On 18 March 2025, the National Bank of Ukraine (NBU) enacted Resolution No. 32 "On Establishing Criteria for Determining Enterprises, Institutions, Organisations that are Important for the National Economy in the Field of Insurance." This Resolution, adopted alongside the Law of Ukraine "On Insurance" No. 1909-IX, forms part of a broader regulatory overhaul aimed at modernising Ukraine's insurance sector and aligning its legal framework with EU standards —particularly with Solvency II and the Insurance Distribution Directive (Directive 2009/138/EC and Directive (EU) 2016/97, respectively).
Criteria for Determination of Economic Significance
Insurers must satisfy all the following conditions:
- the insurer must comply with the capital adequacy norms as defined in the Regulation on Establishing Requirements for Ensuring Solvency and Investment Activities of an Insurer, approved by Resolution No. 201 of the NBU Board, dated 29 December 2023 (as amended). Alternatively, where applicable under Articles 117 or 118 of the Law on Insurance, an insurer may be considered compliant if it adheres to a recovery or financing plan that has been formally approved by the NBU, based on its most recent reporting in accordance with Resolution No. 123 (25 November 2021).
- the company's ownership structure must be formally recognised as transparent by the NBU. This determination is made under the Regulation on Requirements for the Ownership Structure of Financial Service Providers, as approved by NBU Resolution No. 30, dated 14 April 2021. Transparency of ownership is critical in ensuring regulatory clarity, accountability, and investor confidence.
- the insurer must be categorised as Group 1 in terms of social importance, based on the annual assessment carried out by the NBU. This is undertaken under the Regulation on Establishing Criteria for Determining the Risk Profile of Financial Service Providers, Their Social Importance, and Supervisory Actions of the NBU, as adopted in Resolution No. 143 of 8 November 2023.
The implementation of Resolution No. 32 has several practical implications for market participants:
- stronger risk management
- investor and consumer confidence
- support for key market players
Conclusion. The basis for determining a company's significance for the economy is its compliance with all three criteria listed above. These law developments will have lasting effects on regulatory oversight, capital markets integration, and the attractiveness of Ukraine's insurance sector to both domestic and foreign investors.
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