UAIB's proposals taken into account in the OECD report "Stronger Financial Markets and Institutions for Ukraine's Recovery"

On March 5, the Organisation for Economic Cooperation and Development presented its report “Stronger Financial Markets and Institutions for Ukraine’s Recovery”.

The Association previously provided its suggestions to the draft report, following the OECD Roundtable, which took place in December 2025.

The OECD final report largely took into account the suggestions of the UAIB, in particular:

1. Regarding the reform of the Collective Investment Institutions market:

• "Because of the important role currently played by CIIs in the Ukrainian economy, reforms should be carefully adapted, minimising potential negative effects on existing business activity." (Chapter 2. Ukraine’s financial system framework, 2.2.4. Reform the legislation of investment funds, p. 22);

2. Regarding reforming the non-state pension provision system:

• "In addition, developing an asset-backed pension system that complements existing pension arrangements will help increase retirement resources while also providing a larger pool of savings for capital market development." (Executive summary,p. 8);
• "The development of asset-backed pensions will help diversify financing sources for a resilient pension system, while also contributing to capital market development. Key considerations for regulators before and during implementation include the institutional setup, costs, provider types, governance, supervision and financing sources that complement existing schemes." (Executive summary,p. 9);
• “In reforming its pension arrangements, Ukraine could preserve the current system of personal voluntary accounts and integrate it in the overall asset-backed pension system, which would help to maintain the trust of its participants and encourage new ones.” (Chapter 6. Guidelines to develop asset-backed pensions in Ukraine,6.1. Introduction, p. 109);
• "There are trade-offs in the choice of pension providers. The main decision is whether pension providers should be part of existing financial entities, or whether to set up independent standalone pension entities (OECD, 2022[6]). The experience of OECD countries ranges from situations where existing entities such as a bank, mutual fund, or insurance company become providers (e.g. Korea) to situations where asset backed pension providers are independent, standalone entities, and not owned by providers of other financial services (e.g. Australia). In between are situations where pension providers are independent entities that retain ties to existing financial services providers (e.g. Chile). 

To decide within this range of options, policymakers need to look at factors such as: 

• the cost to members 

• what would be convenient and simple given the country’s starting point 

• which providers would the public trust

• how to avoid market concentration, and 

• how to avoid a market structure in which clients are captive and cannot choose or change provider"
The choice of the type of legal structure of pension providers is also an important feature to consider.

(Chapter 6. Guidelines to develop asset-backed pensions in Ukraine,6.3.1. Institutional set-up, p. 110).

3. Regarding corporate governance:

• "According to stakeholders, Ukrainian regulations on stock exchange operations and listing rules are too demanding for the country’s market context. Because of limited financing opportunities and high regulatory costs, even large Ukrainian companies do not list domestically. In addition, neighbouring capital markets are deemed more flexible and convenient for Ukrainian companies. Although the capitalisation threshold was recently revised as part of NSSMC regulatory changes to stock market operations, Ukraine could nonetheless reconsider the new threshold. Allowing stock exchanges greater flexibility to set rules on matters such as the timing of incorporation and shareholder composition could also be a positive step, particularly with a view to attracting foreign investment and developing a growth market for SMEs." (Chapter 3. Ukraine’s corporate governance framework, 3.2.3. Revising NSSMC regulations for stock market functioning, p. 54).

For more details, see the report linked above.

Also, last week, UAIB discussed the voluntary pension reform in Ukraine with the EU FINMAR Project.

UAIB will continue to collaborate with stakeholders in the reform of investment and pension funds in Ukraine, including international partner organisations.