P2P Arbitrage in Ukraine: monobank, Transfer Limits and Crypto Taxes
Everything about P2P arbitrage with the hryvnia: which exchanges and banks work now, where the card-to-card transfer limits came from, how banks react to P2P trades, how much tax you pay on crypto income today and what will change once the virtual assets law is passed.

Exchanges with UAH and the current spread
The hryvnia trades on all nine P2P exchanges P2P.Army tracks; Binance has about 53% of the ads, and the rest is split among Bybit, OKX, WhiteBIT and others. Once the virtual assets law is passed, such exchanges will need authorization from the NSSMC (National Securities and Stock Market Commission). The table below is live.
| Exchange | Buy USDT | Sell USDT | Spread | Ads | Activity 24H |
|---|---|---|---|---|---|
| 46.91 | 47.25 | -0.71% | 2,241 | 152,480 | |
| 47.03 | 48.76 | -3.55% | 1,435 | 100,554 | |
| 47.36 | 48.20 | -1.73% | 441 | 3,482 | |
| 49.32 | 46.88 | +5.20% | 256 | 6,471 | |
| 48.22 | 47.10 | +2.38% | 243 | 1,215 | |
| 47.28 | 45.77 | +3.28% | 231 | 13,354 | |
| 47.80 | 48.85 | -2.15% | 212 | 2,634 | |
| 47.99 | 47.05 | +1.99% | 202 | 4,538 | |
| 48.86 | 45.69 | +6.94% | 103 | 401 |
Average prices mix different payment methods and ads from new accounts, so a large or negative spread in the table is a reason to check, not a trade. Filter counterparties by history in the order book builder.
Payment methods
| Method | Ads | Activity 24H | Exchanges |
|---|---|---|---|
| Monobank | 2,865 | 51,202 | 4 |
| Privat Bank (Universal Card) | 2,649 | 40,465 | 4 |
| PUMB | 2,137 | 35,842 | 3 |
| A-Bank | 2,083 | 40,444 | 3 |
| Sense SuperApp | 856 | 8,105 | 3 |
| Oschadbank | 741 | 10,033 | 2 |
| Bank Transfer | 636 | 3,886 | 2 |
| Raiffeisen Bank Aval | 604 | 11,104 | 1 |
Card-to-card transfer limits
In June 2024 the NBU (National Bank of Ukraine) sent banks a letter asking them to scrutinize incoming P2P transfers more closely, including small ones at an abnormal frequency — without numeric thresholds. By a resolution of August 27, 2024, the NBU capped outgoing card-to-card transfers at UAH 150,000 per month from October 1, 2024, for six months; after April 1, 2025, this limit was not extended. Since then, limits have been set by a voluntary memorandum of banks:
| Client | Limit without proof of income |
|---|---|
| High risk level | UAH 50,000 per month |
| Low and medium risk level (from June 1, 2025) | UAH 100,000 per month |
| New or “dormant” sole proprietors (FOP) and legal entities | Separate limits from August 14 and November 14, 2026 (amendments of May 14, 2026) |
In July 2026 the NBU published a draft resolution on risk levels of payment transactions (for example, more than 10 top-ups in less than an hour); we could not find whether it has been adopted. We have not verified whether monobank and PrivatBank signed the memorandum — check your bank’s terms.
monobank and PrivatBank
In September 2025 monobank support told clients that mass exchanges via P2P may qualify as business activity and asked them to refrain from such operations: the bank may block the card pending a review. In November 2023 PrivatBank said there were no new rules, but the bank may request information when turnover exceeds what was declared; at the same time it cut off a client who had made many P2P trades on Bybit.
Ban on buying crypto from hryvnia accounts
Since April 21, 2022, the NBU has banned buying cryptocurrency from hryvnia accounts — this applies to card payments on exchanges; purchases from foreign currency accounts are allowed within a limit. We found no repeal of this rule. A P2P trade between individuals is technically a card-to-card transfer, so the limits and checks described above apply to it.
Taxes and regulation
| Rule | What it means for a P2P trader |
|---|---|
| Law 2074-IX “On Virtual Assets” (signed Mar 16, 2022) | Not in force: it will take effect only together with amendments to the Tax Code, which have never been passed |
| Bill 10225-d | Registered Apr 24, 2025, first reading Sep 3, 2025; as of Oct 30, 2026 — “being prepared for the second reading” |
| Regulator under the bill | NSSMC (its virtual assets department was created in July 2026); NBU — e-money tokens only |
| Current taxation | Per the STS clarification (Mar 16, 2026): 18% personal income tax + 5% military levy on income received |
| Military levy | 5% since December 1, 2024 (Law 4015-IX) |
| Proposed in 10225-d (not yet in force) | 23% (18% + 5%) on net annual profit when cashing out to fiat; crypto-to-crypto swaps tax-free; loss carryforward; income up to one minimum wage exempt; P2P without registering as a sole proprietor (FOP) — an annual tax return with exchange statements |
| Preferential first year (under the bill) | 5% personal income tax + 5% military levy on the sale amount, with no deduction for costs; the final wording depends on the second reading |
The timeline keeps slipping: the second reading was promised for March, then for August 2026. On October 27, 2026, NSSMC head Oleh Semeniuk said the bill would go to its second reading “this month” and called a January 1, 2027 launch unrealistic: after adoption, a transition period of about six months is needed. Keep your trade history — you will need it for your tax return in any scenario.
