Loans and microloans for military personnel in 2026: what is not charged, what is written off, and how to apply

Conscripts, reservists and military personnel taking part in national defence operations, as well as their spouses, are exempt from interest, fines and late payment charges on loans for the duration of their service (paragraph 15 of Article 14 of the Law ‘On the Social and Legal Protection of Military Personnel’). This exemption does not apply automatically — an application accompanied by supporting documents must be submitted to the lender. A repayment holiday does not write off the principal debt; full write-off is provided for loans taken out by deceased defenders and persons with Group I–II disabilities resulting from the war.

Repayment holidays for military personnel — a benefit that everyone has heard of, but which, in practice, fails in two respects: banks do not apply it until they receive an application with supporting documents, whilst microfinance organisations (MFOs) often ignore the application altogether, continuing to ‘rack up’ interest under the guise of fees. The result is that a conscript returns from service to face a debt that, by law, should not exist, and which has to be written off retrospectively.

Let’s look at who is entitled to this concession, how to apply for it without falling into traps, what to do about interest already unlawfully charged, and in which cases the debt is written off in full. Personal support – on the page of a solicitor specialising in loans and microloans.

Who is eligible for a repayment holiday

Under paragraph 15 of Article 14 of Law No. 2011-XII, the following are eligible:

• those mobilised — from the first day of conscription;
• reservists called up during a state of emergency;
• other military personnel taking part in activities to ensure the defence of the state — from the first day of such participation; even a single day’s participation in combat operations or defence activities is sufficient, and the benefit is retained for the remainder of their service;
• spouses of male and female defenders — in respect of their own loans.

Who is not covered by the benefit: contract soldiers who serve exclusively in the rear (headquarters, training centres, depots) and have not been involved in combat or defence operations — for them, interest is accrued as normal. This is the most common point of dispute with banks, and it is resolved by a certificate confirming participation in defence operations.

What exactly is ‘frozen’ and what is not

Components	For the duration of service
Interest on the loan	Not charged
Penalties and late payment charges	Not charged
Principal amount of the loan	Not written off — the obligation to repay remains
Mortgage interest	As a general rule, this is charged (certain exemptions apply to residents of occupied territories and owners of destroyed homes)
Car loan insurance premiums	These are payable — the exemption applies only to interest

The scope of the provision is broader than is commonly thought: it covers obligations not only to banks, but also to MFIs, enterprises, institutions, organisations of all forms of ownership and even to private individuals. Claims by MFIs that ‘We are not a bank; the law does not apply to us’ are manipulative.

How to apply: application + supporting documents

1. Gather proof of status: a certificate of mobilisation or military service, and for contract soldiers — a certificate of participation in defence operations; for married couples — additionally, a marriage certificate.
2. Submit a written application to each creditor requesting the application of paragraph 15 of Article 14 of Law No. 2011-XII, together with copies of the supporting documents — via a branch with a receipt stamp, by registered post, or via the bank’s official electronic channels. The application may be submitted by the serviceman themselves, their spouse, or a representative acting under a power of attorney.
3. Record the date of submission: the concession applies from the first day of service or participation in defence activities, but without an application, the bank will not be aware of your status — and the sooner you submit it, the less you will have to repay.
4. Check your statements every month: if charges are still being applied, submit a written request for a recalculation, followed by a complaint to the NBU and, if necessary, legal action.

If a bank or MFI continues to charge interest: how to get a refund

Any interest charged in contravention of the exemption constitutes funds received without legal basis and is subject to repayment in accordance with the rules on unjust enrichment (Article 1212 of the Civil Code). The procedure: reconciliation of accounts, a written demand for recalculation and repayment (or set-off against the principal debt), a complaint to the NBU against the creditor, and legal action — if the matter is not rectified voluntarily. A separate issue concerns MFOs that disguise interest as ‘service charges’: this involves a link to the limits on charges, which we discussed in the article on recalculating debt owed to MFOs, and if the lender has already taken the matter to court — the procedure outlined in the article on setting aside a court order.

When the debt is written off in full

A repayment holiday is a pause, not a write-off. The law provides for the full write-off of consumer loan obligations for certain categories: in the event of the death of a serviceman or servicewoman, or where a person is assessed as having a Group I or II disability as a result of the war. Write-off is not automatic either: the heirs or the borrower themselves must submit an application to the lender, accompanied by supporting documents. If a loan taken out by a deceased serviceman or servicewoman is included in the estate, do not continue to pay it ‘out of habit’: first, exercise your right to have it written off.

