Ukraine's Virtual Assets Bill: What the First-Reading Text of № 10225-д Actually Says

The short version

Ukraine adopted a Law "On Virtual Assets" back in February 2022 — and it never entered into force, because its own final provisions tied it to tax amendments that were never passed. Bill № 10225-д (registered 24 April 2025 by the Finance, Tax and Customs Policy Committee under Danylo Hetmantsev) is the second, far more ambitious attempt: a single umbrella act that amends the Tax Code, restates the virtual-assets law in a new edition under a new name — "On Virtual Asset Markets" (Про ринки віртуальних активів) — and adjusts a set of adjacent laws including the Law on Advertising and the Law on Currency and Currency Operations.

The Verkhovna Rada adopted it as a basis in the first reading on 3 September 2025, with 246 votes, and instructed the committee to refine it. It was placed on the current session's agenda by Resolution 4775-IX of 10 February 2026, and its official status is now "being prepared for the second reading." This article describes what is actually in the first-reading text — the only version publicly available — provision by provision.

A MiCA-shaped law: the new "On Virtual Asset Markets"

The heart of the bill is a complete new edition of the virtual-assets law, and its architecture will look familiar to anyone who has worked with the EU's MiCA regulation — the bill is formally flagged as a European-integration bill, and the parliamentary EU-integration committee assessed it as broadly consistent with EU law (while requesting refinements). The new law is organised in nine sections:

1. IGeneral provisions — scope, definitions, legal foundations.
2. IIThe legal regime of virtual assets — what a virtual asset is, its types, and ownership rights. Virtual assets are objects of civil rights; they are not legal tender.
3. IIIVirtual assets that are neither asset-referenced tokens nor e-money tokens — the default category, with rules for public offers, including white paper requirements and marketing communications.
4. IVAsset-referenced tokens — issuance, trading and asset reserve rules for tokens stabilised against baskets of values.
5. VE-money tokens — tokens referencing a single official currency: issuance, redemption, and investment of received funds.
6. VIService providers — authorisation requirements and conduct rules for providers of virtual-asset services.
7. VIIVirtual asset markets — rules for trading venues and market-abuse prevention.
8. VIIIRegulator powers — supervision and enforcement measures.
9. IXFinal and transitional provisions.

Who regulates? Still the open question

Remarkably, the first-reading text leaves the single most contested institutional question open. As co-sponsor Yaroslav Zhelezniak put it on the day of the first-reading vote:

"Who the regulator is (the NBU or the NSSMC) is still unknown."

The 2022 law had settled on the National Securities and Stock Market Commission; the current draft's supervision section is written around "the Regulator," with the allocation between the National Bank of Ukraine and the NSSMC to be resolved — one of the headline items to watch in the second-reading text.

Service providers: authorisation, reporting, fines

For businesses, the operative rules in the first-reading text are:

• Authorisation with the regulator — with a registration route for certain categories — required within 60 days of starting activity;
• Annual reporting obligations;
• Fines from 0.5 to 100 minimum wages for failure to report or other violations;
• Client- and investor-protection mechanisms, including advertising regulation (hence the amendments to the Law on Advertising) and anti-fraud measures;
• Alignment of the AML framework for virtual assets with international standards.

A second, separate registration obligation arrives through the Tax Code: providers serving Ukrainian residents must register with the tax authorities and file an annual report on virtual-asset transactions of Ukrainian-resident individuals and legal entities. The explanatory materials present this as Ukraine's first step toward the OECD's Crypto-Asset Reporting Framework (CARF) and the EU's DAC8 — that is, toward automatic international exchange of crypto tax information. Notably, the bill softens the landing: during the transition, reporting fines apply at 10% of the statutory amount in 2026 and 25% during 2027–2029.

The tax regime: 23% on profit, with a 5% amnesty-style window

The Tax Code amendments are where most readers' questions live, and the first-reading text is specific:

For individuals, a special regime applies to virtual-asset operations, separate from both ordinary income and the existing investment-profit rules. Tax is charged on the positive financial result for the year: all proceeds from selling virtual assets, minus documented costs of acquiring (or creating) them, with the allowable-cost list deliberately limited (and expandable by the Finance Ministry in agreement with the regulator). Losses carry forward until fully absorbed, with narrow exceptions. There is no tax agent: the taxpayer self-declares and self-pays.

The rate, per the bill's sponsors, is the standard combination — 18% personal income tax plus the 5% military levy, i.e. 23% of profit.

The first-reading text also carves out what is not taxed:

• Crypto-to-crypto exchanges — swapping one virtual asset for another is not a taxable event;
• Sales within one minimum wage per year;
• Assets received from issuers via emission, free distribution, or in exchange for personal data — a definition that captures typical airdrop mechanics.

And the transitional headline: for virtual assets acquired before the law enters into force, individuals selling during the first year may opt for a preferential 5% personal income tax rate — per committee chair Danylo Hetmantsev, without confirming historical acquisition costs. Functionally, it is a legalisation window: declare, pay 5%, and bring pre-existing holdings into the open in year one. (The first-reading text wrote this window for 2026 — one of several dates that will necessarily shift in the second-reading version, since the bill was not adopted in time for a 1 January 2026 start.)

For companies, the bill introduces adjustment differences modelled on the Tax Code's existing securities-taxation approach. On VAT, virtual-asset issuance, placement, sale, exchange and redemption are outside the scope — with carve-outs pulling NFT sales and exchanges and tokens that certify rights to goods or services back into VAT, and with providers' services outside VAT except consulting. And the simplified tax system is closed off entirely: single-tax payers may not conduct virtual-asset operations, and providers may not sit on the simplified system.

What the committees flagged

The official record heading into the second reading contains documented tensions worth knowing about: the Main Scientific and Expert Directorate issued remarks on the draft; the Anti-Corruption Committee concluded that certain provisions do not meet anti-corruption legislation requirements; the Budget Committee noted fiscal effects in both directions; and the EU-integration assessment, while broadly positive, requested refinements. None of this blocked the first reading — but it maps the areas where second-reading amendments are most likely.

What happens next — and what to do about it

The bill is on the agenda and prepared for the second reading. Its own sponsors have cautioned that the text "may change substantially" before adoption — the regulator question alone guarantees meaningful amendments, and every date in the first-reading text needs recalibration. When the adopted text appears, we will publish a companion analysis of what changed against the version described here.

For businesses with Ukrainian users or Ukrainian operations, the practical read is: the direction is set — a MiCA-shaped authorisation regime, provider reporting wired toward CARF/DAC8, and a defined tax perimeter with a one-year legalisation window. The details are still moving. If you're structuring now, structure for the direction, and keep a close watch on the second-reading text.