Assistance projects - Komisja Nadzoru Finansowego

International cooperation

Twinning project for the National Bank of Ukraine financed from EU funds ‘Implementing effective supervision over non-bank financial institutions’

Modification date:

Project description

Project title: ‘Implementing effective supervision over non-bank financial institutions’
Contracting Authority: Delegation of the European Union to Ukraine
Partners engaged in the project on the part of the EU: 
1) Lead Partner: 
  • Urząd Komisji Nadzoru Finansowego (Polish Financial Supervision Authority – UKNF)  
2) Junior Partners: 
  • Lietuvos bankas (Bank of Lithuania – LB) 
  • Fundación para la Internacionalización de las Administraciones Públicas, F.S.P (Foundation for the Internationalisation of Public Administrations, F.S.P. – FIAP) cooperating with Dirección General de Seguros y Fondos de Pensiones (Directorate-General for Insurance and Pension Funds, Ministry of Economy, Commerce and Business, Spain – DGSFP)

Project Beneficiary: National Bank of Ukraine (NBU) 

The project is financed by the European Union. Project budget: EUR 1 452 759.00
Project implementation period: from 1 January 2025 to 31 December 2026 (24 months)

Project objectives

The objective of this project is to support the National Bank of Ukraine in implementing risk-based supervision in accordance with EU best practices while promoting safe development and efficient services of non-bank financial institutions to secure sources of funding for the post-war recovery of Ukraine’s economy and its integration with the EU and global financial markets.

The project aims to contribute to the implementation of supervisory assessment of non-bank financial institutions in line with EU standards and to the development of economic ratios model for non-bank financial institutions in Ukraine.

Project Beneficiary: National Bank of Ukraine 

The project is implemented in collaboration with peer supervisory authorities and other competent public institutions from EU Member States: Urzad Komisji Nadzoru Finansowego (Polish Financial Supervision Authority – UKNF), Lietuvos bankas (Bank of Lithuania – LB) as well as Fundación para la Internacionalización de las Administraciones Públicas, F.S.P (Foundation for the Internationalisation of Public Administrations, F.S.P. – FIAP) and Dirección General de Seguros y Fondos de Pensiones (Directorate-General for Insurance and Pension Funds, Ministry of Economy, Commerce and Business, Spain – DGSFP).

Project scope

This two-year twinning project involves preparation and conduct of 99 short-term expert missions for the NBU, with participation of experts from supervision authorities from Poland, Lithuania, and Spain. The experts appointed for the project have the relevant knowledge and experience necessary for a given activity under the project. Due to Russia’s full-scale invasion of Ukraine, all project activities are carried out remotely.

Planned tasks include preparation of risk assessment methodologies and supervision techniques as well as training for supervisors in accordance with EU legislation and EU best practices. 

Project activities include consulting and training expert missions for the NBU, workshops for insurance undertakings in Ukraine, and study visits. The following will be prepared and delivered for use by the NBU: review reports with gap analysis and with recommended measures for adaptation to EU requirements, roadmaps, recommendations on amendments to legislation or other internal supervisory documents, guidelines, handbooks, tools and instructions, for example regarding implementation of risk-based supervision, key assumptions for legislative proposals, and workshop materials.

The project scope covers four thematic blocks (components) and the following expected results: 

A. Introduction of quantitative assessment of risks that pose a threat of capital loss, liquidity of non-bank financial institutions, and risk profile.

Component A – delivered by experts from LB and DGSFP – includes: 

support in preparing internal documents for the NBU (roadmaps and instructions) and legislative proposals introducing risk assessment methodologies; training for the NBU staff and representatives of Ukrainian insurance undertakings. The project activities are focused on supporting the NBU in implementing a new legal framework under the Solvency II Directive, and Secondary Regulation, and on increasing the capacity of the entire insurance sector in Ukraine to adapt to the new framework and to improve the regulatory and supervisory framework for credit unions and payment service providers in Ukraine.

Sub-results:

[1.1] Development of a Roadmap for quantitative assessment of risks affecting non-bank financial institutions’ performance and respective draft regulatory requirements.
[1.2] Development of a Regulation (‘target model’ of System of Risk Management (SRM)) which includes a quantitative assessment of risks and capital adequacy, risk profile.
[1.3] Development of a concept and ‘Roadmap’ for introduction of internal capital adequacy and liquidity assessment in the Ukrainian non-bank financial services market.

B. Development of risk-oriented supervision and introduction of supervisory assessment of non-bank financial institutions.

