Ukraine’s Stock Market Regulator Says It Met IMF Benchmark Despite Criticism

The institution told Kyiv Post it had fully addressed the requirements demanded by the IMF, even though the fund claimed in the March 2025 memorandum it hadn’t.

Ukraine’s National Securities and Stock Market Commission (NSSMC) says it had submitted an operational strategy and started the independent fit and proper review, although economists had previously stated it had not been done. 

Both NSSMC strategy and review are a requirement of the International Monetary Fund (IMF) to complete the review of its four-year, $15.5 billion Extended Fund Facility (EFF) program. 

It is assessed that the commission needs to be reformed as Ukraine is striving to launch the stock market for retail clients – if it is to be able to attract the necessary capital for Ukraine’s recovery.

If NSSMC doesn’t the IMF’s requirements, Ukraine risks losing the next tranche of $500 million, expected after completion of this month’s the eighth review

Previously, analysts from the Ukrainian RRR4U Consortium had criticized the NSSMC for failing to complete the benchmarks on time.   

In a reply to Kyiv Post’s request for a comment, NSSMC wrote that it had fulfilled the Structural Benchmark No. 48 and developed a reorganization and operational strategy. 

“This strategy was submitted to the IMF in accordance with the established procedure in January 2025. Accordingly, this task has been completed,” NSSMC said. 

However, the IMF suggested NSSMC had not met the necessary requirements in its memorandum after the seventh review published in March 2025, which also said  “The [Ukrainian] authorities also missed the January structural benchmark for the NSSMC strategy.”

NSSMC also told Kyiv Post that it initiated a check in April, which happened after the IMF criticized the institution openly. 

“In particular, on April 16, 2025, the procurement of services from an independent consultant was initiated to conduct an independent assessment of the compliance of certain staff members of the Commission with the requirements of the legislation and internal regulatory documents,” NSSMC wrote in the reply to our request. 

Analysts at the RRR4U consortium also warned it might jeopardize next tranches under the EFF program, critically important to finance Ukraine’s war-torn economy. 

They added that NSSMC should have adopted the Code of Ethics for employees and assess the staff according to this document. 

“According to the seventh review of the IMF program, Ukraine fulfilled all components of the benchmark except for the performance assessment of the NSSMC. As a result, Structural Benchmark No. 48 was considered unmet,” the RRR4U Consortium wrote. 

Kyiv Post sent an additional request asking NSSMC to clarify the differences between the information in the IMF memorandum and its reply to Kyiv Post, also asking what are the next steps necessary to complete the benchmark. 

Ukraine’s Prime Minister Denys Shmyhal reported that the IMF was finalizing its work on the eighth review of the four-year, $15.5 billion EFF program for Kyiv.

Ukraine has already passed a record seven successful reviews of the program. 

If the eighth is also successful, the IMF will disburse a tranche of around $500 million, Shmyhal wrote in his blog on Telegram. Shmyhal called the meetings with the IMF mission, led by its head Gavin Gray as being “successful.”