The work of the National Association of Insurers of Ukraine (NAIU) in 2025 was built on the foundation of the Annual Plan approved by the General Assembly and encompassed an exceptionally broad spectrum of tasks. From legislative initiatives and tax amendments to the implementation of innovative educational platforms and the deepening of international cooperation—throughout the year, the NAIU team not only completed all planned activities but also executed a series of additional projects, promptly responding to current market challenges. As part of our traditional public reporting, we detail the year’s main achievements below.
Improvement of Tax Legislation and Sectoral Reforms
One of the Association’s unwavering priorities remained the tax stimulation of market development. This year, we succeeded in ensuring the inclusion of issues related to the improvement of insurance taxation in the Government’s Priority Action Plan for 2025. This was a logical continuation of previous years’ work, when NAIU, in close cooperation with the National Bank of Ukraine (NBU), agreed upon amendments to the Tax Code. These changes pertained to stimulating the development of personal insurance lines, harmonizing tax legislation due to the market’s transition to the international reporting standard IFRS 17 , and aligning the Code’s provisions with the requirements of the new Law of Ukraine “On Insurance.”
In 2025, NAIU developed a regulatory concept for the activities of insurance intermediaries, which also necessitates corresponding amendments to the Tax Code. Throughout the year, the Association provided support for this draft law, delivered comprehensive argumentation to stakeholders, and discussed the necessity of these innovations during meetings with the NBU Board.
In parallel, extensive work continued on implementing the laws “On Insurance” and “On Compulsory Third-Party Liability Insurance for Owners of Land Vehicles.” Responding to requests from market participants, NAIU formulated consolidated positions and provided methodological support for the new regulations. To make this process as convenient as possible for insurers, we created an “Expert Center” on the Association’s official website—a dedicated section for the centralized publication of NBU clarifications and recommendations. The Association’s experts processed a significant volume of the regulator’s draft normative-legal acts submitted for public discussion and initiated amendments to specific requirements. Interaction with the Consumer Rights Protection Department was also a vital aspect; we held joint meetings and established a regular exchange of information regarding law enforcement practices.
New Rules for Insurance Intermediaries and Educational Projects
The Concept of amendments to the regulation of insurance intermediaries developed by NAIU proposes a clear division of their functions. One part of these functions covers direct client interaction, while the other covers the organization of insurance product distribution, which includes managing agent networks, training, and recruiting. The Concept also distinguishes a group of intermediaries whose primary service is providing access to their own clients and lead generation. Such changes will allow for the legal formalization of relations with insurance intermediaries in accordance with their true nature. This, in turn, will make the interaction between insurers and intermediaries maximally transparent, leaving no room for fraud or manipulation.
The implementation of new legislative requirements regarding the training of insurance intermediaries became one of the most extensive projects of the year. NAIU created a specialized platform and launched websites for training the intermediaries of the Association’s members. We produced high-quality educational video content, text materials, and tests, which were made freely available on the newly created “NAIU-Ukraine” YouTube channel. This served as an effective response to insurers’ urgent need to train their partners. Furthermore, the Association conducted training for insurers themselves on agent registration procedures, and, together with market participants, developed standard application forms and a list of required documents for intermediaries of all ownership forms. We also organized consultations with aggregators regarding information disclosure and created a convenient communication platform for sharing experiences.
Financial Monitoring and Reporting Transparency
In the realm of financial monitoring, the key objective was to simplify customer due diligence procedures. Our goal was to improve regulation, harmonize it with the updated Law of Ukraine “On Insurance,” and fully account for the specific nature of insurance activities. NAIU held a series of working meetings with the NBU and submitted official appeals with detailed justifications for the necessity of amending Resolution No. 107, specifically concerning the settlement of insurance claims and the payment of indemnities. The Association also directly participated in a working group under the State Financial Monitoring Service to conduct a national risk assessment, and ensured the consolidated submission of a questionnaire for the annual typological study on money laundering and terrorist financing risks.
Another major challenge was resolving issues surrounding the Standard Audit File for Tax (SAF-T UA). The Association initiated appeals to the Ministry of Finance and the tax authority, pointing out the primary risks: the unauthorized disclosure of insurance confidentiality and the failure to account for industry specifics, as the SAF-T UA file is oriented toward commodity exchange operations, which are not characteristic of insurance. At the same time, an important victory of the year was the elimination of a legal collision regarding insurance confidentiality and the introduction of corresponding amendments to the stock market regulator’s decisions.
International Cooperation, War Risks, and Looking to the Future
Ukraine’s movement toward the EU also defined the international vector of our work. The Association ensured active participation in the working group on financial services, where the state’s negotiating positions were formulated, and held consultations on adapting Ukrainian legislation to European standards. International activities also encompassed cooperation with the IFC on a market review, participation in the “Responsible Business for the Recovery of Ukraine” conference alongside representatives from the European Commission and the OECD, as well as specialized meetings with UkraineInvest. Additionally, we commenced promising cooperation with GIZ within the STEP IN 2 EU program.
Responding to the challenges of the times, NAIU continued its active work on a war risk insurance mechanism jointly with the Government, the NBU, and the World Bank. The Association joined a Memorandum of Understanding involving leading global players such as Marsh McLennan, Lloyd’s, AON, and the EBRD, working on the development of a state compensation system for war risks. Simultaneously, issues regarding the optimization of the implementation of Solvency II requirements were addressed in collaboration with the National Bank.
The development of human capital was not overlooked. The Association created an internal HR committee and intensified its work on financial literacy by launching its own “RPO.Insurance” project. We became a proud partner of the NBU’s initiatives “Financial Literacy for the Defenders of Ukraine” and the “FinLit Forum.”
In 2025, a new participant, IC “Express Insurance,” joined the PRIMA project, and NAIU welcomed IC “Arsenal” to its membership.
In concluding the year, the Association not only planned its current operations but also developed a comprehensive “Strategic Digest of the Insurance Market 2026–2028.” This document, created by experts from NAIU’s “Strategic Planning and Analysis” committee, contains a profound vision for the market’s development over the next three years. The Digest covers forecasts for market indicators, the factors influencing them, as well as an assessment of the consequences of implementing future regulatory acts. Such foundational planning allows us to look confidently into the future and continue building a reliable, transparent, and European insurance market in Ukraine.
