent liabilities.	MoF	Medium
	Maintain updated registers for all state guarantees on the MOF’s website and move to regular consolidated reporting of all measured contingent liabilities.	MoF	Medium
Chapter 5: Financial Consumer Protection and Financial Literacy
	Strengthen complaints handling and redress mechanisms in financial services.	NBU, NSSMC	Short
	Enhance measures to improve consumer protection in the field of consumer credit.	NBU	Short
	Improve the impact assessment of financial literacy initiatives and take a more systematic approach to monitoring and evaluating financial literacy initiatives.	NBU Interagency working group	Short
Chapter 6: Asset-Backed Pensions
	Diversify the sources to finance retirement by creating complementary asset-backed pensions.	MSPFU	Medium
	Determine the institutional setup of prospective asset-backed pension arrangements.	MSPFU	Medium
	Put in place mechanisms that protect the assets managed by pension providers.	NSSMC, Other relevant institutions	Medium
	Develop the asset-backed pension framework to ensure effective governance, regulation and supervision of pension providers.	MSPFU	Medium
	Assess the costs of introducing asset-backed pensions considering the new operational capacities needed.	MoF	Medium
	Ensure that contributions to asset-backed pensions come from new savings and not from contributions diverted from the unfunded PAYG public pension system.	MoF, MoE	Medium

Table 1.2. Other supporting recommendations

Recommendation	Responsibility	Timeframe
Chapter 2: Financial System
Launch targeted public awareness campaigns to strengthen trust in financial markets and reinforce confidence in the rule of law.	MoF	Medium
Support the development of life insurance products and promote asset-backed pension schemes.	MoF	Medium
When security and fiscal conditions have stabilised, consider aligning the tax treatment of government bonds to that of securities issued by private entities and simplify the tax treatment of bond investors.	MoF	Medium
Consider listing stakes in state-owned banks on the stock market, to reduce state ownership in the banking system and stimulate the development of the capital market.	MoF, NSSMC	Long
Consider regulatory and market development measures to reduce the concentration of government bonds in the banking system in the medium run.	MOF, NBU, NSSMC	Medium
Advance liberalisation reforms to foster the development of trade financing instruments, starting with the full implementation of the factoring law.	MEEA, MoF	Medium
Consider introducing prudential limits for mortgage borrowing, such as loan-to-value or debt-service-to-income in line with international best practice to safeguard financial stability as the non-subsidised mortgage market develops.	NBU	Long
Consider expanding the range of firms and products that are eligible to participate in the NBU Regulatory Sandbox, to support innovation and ensure a level playing field across financial sub-sectors.	NSSMC, NBU	Medium
Chapter 3: Corporate Governance
Set up a growth equity market with a focus on SMEs.	NSSMC	Medium
Revise NSSMC regulations for stock market functioning, including updating listing requirements, along with increasing integration into global capital markets.	NSSMC	Short
Establish a monitoring system for companies’ compliance with a corporate governance code or standards, including a national report on corporate practices.	NSSMC	Medium
Chapter 4: Public Debt Management
Consider the case for setting up a designated debt management office with all functions (front, middle, and back office) in one place.	MoF CMU	Long
Enhance risk management through the development and integration of the middle office function.	MoF	Short
Assess the case for issuing new debt instruments.	MoF	Medium
Assess the specific case for expanding the retail programme to offer digital access to non-marketable products.	MoF	Medium
Pilot AI-enhanced forecasting tools to sharpen the precision of cash flow forecasting.	MoF	Short
Monitor technological advances, for example in DLT/CBDC innovations, and trends applicable to cash and liquidity management and consider testing small-scale pilots/sandboxes.	MoF NBU	Medium
Update the methodological guidance for assessing fiscal risks in key spending areas and contingent liabilities, including PPPs, guarantees, local governments and SOEs, and publish the methodology used to price fees.	MoF	Medium
Consider giving the debt management function a greater role in advising on the provision of guarantees, and make the middle office specifically responsible for the risk management of the guarantee portfolio.	MoF	Medium
Chapter 5: Financial Consumer Protection and Financial Literacy
Enhance engagement and international collaboration through the OECD and FinCoNet in the field in financial consumer protection and market conduct supervision.	NBU, NSSMC	Medium
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
Continue to increase 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 the integrity of financial literacy initiatives.	NBU, Interagency working group	Short
Continue efforts to further align with, and consider adhering to, the OECD Recommendation on Financial Literacy.	NBU, NSSMC, Other relevant institutions	Medium
Chapter 6: Asset-Backed Pensions
Ensure that the design of the DC pensions plans is coherent, inclusive and set contribution levels such that they are sufficiently high to achieve retirement income objectives.	MSPFU, MoF	Medium
Design financial incentives to maximise the impact on enrolment and contributions.	MSPFU, MoF	Medium
Ensure that the design of DC pensions promotes low-cost and cost-efficient retirement arrangements in both the accumulation and pay-out phases.	MSPFU, NSSMC	Medium
Ensure that all individuals have access to appropriate and sustainable investment strategies and a well-designed default.	MSPFU, MoF, NSSMC	Medium
Ensure that the design of DC pension plans provides protection against longevity risk in retirement, and that longevity risk is regularly monitored and managed.	MSPFU	Medium
Build trust in the system by ensuring effective, personalised, regular, consistent and unbiased communication to members, and by promoting awareness of and supporting financial education on retirement and pensions.	MSPFU	Medium
Build a strong regulatory framework that ensures that pension providers manage retirement savings in the best interest of their members.	MSPFU	Medium
Provide the necessary capabilities, resources, powers and protections to the supervisory authorities to implement the pension regulation and adopt a risk-based approach to supervision.	MSPFU	Medium

1.2.1. Implementation timeframe

All recommendations have also been classified according to the proposed timeframe for implementation:

• Short term: Measures that should be implemented as early as possible, including during martial law where possible.

• Medium term: Measures that are more appropriate to implement once security and economic conditions stabilise, possibly after martial law ends.

• Long term: Measures that should be implemented gradually and are dependent on wider structural reforms or market developments.

References

[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.

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