Of course, here is an analysis of the provided legislative act:
1. **Essence of the Law:** Resolution No. 64 dated June 13, 2025, adopted by the Board of the National Bank of Ukraine, establishes requirements for the regulatory capital of non-bank payment service providers. It defines the procedure for calculating, the components of regulatory capital, as well as the procedure for attracting subordinated debt and obtaining permission for its inclusion in regulatory capital. This is necessary to ensure the financial stability and reliability of these institutions.
2. **Structure and Main Provisions:**
* The law consists of several sections that regulate general provisions, the calculation of regulatory capital, capital adequacy ratios, and the procedure for attracting subordinated debt.
* It defines how to calculate Tier 1 and Tier 2 capital, which assets and liabilities are included or excluded from the calculation.
* Minimum regulatory capital and regulatory capital adequacy ratios are established.
* The law also amends the Regulation on the Authorization of Financial Service Providers, in particular, the requirements for the inclusion of subordinated debt in regulatory capital are clarified.
* Compared to previous versions, this act repeals previous resolutions that regulated prudential ratios for non-bank payment service providers and introduces new requirements based on the Law of Ukraine “On Payment Services.”
3. **Key Provisions for Use:**
* Non-bank payment service providers must comply with regulatory capital requirements daily and calculate its amount based on accounting data.
* In case of violation of regulatory capital requirements, the institution is obliged to notify the NBU within three business days.
* Payment institutions must bring their regulatory capital into compliance with the requirements of the Regulation by December 31, 2025, taking into account the average monthly volume of payment transactions for 2024.
* Attracting subordinated debt is possible subject to obtaining permission from the NBU, and its inclusion in Tier 2 capital has certain restrictions and a reduction schedule.
