Interchange caps and timing: what the EU requires, and what Ukraine decides for itself

The National Bank of Ukraine has drafted a bill that would bring interchange caps in line with Regulation (EU) 2015/751: an interim level of 0.5% in 2027, then 0.2% for debit cards and 0.3% for credit cards from 1 January 2028. The thing that matters for PSPs is not whether those numbers exist — they do in the EU already — but when Ukraine chooses to apply them, and how much damage it does to card economics on the way.

1. The current proposal is still just that: a proposal. The Cabinet of Ministers is preparing to submit it to parliament, so the text has not yet been registered in the chamber. At this stage, comments on the draft are part of government preparation, not some grand conspiracy against European integration.
2. The debate has been framed as if the argument is over the rates themselves: 0.2% and 0.3% versus 0.678%. That framing is wrong. The EU rates are not the real question here; the real question is the start date. If Ukraine rushes, it may end up repeating the European experience with its side effects, only without the luxury of seeing them in advance.
3. According to the National Bank’s data for Q1 2026, Ukraine’s average interchange rate is 0.678%, while the average merchant discount rate (MDR) is 1.248%. These are figures from the Banking Sector Review, not market estimates. For comparison, the weighted average interchange rate in Europe on the eve of the Regulation’s launch was about 0.65%, so Ukraine is roughly where the EU was when it started regulating in 2015.
4. This is not just a market snapshot; it is a reminder of how the current structure was built. The present interchange level was agreed by the National Bank, banks, and payment systems in summer 2022, as a compromise under full-scale invasion. In other words, the market has already moved part of the way toward the European model voluntarily, and it did so in the worst possible circumstances.
5. By the end of Q1 2026, Ukraine had 61.4 million active payment cards, and 96 out of 100 card transactions were cashless. That is ahead of most EU countries. The infrastructure behind that usage was not financed by the state budget or grants, but by issuer revenue, with interchange as a key line item. For issuers, acquirers, and PSPs, this is the bit that matters: caps do not land on a blank sheet of paper, they land on a system that is still being paid for.

Regulation 2015/751 is part of the EU acquis, meaning it becomes mandatory for member states automatically once they join. Ukraine’s eventual obligation is not in doubt; the open question is whether the country is obliged to apply the caps before accession. That timing question is where the commercial consequences sit for card issuers, acquirers, and high-risk merchants that rely on interchange-funded issuing economics.