Component B – delivered by experts from UKNF and LB – includes: 

support for the NBU in developing supervisory tools (roadmap, methodologies, instructions) and regulations for the introduction of risk-based supervisory assessment for insurance undertakings, credit unions and payment service providers and support in preparing for supervisory assessment, including by providing training for NBU staff. 

Sub-results:

[2.1] Development of risk-based supervisory assessment methodologies for non-bank financial institutions.
[2.2] Development of a proposal for a Regulation on the introduction of risk-based supervisory assessment of non-bank financial institutions.

C. Development of a model of economic prudential requirements for non-bank financial groups 

Component C – delivered by experts from UKNF – includes:

support for the NBU in their efforts to improve supervisory competences concerning non-bank financial groups and regulatory  competences concerning financial benchmarks, including adaptation to EU standards, directives and regulations; and assistance in preparing a proposal for an NBU Regulation on non-bank financial groups , considering new prudential requirements, with training for NBU staff.

Sub-results:

[3.1] The composition of standards aimed at limiting risks, to which a non-bank financial institution is exposed as a result of participation in a non-bank financial group.
[3.2] Approbation of standards is carried out with the involvement of Ukrainian non-bank financial groups participants, limit values of standards are determined.
[3.3] Development of amendments to the Regulation on regulation of non-bank financial groups in order to introduce the defined standards.

D. Strengthening the NBU capacity for the implementation of the EU-Ukraine Association Agreement obligations and preparing for EU accession 

Component D – delivered by experts from UKNF – includes: 

providing training for the NBU staff in areas related to the EU accession process, including recommendations and support for the purpose of reporting on the implementation status of obligations connected with the process of Ukraine’s accession to the EU, and the strengthening of the capacity of the Ukrainian supervisor to cooperate with EIOPA, European Supervisory Authorities, central banks and international organisations in the area of non-bank finance and at international forums.

Sub-results:

[4.1] Recommendations for efficient EU accession negotiations, preparing information on the NBU’s progress regarding the EU Enlargement Package, implementation the EU-Ukraine Association Agreement obligations in the non-bank financial sphere.
[4.2] Recommendations on enhancing cooperation between the NBU and EIOPA, supervisory authorities competent for non-bank financial institutions in EU Member States/central banks and international organisations in the non-bank financial sphere and in international fora, including IAIS.
[4.3] Recommendations on the organisation of  exchange of experience and expertise system, including establishment/involvement in expert and training platforms, centres,  events for the exchange/sharing expertise and special knowledge on bilateral and multilateral basis between the NBU and. banking/non-banking financial regulators.

Project Partners

Beneficiary: National Bank of Ukraine

The National Bank of Ukraine (NBU) was established in 1991 and serves as the central bank of Ukraine. The Governor of the NBU is appointed by the Verkhovna Rada of Ukraine upon the submission by the President of Ukraine for a seven-year term.
The NBU is responsible for maintaining price stability, ensuring financial stability, developing payment infrastructure, and promoting the sustainable development of the financial system. In its capacity as a supervisory authority, the NBU performs supervision and oversight of Ukrainian banks and non-bank financial institutions and safeguards the rights and interests of consumers. In 2020, the NBU became the regulator of non-bank financial services market, which comprises insurance companies, leasing companies, factoring companies, credit unions, pawnshops, and other financial institutions, except for the securities market.
Within the process of the EU accession, the NBU works on aligning national financial legislation with the EU acquis. 

Implementing Institutions

Lead Partner - Urząd Komisji Nadzoru Finansowego 

Urząd Komisji Nadzoru Finansowego (UKNF) has operated since September 2006, and in January 2008 it became a fully integrated authority responsible for all sectors of the financial market in Poland The Chair of Komisja Nadzoru Finansowego (KNF) is appointed by the Prime Minister for a 5-year term. The KNF exercises financial market supervision, including bank supervision, capital market supervision, insurance supervision, pension supervision, supplementary supervision of financial conglomerates, supervision of electronic money institutions, payment institutions and payment service offices, as well as supervision of credit unions. Ongoing supervisory activities are performed by the UKNF under the leadership of the Chair of the KNF. The purpose of supervision of the financial market is to ensure its proper functioning, stability, security and transparency, confidence in the financial market, and to ensure that the interests of the market participants are protected.

