The bank sees neither an “exchange service” nor a “private person” — it sees the fields of the payment instruction: the payer's name and details, the amount, the date and the text of the payment reference. The whole difference between the two pictures lives in those fields, and they are filled in by the payer, not by the bank.
Under NBU Instruction № 163 the payment reference is a mandatory detail, and it has to be filled in so that the payee understands the full information about the payment and about the documents it goes on. How full it is, the payer decides. The payer's bank checks this field only by external signs, and it is the payer who answers for whether what is written matches the substance of the transaction.
Instruction № 163 contains no requirement to write a contract number or VAT in the payment reference: that is banking and contractual practice, not a rule. The format is prescribed in three cases only — a direct debit, an enforced debit and payments to the budget. What does apply is the opposite rule: fields of a transfer filled in meaninglessly are to be treated by the bank as an absence of information.
Which fields reach the payee's bank at all
The list of mandatory details of a payment instruction sits in clause 37 of section II of NBU Instruction № 163 of 29.07.2022, version of 01.08.2026. The payment reference is fifth in order there, and the same clause records who fills it in: the mandatory details are filled in by the payer. Not the bank and not the payee.
The rule for filling it in is clause 41. The payer must give the payee full information about the payment and about the documents it goes on, and decides how full that is themselves. The payer's payment service provider checks the filling in only by external signs. Clause 35 of section I closes the construction: it is the payer who answers for whether what is written matches the substance of the transaction.
After that the field lives a life of its own. The Law “On Payment Services” № 1591-IX of 30.06.2021, version of 26.06.2026, Article 40: an instruction must contain information that allows the payer and the payee to be identified, and the information stated by the initiator is passed on unchanged — however many intermediaries there are.
A detail about the hierarchy of rules: the phrase “призначення платежу” itself does not occur in the Ukrainian text of the law even once — the mandatory details are set by the NBU, part 7 of the same Article 40. The requirement to fill in the field lives entirely at the level of a subordinate act, not of a law.
Two small things that are visible in a statement. The details are filled in in the state language (clause 10), and Latin script is allowed only if the rules of the payment system or of the bank provide for it. A transfer without opening an account (clause 105) also requires a reference, and the data about the payer goes on unchanged (clause 113).
The asymmetry: the bank knows more about the payer than about the payee
This is where “a transfer from a company” and “a transfer from a person” diverge the most, and the point is not the sender's reputation but the volume of data. Article 14 of Law № 361-IX, version of 26.06.2026, describes which data must accompany a transfer — the sets for the two sides are different.
Data accompanying a transfer | About the payer | About the payee |
|---|---|---|
Ukraine, full set — Art. 14 of Law № 361-IX | surname and first name, account or wallet number and additionally one of: place of residence, passport series and number, RNOKPP, date and place of birth | surname, first name and account number |
EU, full set — Regulation (EU) 2023/1113 | name, account number and additionally address, document number or date and place of birth | name, account number, LEI |
What goes by default inside the jurisdiction | account number | account number |
Part 1: inside Ukraine a transfer is accompanied by at least the account numbers of both sides. The full set the entity is obliged to provide on request within three business days — for transactions from 30 thousand hryvnias. For smaller ones the shortened one is enough, but only where there are no signs of a link with transactions that together exceed that threshold.
Part 5 is about something else: it lifts verification up to the same 30 thousand, but not where there is a suspicion about the transaction or the funds were received from the payer in cash. And part 6: where the information that a transaction must be accompanied by is absent, carrying it out is prohibited. Not “may be suspended”, but prohibited.
One more thing about this article, because it gets cited to the wrong address: it contains no separate travel rule regime for cryptocurrency. In the version in force virtual assets are mentioned only as a way of initiating a payment transaction. The requirements for crypto transfers live in a different document.
The same in the euro area — and where there is no threshold at all
Regulation (EU) 2023/1113 has applied since 30 December 2024. The date sits in Article 40, not in Article 39, where what is actually recorded is the repeal of the previous regulation — this small thing is mixed up regularly. The logic of the regulation is the same as in the Ukrainian law: the extended data is needed only about the payer.
Inside the EU a transfer is accompanied by account numbers (Article 5), and the provider issues the full set on request within three business days — for transfers above €1,000. Article 4(6) prohibits carrying out a transfer until the provider has satisfied itself of full compliance with the requirements.
For transfers of crypto-assets, though, there is no threshold at all: the requirements are the same regardless of the amount, and the regulation makes no exemptions for small domestic transfers. A thousand euro appears in relation to crypto-assets in one place — Articles 14(5) and 16(2), and not in Article 19, as secondary sources write.
