Олександр Сич
August 29, 2026
Law No. 3498-IX has capped the maximum daily interest rate on consumer microloans: in 2026, it stands at 1 per cent per day of the loan amount, including all fees and charges. Furthermore, under the Law ‘On Consumer Credit’, late payment charges may not exceed 15 per cent of the overdue amount, and the total amount of the penalty may not exceed half of the loan amount received. Any charges exceeding these limits are unlawful and subject to recalculation, including through the courts.
Just a few years ago, the story of ‘borrowing 5,000 UAH and ending up owing 60,000’ was a common occurrence: interest rates charged by microfinance organisations reached 2 per cent per day or more, and late payments multiplied the debt every month. The legislator has gradually dismantled this model: Law No. 3498-IX introduced a maximum daily rate with a phased reduction, and in 2026 it will be set at 1 per cent per day. The National Bank monitors compliance in more than just a formal sense: in December 2025, one of the major MFOs was fined over 2.8 million UAH for exceeding the maximum daily rate and for hidden charges.
For borrowers, this means two things: new loans have become more predictable, whilst existing debts calculated ‘the old way’ should be checked and recalculated. Let’s look at how the limits work, how to calculate the legal maximum for your debt, and what to do about claims that exceed it. For a personalised analysis, visit the service page of a solicitor specialising in loans and microloans.
Three limits that protect the borrower
| Limit | Amount | Basis |
|---|---|---|
| Maximum daily interest rate | 1 per cent per day of the loan amount (including interest, fees and all other payments) | Law No. 3498-IX |
| Late payment penalty | no more than 15 per cent of the overdue payment | Part 2 of Article 21 of the Law of Ukraine ‘On Consumer Credit’ |
| Total penalty (fines + late payment penalty) | not exceeding half the amount of the loan received | Part 2 of Article 21 of the Law of Ukraine ‘On Consumer Lending’ |
Example of calculating the statutory maximum: a loan of 10,000 UAH for 30 days. Interest and fees combined — no more than 1% × 30 days = 3,000 UAH. The total penalty for late payment — no more than 5,000 UAH. In other words, even in the worst-case scenario, a demand to ‘pay back 40,000 for a tenner’ has no legal basis.
Do the new limits apply to old debt?
The 1 per cent rate applies to charges from the moment the relevant phase of the restrictions came into force; it is not applied retrospectively to the entire previous period. However, this does not mean that old debt is untouchable: the limits on late payment charges and aggregate penalties under the Law of Ukraine ‘On Consumer Lending’ have been in force for some time; hidden fees and payments not specified in the contract are not enforceable; and any terms of the contract that conflicted with the restrictions in force at the time of conclusion are void. In practice, recalculating a typical ‘inflated’ debt reduces the MFI’s claim by a factor of 2 to 4.
How to recalculate your debt: step by step
- Request a detailed breakdown of your debt from the MFI, showing the principal, interest, fees, penalties and late payment charges, with the dates on which they were charged. The lender is obliged to provide this; refusal is grounds for a complaint to the NBU.
- Check the contract: the actual annual interest rate, the list of all payments, and whether the rate complied with the limits in force on the date the contract was signed.
- Calculate the legal maximum using the limit formulas and compare it with the amount demanded.
- Send the MFI a written request for a recalculation along with your calculation. A significant proportion of companies adjust the amount at this stage — it is not in their interests to face legal action over unlawful charges.
- Lodge a complaint with the NBU via the ‘Complaints’ section on the regulator’s website: the NBU imposes fines for exceeding the rate, and a complaint noticeably changes the tone of the negotiations.
- Court — if the MFI persists: file a counterclaim in response to its claim, or bring your own claim seeking to have the terms of the contract declared invalid and to have the amount recalculated.
Typical MFI violations identified during an audit
- ‘service’ and ‘package’ fees on top of interest, which in total exceed the daily limit;
- a fee for extending the term, which was not included in the calculation of the actual interest rate;
- accrual of interest after the expiry of the contract term at the loan rate instead of the statutory consequences of default;
- penalty interest exceeding 15 per cent of the overdue payment and a forfeit exceeding half the loan amount;
- sale of the debt to debt collectors with ‘inflated’ amounts not included in the original calculation.