Junior Partners 

Lietuvos bankas (Bank of Lithuania)
Lietuvos bankas was established in 1922 and serves as the central bank of the Republic of Lithuania. The Chair of the Board of Lietuvos bankas is appointed by the Parliament of the Republic of Lithuania upon nomination by the President of the Republic of Lithuania for a five-year term.
As a member of the Eurosystem, Lietuvos bankas contributes to the implementation of the single monetary policy of the euro area and performs functions related to financial stability and macroprudential policy. Since 2012, LB has been the single supervisory authority for all financial markets and institutions in Lithuania, supervising credit institutions, insurance and securities, payment and electronic money institutions, and other financial institutions operating in Lithuania, and investigating the disputes between consumers and financial institutions.

DGSFP – Dirección General de Seguros y Fondos de Pensiones (Directorate General for Insurance and Pension Funds, Ministry of Economy, Commerce and Business, Spain)
The Directorate General of Insurance and Pension Funds, DGSFP, was created in 1928, however, the Insurance Inspectors began performing supervisory tasks in 1908, so Spain has more than 115 years of experience supervising insurance sector. The supervisor function relies on the Insurance Inspectors, who have that function assigned by law, according to article 123 of the Spanish Law 20/2015, of 14 July, on the management, supervision and solvency of insurers and reinsurers. Insurance Inspector is the highest grade (grade A1) within the DGSFP and inside the Spanish Civil Servants. All the management positions inside DGSFP, including the Director, are covered by Insurance Inspectors. The DGFSP is the Spanish government financial regulatory agency which supervises and controls Spain's Insurance and pension fund sector. 
It is responsible for ensuring that the insurance sector works properly, providing appropriate protection to policyholders and members of pension funds. To that end, it is empowered to regulate, issue mandatory criteria to be complied by insurance undertakings and groups to guarantee the proper operation of the whole insurance market in accordance with current legislation (under SII framework).
It is part of the Spanish Secretary of State of Economy & Business Support of the Ministry of Economy, Trade and Business of Spain.

FIAP– Fundación para la Internacionalización de las Administraciones Públicas, F.S.P  (Foundation for the Internationalisation of Public Administrations, F.S.P. – FIAP)
Part of Ministry of Foreign Affairs, European Union and Cooperation, Spain
The Foundation for the Internationalisation of Public Administrations (FIAP) is a Spanish public sector foundation attached to the Ministry of Foreign Affairs, European Union and Cooperation. FIAP supports the international projection of Spanish public institutions through institutional cooperation and technical assistance programmes worldwide.
FIAP works by mobilising Spanish public expertise —ministries, regulatory bodies, supervisory authorities and other public entities— to strengthen public policies and institutions in partner countries. It designs and manages EU-funded cooperation projects, including Twinning and other instruments, contributing to institutional reform, governance improvement and alignment with EU standards.
As an implementing entity of Spain’s international cooperation system, FIAP ensures that projects are delivered in accordance with principles of public integrity, accountability and results-based management. Its role is to connect peer public administrations, facilitating knowledge transfer and sustainable institutional development.
FIAP forms part of Spain’s external action framework and operates in close coordination with the Ministry of Foreign Affairs, European Union and Cooperation, contributing to the strengthening of democratic institutions, public sector modernisation and international partnerships.
Twinning is an EU instrument of institutional cooperation between public administrations in EU Member States and beneficiary countries and/or partner countries. A twinning project consists in combining the experience and expertise of public sector institutions in EU Member States and beneficiary countries to achieve concrete results as part of jointly agreed project activities.

News [What’s new]

Summary of project implementation in 2025 

The project activities started in April 2025 and are now being implemented by experts from the Directorate-General for Insurance and Pension Funds, Ministry of Economy, Commerce and Business (Spain), the Polish Financial Supervision Authority, and the Bank of Lithuania, in cooperation with the National Bank of Ukraine.

46 out of 99 missions planned for the entire project period (46%) were completed by the end of 2025 as part of three out of four components (A, B, and D). 

The scope of expert missions in Components A and B focused on supporting the NBU in adapting the supervisory practice and regulations in relation to insurance undertakings, payment service providers and credit unions, and in Component D – on performing the obligations related to the EU accession process and active collaboration between the NBU on the one part and international organisation and third parties on the other part, in the field of non-bank finance.

All project activities were completed in accordance with the project work plan, including preparation, by experts from Spain, Lithuania and Poland, of required documents for further use by the NBU. 

The outputs were adapted to the NBU’s expectations and they are applied in the adaptation of the Ukrainian supervisory practice to the EU rules and standards, and in gradual harmonisation of rules with the acquis communautaire.

