In a column for PSM, Oleksandr Karpov, Director of the EMA Association and founder of Open API Group, analyzes what Ukraine must do regarding interchange fees within the framework of European integration, what decisions remain within its purview, and what consequences haste might lead to.
Photo: chatgpt.com
The National Bank has drafted a bill introducing caps on interbank commission rates in line with Regulation (EU) 2015/751. An intermediate level of 0.5% is set for 2027, and target rates of 0.2% for debit cards and 0.3% for credit cards are to take effect from January 1, 2028. The Cabinet of Ministers is preparing to submit the document to parliament.
This means the text is not yet in the legislative chamber. As long as the draft is not registered, comments on it are a normal part of preparing a government decision, not an attempt to block the bill.
The public discussion around the document is framed as if the dispute is about a number: one side cites 0.2% and 0.3%, the other 0.678%. Within this framework, anyone questioning the draft is positioned as hindering European integration.
The framework is incorrect. The 0.2% and 0.3% rates are in effect in the EU and will be in Ukraine – this is not a point of contention. The subject of discussion is the effective date. The answer determines whether Ukraine will repeat the European experience with its side effects, or whether it will tread the same path with these effects clearly visible in advance.
The Point We Are At
According to the National Bank’s data for the first quarter of 2026, the average interbank commission rate in Ukraine is 0.678%, and the average acquiring fee (MDR) is 1.248%. These are figures from the Banking Sector Review, not market participant assessments.
For comparison, the weighted average interchange rate in Europe on the eve of the Regulation’s launch was around 0.65%. Ukraine is currently at approximately the same point from which the EU began regulation in 2015.
This is not inertia. The current rate was agreed upon by the National Bank, banks, and payment systems in the summer of 2022 – a compromise decision amidst full-scale invasion. The market has already covered part of the path towards the European model, voluntarily and under the worst circumstances.
As of the end of the first quarter of 2026, there are 61.4 million active payment cards in Ukraine, and 96 out of 100 card transactions are cashless: by this metric, Ukraine surpasses most EU countries. This infrastructure was not financed by the budget or grants but by issuer revenues, where interchange is a key component.
This is not an argument against reform but a description of the starting point: in 2015, the EU launched regulation where infrastructure had been built for decades. Here, it is still being built.
Read also: Interchange Fee Regulation in Europe: What Central Bank Data Shows
What Exactly Ukraine Is Obligated to Do
The Regulation is part of the acquis communautaire, the body of EU law binding on every Member State. Upon Ukraine’s accession, it will apply automatically; there are no doubts, and the EMA does not dispute this. The question is different: is there an obligation to implement the caps before accession?
The answer requires precision, as this is where the discussion most often falters.
Regulation 2015/751 is indeed mentioned in benchmark 4.2 for closing Chapter 4 “Free movement of capital” – on this basis, the National Bank builds its position. However, the benchmark requires implementation of the Regulation, not the introduction of caps before accession. This is not wordplay: nine out of twenty key provisions of the Regulation are tied to the EU internal market – cross-border acquiring, territorial scope, competent authority, sanctions, out-of-court complaint resolution – and cannot function outside of membership. The European Commission, which drafted this Regulation, cannot be unaware of this.
As for specific dates, they are not in the benchmark. The list of measures in the National Program under Chapter 4 formulates the obligation as follows: entry into force of legislative amendments regarding the timing of setting maximum rates at a level not exceeding 0.2-0.3%, with a deadline of December 2027. The subject of the measure is the law, not the rate.
The schedule of 0.5% from January 1, 2027, and 0.2%/0.3% from January 1, 2028, is contained in Ukraine’s negotiation position, approved by Cabinet of Ministers Resolution No. 534-r of May 30, 2025, and in the draft law developed by the National Bank.
The direct consequence is that the date of introduction of target rates is a decision Ukraine makes itself. A law in effect in 2027, which sets 0.5% from July 1, 2028, and target rates from the date of accession, fully fulfills the National Program measure: the timelines are regulated within it.
Moldova: A Case Misquoted
Moldova is mentioned as an example of a candidate country that has already lowered interchange fees: implying that we should do the same now. The facts are different. In 2023, the National Bank of Moldova adopted a phased reduction of fees from 1.6% for debit and 2.5% for credit cards to 0.5-0.6% over two years in three stages. This leads to two conclusions, neither of which supports this argument.
First. The 0.5-0.6% level is twice to three times higher than the Regulation’s caps. Moldova has not implemented it; it took an administrative step by a central bank decision. The rest of the path will be taken upon actual EU accession – European law is transposed during the accession phase, not during candidacy.
Second. Ukraine’s current rate of 0.678% is lower than Moldova’s target. Moldova moved from 1.6%, while Ukraine already stands at 0.678%. This is not the same step or scale.
When read correctly, the Moldovan case works in the opposite direction to how it is used. And it is not unique: out of more than sixteen jurisdictions that have introduced interbank commission regulation, none have done so simultaneously.