When a solicitor is not needed
If the debt is recent, the MFI’s calculations are transparent and fall within the limits — the matter can be resolved through payment or restructuring without a solicitor. A solicitor is needed when the claim is many times greater than the amount borrowed, when the debt has been resold to debt collectors, when the MFI has already taken the matter to court, or when there are several debts and a comprehensive strategy is required — ranging from recalculating each one to personal bankruptcy as a last resort.
Questions and answers
What is the maximum rate for a microloan in 2026?
1 per cent per day of the loan amount, including interest, fees and all other payments (Law No. 3498-IX). Anything structured to circumvent this limit constitutes a breach for which the NBU imposes a fine.
I borrowed 8,000 UAH, but they’re demanding 35,000. Is this legal?
Almost certainly not. Work out the maximum: interest is capped at 1 per cent per day for the duration of the loan, the penalty is half the loan amount (4,000 UAH), and the late payment charge is 15 per cent of the overdue amount. Demand a detailed breakdown and a recalculation.
Does the 1 per cent limit apply to debts taken out previously?
The rate applies to charges incurred after the relevant stage of the restrictions came into force. Older periods are assessed against the limits in force at the time: a late payment penalty of 15 per cent, a forfeiture of ≤ half the loan amount, and a ban on hidden charges. A recalculation usually reduces the amount significantly anyway.
The MFI is not providing a detailed calculation of the debt. What should you do?
Send a written request and, in the event of a refusal or no response, lodge a complaint with the NBU — the obligation to provide a calculation is explicitly stipulated in consumer credit legislation. Without a calculation, it will be difficult to prove the amount, both with the MFI and in court.
Where can you complain about an MFI, and does it work?
To the National Bank via the complaints section on its website. It works: the NBU imposes fines for exceeding interest rates and hidden charges, and the very fact of a complaint often makes the MFI more accommodating in negotiations regarding a recalculation.
Can interest keep accruing indefinitely until I pay?
No. Interest at the agreed rate is charged within the term of the contract; once this expires, other, limited mechanisms apply. The Supreme Court’s case law has consistently ruled against ‘perpetual’ interest at the contractual rate.
The debt has been sold to debt collectors, and the amount has increased. Are they entitled to do this?
The new creditor acquires exactly the same rights as the MFI held — it is not possible to ‘inflate’ the debt upon sale. Demand that the debt collection agency provide documents confirming the assignment of the debt and the original calculation; amounts exceeding the legal limits can be contested in the same way.
What happens if I simply do not pay back the microloan?
A debt within legal limits will not simply disappear: the MFI or debt collector can recover it through the courts or by means of a notary’s enforcement order, with your bank accounts being frozen. The best strategy is not to go into hiding, but to establish the lawful amount of the debt and negotiate a restructuring of the correct sum.
Is it possible to write off debts to MFOs completely?
There is a legal mechanism available — personal bankruptcy — but this is a last resort with consequences for your assets and credit history. In most cases, a recalculation and restructuring are sufficient.
How much does a solicitor’s assistance cost in a case involving an MFO?
It depends on the stage: analysing the contract and calculating the lawful debt — a fixed-fee consultation; supporting negotiations or court proceedings — based on the volume of work. Current rates are available on the pricing page; in court proceedings, the costs of legal assistance are recovered from the MFI if the case is won.
Sources
- Law of Ukraine No. 3498-IX (restrictions on the daily interest rate) — zakon.rada.gov.ua
- Law of Ukraine ‘On Consumer Credit’ No. 1734-VIII, Article 21 — zakon.rada.gov.ua/laws/show/1734-19
- National Bank of Ukraine, ‘Consumer Protection’ section — bank.gov.ua
- Civil Code of Ukraine, Articles 549–552, 1054 — zakon.rada.gov.ua/laws/show/435-15
Recalculation of debt owed to an MFI with the company ‘Svarog’
Send us the contract and the latest demand from the MFI or debt collectors — we will calculate the legal maximum amount of your debt across all credit lines, prepare a request for recalculation and a complaint to the NBU, and if the case is already in court — a counter-claim, which usually reduces the claim significantly. Related services: lawyer specialising in loans and microloans, legal representation, full price list.
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