The period from April to December 2025 resulted in successful completion of the following expert missions, with measurable outcomes for use by the NBU. 

In Component A, Spanish and Lithuanian experts successfully finalised 37 expert missions in cooperation with the Ukrainian financial supervisor in order to enhance the NBU’s activities for the improvement of the regulatory and supervisory framework for the non-bank financial services market in the following areas:

1. In the segment of payment service providers, experts from the LB delivered a complete package of outputs to support the Ukrainian financial supervisor during 11 expert missions aimed at meeting result indicators for sub-results 1.1, 1.2 and 1.3*.

*In terms of supporting the NBU in developing internal documents and methodologies, adjusting regulatory requirements, and supporting activities for the introduction of quantitative assessment of risks and capital adequacy.

2. In the segment of insurance undertakings: 

a) all delivered outputs were completed by experts from the Spanish supervisory authority to meet result indicators for sub-results 1.1 and 1.2* as part of 22 missions (14 for the staff of the NBU and 8 for representatives of Ukrainian insurance undertakings, including a study visit of the NBU to Madrid to recapitulate DGSFP support);

*In terms of supporting the NBU in developing internal documents and methodologies, and adjusting regulatory requirements on the quantitative assessment of risks and capital adequacy.

b) experts from the LB launched first activities for the NBU as part of sub-result 1.3*.

*To support the NBU’s activities for the introduction of quantitative assessment of risks and capital adequacy.

3. In the segment of credit unions, experts from the LB launched first activities aimed at supporting the achievement of results for sub-result 1.1*. 

*In terms of supporting the NBU in developing internal documents and adjusting regulatory requirements.

The missions of DGSFP experts in the area of insurance undertakings focused on regulatory aspects, supervisory practice and techniques, and the roadmap for regulatory aspects taking into account supervisory practice and techniques. 

The missions of LB experts in the area of payment service providers and credit unions concluded with reports on the review of regulatory gaps and with tailored recommendations for the NBU. 

In Component B, UKNF experts delivered support as part of five expert missions in the segment of insurance undertakings aimed at supporting the NBU in meeting indicators for sub-results 2.1 and 2.2 in risk-based supervision, developing supervisory tools and methodologies, and introducing risk-based supervisory assessment. Delivered outputs included mainly handbooks, supervisory procedures, and templates for supervisory purposes.

In Component D, UKNF experts conducted four cross-sectoral expert missions oriented towards enhancing the NBU’s capacity to perform the obligations related to EU accession and to actively cooperate with IAIS, OECD and other international organisation in the field of non-bank finance and at international forums. Polish experts shared multiple insights into supervisory practices, handbooks, procedures and tools, as well as related recommendations. 

With the expert support received, the NBU continues the review and further work to develop or adjust the regulatory framework for the supervision of insurance undertakings, credit unions and payment service providers. 

In addition to the project activities described above:

  • A virtual kick-off meeting was held on 14 May 2025 with high-level representatives of public administration and diplomatic services from Ukraine, Poland, Lithuania, and Spain, as well as representatives of Ukrainian insurance undertakings, credit unions, non-bank payment service providers, professional associations, media, and market. The purpose of the meeting was to present the overall objectives of the support financed from EU funds to all the stakeholders involved in the project, the media, and the general public (more details here). 
  • The Delegation of the European Union to Ukraine communicated its full approval of the first three interim reports on project implementation in 2025 (for Q1–Q2, Q3 and Q4 2025, respectively). 

Contact persons 

Polish Financial Supervision Authority
Joanna Lipowczan, Project Manager, International Cooperation Department 
e-mail: joanna.lipowczan@knf.gov.pl 
Marta Bartnik-Wójcik, Resident Twinning Adviser
e-mail: marta.bartnik-wojcik@knf.gov.pl 

National Bank of Ukraine
Tetiana Tytarchuk, Resident Twinning Adviser Counterpart
e-mail: Tetiana.Tytarchuk@bank.gov.ua, +380 50 4104131  
Svitlana Zarazhevska, National Bank of Ukraine Press office 
e-mail: Svitlana.Zarazhevska@bank.gov.ua, +380 97 886 43 63

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This website was created and is maintained with the financial support of the European Union. Its contents are the sole responsibility of Urząd Komisji Nadzoru Finansowego (Polish Financial Supervision Authority – UKNF) and do not necessarily reflect the views of the European Union.

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