Poland lowered interchange fees over three years before reaching European levels. Croatia received a two-year transition period after joining the EU. Israel stretched the reduction over six years, Malaysia over five. The EU itself implemented the Regulation over five years – in peacetime and with developed card infrastructure.
The reason for this unanimity is not lobbyist pressure. A sharp reduction in one component of acceptance costs yields a predictable market reaction: revenue is redistributed, not eliminated. European data records several channels – new fees for merchants, monthly fees for individuals, an increase in unregulated payment system fees, higher cross-border tariffs – and records them in every jurisdiction with interchange regulation.
Interesting on the topic: Ten Years of IFR: What Was Measured, and What Wasn’t
The Queue Interchange Is In
European integration of the payment market is not a single obligation but a package. DORA applies in the EU from January 17, 2025. MiCA was phased in from 2024, with the transitional period closing on July 1, 2026. The Instant Payments Regulation (EU) 2024/886 has changed the economics of European transfers. SEPA: Moldova joined in October 2025; in Ukraine, draft law No. 14327-d was registered in April 2026. Ahead are Verification of Payee and updated open banking requirements under PSD3/PSR: negotiations on this package concluded at the end of 2025, with application expected in 2027-2028. The bar Ukraine must reach will rise again during this time.
Each element has its own resource budget – development, testing, certification, personnel – and all are funded from the same sources as card infrastructure. Hence the question, for which there is no answer yet: why should the element of the package that reduces the resource base for the rest be introduced first? Especially if it is an element whose effectiveness European institutions have failed to confirm over ten years: the European Court of Auditors’ Special Report 01/2025 states that existing studies do not demonstrate positive effects of limiting interbank commissions.
The Formula
Let’s return to the draft schedule: 0.5% for 2027, then 0.2% and 0.3% from January 1, 2028. With an actual weighted average rate of 0.678%, the intermediate stage is effectively non-existent – the entire reduction occurs simultaneously.
EMA proposes a different structure – not a different end point, but a different moment of achieving it.
From July 1, 2028 – a cap of 0.5%. This is a move towards the European model by our own decision, not under external pressure, and the same point Moldova was moving towards.
From the date of Ukraine’s full membership in the European Union – in accordance with the accession treaty, the caps of 0.2% for debit and 0.3% for credit cards will automatically apply, in the version of the regulation that is in effect at that time.
The latter clarification is not technical. The Regulation is under criticism from the EU’s own auditor, and linking it to the accession date means Ukraine will apply the version of the rule that is in effect then. Furthermore, the date does not require forecasting – there is no need to guess the year of accession and rewrite the law if the schedule shifts.
Read also: How Sense Bank Ended Up in the “Forest Gump” Case and Why Pyshnyi Was Summoned to the Rada
Who Pays for the Party
The discussion about interchange is almost always held between two sides – merchants and banks. But neither of them is the one whose bill is settled in the end.
Interbank commission is not a profit that remains. It is a revenue base that finances the issuing part of the system: free account and card maintenance, free transfers, cashback, anti-fraud measures, 24/7 support. When this base is administratively reduced, the costs do not disappear – they change the payer.
European chronology leaves no room for speculation. Until December 2015, a free basic account was standard in most EU countries. As of 2025-2026, a monthly account fee for individuals has become the norm in 85% of EU countries, ranging from €2-6: Deutsche Bank raised its basic account to €6.90, ING Belgium from free to €3.95.
The most comprehensive picture is provided by a 2012 Spanish study, which tracked the full five-year cycle of interchange fee reductions in its market. Over these years, the average annual fee for credit cards increased by 50%, and for debit cards by 56%; banks lost €3.3 billion in revenue and fully compensated for the loss. The authors’ conclusion is direct: the reduction in commissions harmed the consumer.
The American experience adds observational length. A year after the Durbin Amendment, debit card rewards at regulated banks fell by 60%, 90% of large US banks canceled these programs entirely, and between 2009 and 2011, the number of unbanked households increased by one million. A 2023 study on the distribution of these effects among consumer groups in the US and Canada adds another perspective: even the portion of savings that merchants passed on in prices was regressively distributed – wealthy credit card holders with cashback benefited, while those paying with cash and debit cards bore the costs.
In Ukraine, we are talking about 61.4 million active cards, meaning practically every adult Ukrainian for whom a free card and account are the norm. Ukraine’s model of free retail banking is one of the most accessible in Europe, and it is sustained by the revenue base that is proposed to be reduced. This is not a prediction but a description of what has already happened in every jurisdiction that has gone down this path before.
Read also: Eurointegration, Open Banking, and New Fraud Schemes: Key Challenges for the Financial Market – Interview with Oleksandr Karpov
Who Benefits
If consumers do not benefit from the reform, and merchants, according to European data, benefit little – where does the difference go? The answer is provided by a distributional analysis of the American reform. According to the Progressive Policy Institute (December 2025), 72.5% of all savings from interchange fee reductions went to retailers with annual turnovers exceeding $100 million – less than one percent of merchants. The ten largest US chains took 30% of the total savings. Small and medium-sized businesses, for whose sake the reform was declared, received a share that the authors call negligible.