The law “On Virtual Assets” is signed
It never took effect.NBU bans buying crypto from hryvnia accounts
From foreign currency accounts — within a limit.NBU limit of UAH 150,000 per month
On outgoing card-to-card transfers, for six months.Military levy rises to 5%
Law 4015-IX.Limits under the banks’ memorandum
UAH 50,000 / 100,000 per month without proof of income.Bill 10225-d passes its first reading
Crypto taxes and a new version of the law.First reading of bill 16013 on money mules
New Article 200-1 of the Criminal Code.Second reading of 10225-d
Then a transition period of about six months.
Local risks
The main risk for a USDT seller is receiving money stolen from someone else: the victim goes to the bank and the police, the seller’s card gets blocked, and it is the seller who has to explain where the funds came from. On September 2, 2026, the President submitted bill 16013 on criminal liability for money-mule (“drop”) accounts; on September 15 the Rada passed it in first reading (299 votes). The new Article 200-1 of the Criminal Code provides for a fine of UAH 5,100–17,000 for handing over a card or account access, and for buying, storing or selling such means — a fine of UAH 51,000–170,000 or 2–6 years of imprisonment, up to 8 years for a repeat offense or one committed by a group of persons. We have not confirmed its final adoption.
- Trade with counterparties who have 100+ orders and a 95%+ completion rate; large amounts with merchants only.
- Accept money only from the owner of the verified (KYC) account — never from third parties, relatives or “company accounts”.
- Check the credit in your own banking app, not from a screenshot or an SMS.
- Keep a separate card for P2P and withdraw profit regularly.
- For every trade, save the order number, chat, statement, payment reference and the counterparty’s KYC name.
- Never hand over your card or online banking access to anyone — bill 16013 makes this a criminal offense.
- If the bank asks you to explain transactions, respond with documents: exchange statements, order numbers and chats.
P2P.Army tools for UAH
- UAH statistics — exchanges, average prices, activity and top payment methods (free).
- USDT/UAH prices on Binance P2P — the best price for each method (free).
- USDT/UAH spreads — the maker spread by method; TOP-3/5/10 on the P2P plan.
- Order book builder — two exchanges side by side with counterparty filters (P2P plan).
- Taker signals — UAH setups above your threshold in Telegram (P2P plan).
- USD/UAH converter — bank rates against P2P prices (free).
To learn the method itself — where the spread comes from, how to assess payment methods, calculate profit and work as a maker in any country — take the free course “P2P Arbitrage from Scratch”.
Frequently asked questions
Is P2P crypto trading legal in Ukraine?
Cryptocurrency is not banned, but there is no dedicated law in force: the 2022 law never took effect, and bill 10225-d is being prepared for the second reading. Banks may restrict cards over mass P2P trades. This is educational material, not legal advice.
What is the tax on crypto income right now?
Per the STS clarification of March 16, 2026: 18% personal income tax and 5% military levy under the general rules. The new rates from bill 10225-d are not yet in force.
What will change once 10225-d is passed?
The bill proposes 23% on net annual profit when cashing out to fiat, no tax on crypto-to-crypto swaps, loss carryforward and a preferential rate in the first year. Exchanges will have to obtain NSSMC authorization. The final wording depends on the second reading.
What are the card-to-card transfer limits?
The NBU limit of UAH 150,000 applied from October 2024 to April 2025. Now the banks’ memorandum applies: without proof of income, UAH 50,000 per month for high-risk clients and UAH 100,000 for others.
Why does my bank block my card after P2P trades?
Banks treat frequent transfers from different people as a sign of a money-mule account or business activity, and they also act on complaints from fraud victims. Accept money only from the counterparty’s account and keep evidence of every trade.
Sources
- 1.P2P.Army: статистика UAH на P2P-біржахP2P.Army10/30/2026official
- 2.Картка законопроєкту № 10225-дВерховна Рада України
- 3.Danylo Hetmantsev: Ukraine is establishing a legal framework for the development of a modern financial market and digital economyVerkhovna Rada of Ukraine9/4/2025
- 4.
- 5.Гетманцев назвал срок принятия закона о криптоактивахVV / Укрінформ7/18/2026
- 6.
- 7.Оподаткування криптовалюти! Про що законопроєкт 10225-д?YANKIV10/8/2026
- 8.
- 9.
- 10.
- 11.НБУ определился со сроками и лимитами на P2P-операцииForkLog8/27/2024
- 12.НБУ про перевірку вхідних P2P-переказівМінфін6/25/2024
- 13.
- 14.
- 15.
- 16.Прикрили лавочку: Нацбанк усунув лазівку, що дозволяла обійти заборону на купівлю валютиForbes Україна4/22/2022
- 17.Зеленський вніс до Ради два законопроєктиLB.ua9/2/2026
- 18.
About the author

Crypto expert, arbitrage trader and investor
Crypto expert and hands-on crypto arbitrage trader, investor and software developer with over 20 years of experience. On the P2P.Army blog he covers exchange news, P2P and cross-exchange arbitrage.
- Crypto arbitrage
- P2P arbitrage
- Cross-exchange arbitrage
- Crypto exchanges
- Investing
- Software development


