The National Bank of Ukraine has updated its approaches to corporate governance in the banking sector, focusing on sustainable development, social responsibility and ESG risk management. The relevant changes were approved by the Resolution of the NBU Board “On Approval of Amendments to the Methodological Recommendations on the Organization of Corporate Governance in Ukrainian Banks” dated February 3, 2026 No. 31. We described what ESG is in the analytical article “What is ESG: Definition, Context, Relevance”.
Key Changes and Deadlines
The regulator recommended that banks develop, finalize and implement internal documents on sustainable development by July 31, 2026.
The updated recommendations introduce the concept of “responsible business conduct” into the activities of banks. This is a comprehensive process that involves achieving sustainable development goals and minimizing negative impacts on the environment and human rights. From now on, the bank’s strategy must be based on the principles of economic, environmental, social and managerial responsibility.
New standards and the fight against “greenwashing”
The document significantly expands the terminology that financial institutions must operate with. In particular, the concept of “green camouflage” (greenwashing) is introduced – misleading clients or investors through a false reflection of sustainable development goals in bank products or statements.
According to the new Chapter XVI “Sustainable Development of the Bank”, financial institutions must organize their activities, adhering to four key principles:
Economic responsibility: long-term sustainability and financing of priority industries.
Environmental responsibility: reducing greenhouse gas emissions, waste management and “green” financing.
Social responsibility: respect for human rights, inclusion, reintegration of veterans and barrier-free services.
Management responsibility: transparent reporting, fair competition and integrity.
Priorities of wartime and reconstruction
The NBU emphasizes that during martial law and post-war reconstruction, the concept of sustainable development adapts to the realities of the country. Supporting defense capability and energy sustainability plays a key role. The priority is set to finance:
the defense-industrial complex;
critical infrastructure and energy;
business restoration in deoccupied territories;
projects to eliminate the consequences of ecocide.
Working with clients
Banks are required to implement procedures for assessing the ESG risks of their clients. This includes developing a typical ESG client profile and special questionnaires for verification. Financial institutions will check counterparties for the presence of “green camouflage” practices, and if necessary, conduct visits to the client’s place of business for additional analysis.
The decision entered into force on the day following the day of its adoption.