The mechanism is structural: a large chain has bargaining power and ensures that the reduction in the wholesale rate is reflected in its contract with the acquirer, while SMEs operate on a bundled tariff.
Next is the second link. Let’s calculate in hryvnias.
Suppose, after the rate reduction, the merchant’s bank saves one hryvnia per transaction. Of this hryvnia, approximately 30-35 kopecks reach the merchant themselves – the rest settles in those components of the acquiring cost that are not affected by regulation. And this is not a pessimistic estimate: a calculation for a European Commission order in 2020 promised twice as much – until the European Court of Auditors pointed out that it was based on data from the first two years when the market had not yet restructured.
Now, these 30-35 kopecks are supposed to translate into lower prices in stores. This is where the chain breaks. A year after the American reform, merchants were surveyed: 1.2% lowered prices, 21.6% raised them, 77.2% changed nothing. Academic estimates show the same – a change in price from zero to 0.17%.
Multiply these two links, and it becomes clear why consumer benefit has not been measured by any study.
This is not a position “against merchants”: tariff transparency is needed by SMEs no less than by banks. This is a position that a structure that redistributes resources from the owners of 61.4 million cards to a few hundred of the largest chains and does not provide measurable benefit requires stronger justification than a reference to European precedent.
What Should Be Done Before the Rates
The deadline itself solves nothing – it must be filled with substance.
Transparency is the first, and it is needed now. The acquirer’s obligation to disclose the components of the commission separately (Article 9 of the Regulation, unblending) does not require a transitional period and has no documented side effects in any of the studied jurisdictions. This is a rare instance of a rule that benefits everyone: SMEs see the structure of their tariff for the first time, the issuing bank receives protection from the argument of “inflated interchange,” and the regulator gets data. EMA supports this block unconditionally.
Full transposition is the second. The Regulation is a package of four parts: price, competition, transparency, and enforcement. EMA has matched the draft against it point by point: out of twenty key positions, nine are not transposed at all, five with deviations, and six in compliance. Among these six are precisely those that reduce revenue. Cross-border acquiring, separation of scheme and processing, card brand choice, merchant notification for each transaction, supervisory authority, sanctions, and out-of-court complaint resolution – i.e., the rules that were supposed to ensure the reduction reached further down the chain – are not transposed.
At the same time, the draft regulates more broadly than the Regulation where the EU made express exceptions: Article 1(3) exempts corporate cards, cash withdrawals at ATMs and branches, and three-party schemes from the caps, Article 1(1) limits the scope to operations where both banks are from EU countries. The draft contains none of these restrictions. Most notably, ATMs: withdrawing UAH 2,000 at a rate of 0.2% yields 4 hryvnias for the device, electricity, communication, cash-in-transit, and security.
Assessment of consequences for account holders is the third. European experience shows that a reduction in the issuer’s revenue base converts into monthly fees within one to four years. This is not a reason to demand compensation – it is a reason to calculate what will happen to 61.4 million cards before a decision is made, not after the first tariffs appear. There is no such calculation in the draft materials. Public consultations with the market were also not conducted – based on the assumption that the document supposedly does not require the procedure for regulatory acts. A draft that changes the terms of service for every card in the country does not fall under such an interpretation.
Full impact assessment is the fourth. The European Court of Auditors pointed out the lack of evidence base when adopting the Regulation and the inability to demonstrate effects post-factum. Ukraine can conduct this assessment before a decision, with a decade of foreign data before its eyes – and measure the full cost of acceptance, not just one of its components.
What the Discussion Is Really About
The argument “this is an EU requirement, not subject to discussion” closes the discussion without considering the substance – and does not hold up to scrutiny. There is a choice of timing that Ukraine makes itself.
EMA’s position is not to avoid action but to act sequentially to achieve results: first transparency and full transposition of the Regulation, then data, then rates – when Ukraine becomes a member state and applies European law in its entirety, not selectively and prematurely.
The date is more important than the rate – and this is not wordplay. The same figure means different things depending on when it appears. Introduced in a market that already has tariff transparency, a supervisory authority, sanctions for circumvention, and access to the EU internal market, it redistributes income within a mature system – much as the Regulation’s authors intended. Introduced today, without these mechanisms and without assessing the consequences, it simply extracts resources from a system that is still under construction. The figure is the same. The result is not.
Sources:
- Regulation (EU) 2015/751 (IFR);
- ECA Special Report 01/2025;
- Hausemer et al. (2024), DG COMP;
- Regulation (EU) 2024/886 (Instant Payments);
- Iranzo J., Fernández P., Matías G., Delgado M. (2012), MPRA Paper 43097;
- Shapiro R. J., Davis J. (2025), Progressive Policy Institute;
- Board of Governors of the Federal Reserve System, Reg II interchange;
- NBU, Banking Sector Review (May 2026) – interchange 0.678%, MDR 1.248%;
- CMU Resolution No. 438 dated 01.04.2026 (National Program for Adaptation to the EU Acquis).
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