Common mistakes

• Expecting the bank to apply the concession automatically. It won’t: without an application, it won’t be aware of your status, and sorting it out later takes longer than submitting an application straight away.
• Submitting an application only to the ‘main’ bank. The relief must be applied for separately with each creditor — including microfinance organisations.
• Agreeing to ‘restructuring’ instead of a payment holiday. Restructuring with interest payments is a worse deal than the legal exemption from interest altogether.
• Failing to keep proof of your application. Without a receipt or tracking number, the bank will claim it ‘was not received’, and you will lose any dispute over the start date of the relief.
• Ignoring statements whilst on duty. It is cheaper to stop unlawful charges in the second month than to recoup them over two years.

When a solicitor is not needed

If there is only one creditor, your status is confirmed by a standard certificate, and the bank has correctly stopped the charges following your application — there is no need to involve a solicitor. A solicitor is required when the bank refuses to accommodate a contract soldier despite a certificate of military service, when a microfinance organisation ignores the application, when charges that have already been accrued need to be recovered through the courts, and when it comes to writing off the loans of a deceased person in an inheritance case.

Questions and Answers

Does military service exempt you from paying the loan in full?

No. No interest, fines or penalties are charged during the period of service, but the principal amount of the loan remains and must be repaid after service ends. Full write-off applies only in the event of the defender’s death or disability of Groups I–II resulting from the war.

Do payment holidays apply automatically from the day of mobilisation?

The entitlement arises from the first day of service, but the lender will only apply it once you have submitted an application with the relevant documents. Submit your application as soon as possible and keep proof of submission — a recalculation for past months is possible, but requires a separate procedure.

I am a contract soldier in a support unit. Am I entitled to a payment holiday?

If you have not been involved in combat operations or defence operations — no, interest will continue to accrue. If you have taken part for at least one day — yes, from the first day of participation; this must be confirmed by a certificate from your unit.

Does this exemption apply to a serviceman’s spouse?

Yes, the spouses of servicemen are entitled to a waiver of interest, fines and penalties on their own loans. A marriage certificate and service records must be attached to the application.

Does the repayment holiday apply to microloans from MFOs?

Yes, the rule covers obligations to institutions of all forms of ownership, including MFOs. In practice, MFOs most often circumvent the exemption by disguising interest as fees — keep a record of the charges and lodge a complaint with the NBU.

What about mortgages and car loans?

As a general rule, interest on mortgages continues to accrue (with certain exceptions for residents of occupied territories and owners of destroyed homes). For car loans, the relief suspends interest payments but not the principal or compulsory insurance.

The bank continues to charge interest despite the application. What should I do?

A written request for a recalculation, citing paragraph 15 of Article 14 of Law No. 2011-XII, a complaint to the NBU, and, if necessary, a claim for the return of funds obtained without legal grounds (Article 1212 of the Civil Code). You can also turn to the free legal aid scheme.

What about the loans of a deceased serviceman included in the estate?

These are subject to write-off upon application by the heirs, supported by documentary evidence — do not pay them until this right has been exercised. We have covered the procedure for settling the inheritance itself separately; debts not eligible for write-off are inherited within the limits of the value of the estate.

Are utility bills accrued for military personnel?

This is a separate arrangement: late payment charges for housing and utility services are not applied to any consumers during martial law, but the charges themselves are not waived. Do not confuse this with payment holidays – the mechanisms are different.

Service has ended. From when does interest start to accrue again?

Upon completion of service (demobilisation), charges resume in accordance with the terms of the contract. A sensible step to take immediately upon return is to reconcile with each creditor: to confirm that no charges have accrued during the period of service and to agree on a repayment schedule for the principal.

Sources

• Law of Ukraine ‘On Social and Legal Protection of Servicemen and Members of Their Families’ No. 2011-XII, para. 15 of Art. 14 — zakon.rada.gov.ua/laws/show/2011-12
• Explanatory note from the Ministry of Defence regarding payment holidays (February 2026) — kmu.gov.ua
• Civil Code of Ukraine, Articles 1212, 1282 — zakon.rada.gov.ua/laws/show/435-15
• Law of Ukraine ‘On Consumer Credit’ No. 1734-VIII — zakon.rada.gov.ua/laws/show/1734-19

Interest-free repayment holidays without any hidden traps with ‘Svarog’

Send us a list of your loans and your employment documents — we will prepare applications for each lender, ensure the relief is applied, and if a bank or microfinance organisation has already overcharged you, we will reconcile the accounts and recover the funds, including through the courts. We work remotely: applications can be submitted by a spouse or a representative acting under a power of attorney. Related services: lawyer specialising in loans and microloans, legal representation, full price list.

+38 095 554-54-24 · Telegram: @Svaroglaw · Kyiv, 7 Khoriva Street, Office 2 (Podil)