What is meant is a transfer to a self-hosted address: above a thousand euro the provider is obliged to assess whether that address belongs to the sender. The only thing left outside the regulation is a transfer between people without a provider taking part — Article 2(4).
Another mistake in circulation concerns the reference field itself in a European transfer. Regulation (EU) № 260/2012, consolidation of 08.04.2024, does not require “no fewer than 140 characters”: its annex says that the field must accommodate 140 characters, that filling it in is not mandatory, and that once filled in banks are obliged to carry it through unchanged.
What in these fields catches a check
The document under which the bank looks at a transfer is NBU Board Resolution № 65 of 19.05.2020, version of 17.07.2026. Naming it precisely matters: in this story people constantly cite the wrong act. Why the bank is obliged to ask at all is dealt with separately — financial monitoring and the bank's questions.
Annex 16 describes meaningless information about the payer or the payee: where the relevant fields hold a set of random characters or a word that cannot be regarded as the payer's data. Such a case the bank is to treat as an absence of information.
In the same annex are the indicators of online monitoring: an unusually large amount; a jurisdiction from the FATF list; negative information about the entity the transfer came from; an entity that repeatedly fails to answer requests; a transfer without the name of the payer or of the payee.
Annex 20 holds the indicators of suspicion; they are numbered, so the reader can check each one themselves. Six of them bear on the story of “money into a personal account”.
- 53. The payment references of a client that is a business entity usually contain no understandable and clear purpose: only references to contract or invoice numbers, without stating the type of goods or service.
- 63. Financial transactions for significant amounts through the personal account of a natural person, if their character is typical of commercial activity.
- 40. The client receives many payments of insignificant amounts, which are later aggregated and transferred as one large amount to another client.
- 12. The transactions do not match the client's risk profile — age, profession, income.
- 30-1. Exceeding by more than double over a month the maximum amount declared by a client that is a natural person.
- 50. A debt is repaid out of funds coming in from legal entities.
Indicator 53 is itself the answer to the question “what to write” — for a client that is a business entity, admittedly. A reference along the lines of “payment under the contract” does not explain what exactly the money is for, and for financial monitoring this is not neutral text but a sign in its own right. What is always missing is one thing — the type of goods or service.
What is not in these rules — and what gets repeated for nothing
Ministry of Finance Order № 465 does not apply to banks. Clause 2 of section I lists those who apply these criteria, and banks are expressly excluded there: a bank works under NBU Resolution № 65. The order was registered on 09.02.2023, has been in force since 24.02.2023 and has not been changed since; whom it actually binds is in a separate article.
Order № 465 has no criterion of “funds received from a legal entity instead of a natural person”. The nearest thing there is payments received from unrelated or unknown third parties. A direct analogue does exist, but with a different regulator: it is indicator 50 of Annex 20 to NBU Resolution № 65.
Instruction № 163 contains no requirement to write VAT or a contract number: the Ukrainian text of the Instruction does not contain the words “податок на додану вартість” even once. The format of the reference is prescribed in three cases only, and in one of them — in a direct debit — the field is filled in by the payee.
- Direct debit, clause 57. Here it is the other way round: in the “Payment reference” detail the payee must state the name, number and date of the contract with the payer.
- Enforced debit, clauses 63 and 63-1. The format is set by the rule, not by the parties' agreement.
- Payments to the budget. A separate act applies to them — Ministry of Finance Order of 22.03.2023 № 148, in force since 01.04.2023: it sets a structured format of the reference under the ISO 20022 standard.
The NBU has no special crypto indicators of suspicion: a search of the Ukrainian text of Annex 20 for the stem “віртуальн” returns nothing. Cryptocurrency enters the assessment through clause 60 — clients carrying on activity in the field of virtual assets are given high risk automatically, by type of activity and not by behaviour.
And a conclusion that does not follow from this, though it is drawn constantly: “through an exchange service it is calmer, because the sender is one”. We are an exchange service and we still will not say that — clause 60 works the other way round. The number of counterparties and the client's risk profile are different things.
How a payment is recognised at our end and how the bank recognises it
Here is our own mechanics, and it gives a useful contrast. We are an exchange service: we exchange cryptocurrency for cash and back. When a person pays us in cryptocurrency, the order is recognised by the address — an external payment service raises a one-time address for a specific order, and a comment on the transfer is not needed at all.
When a payment goes not to a one-time address but to a permanent account, the comment on the transfer becomes the only thing that links the payment to the order. Without it the payment will not be found automatically and is sorted out by hand. The amount has to match down to the character: the network fee is paid by the sender.
A bank has no one-time accounts for each client. That is exactly why the payment reference is the banking analogue of a one-time address: the single field from which the payee will understand what the money came for, and the bank — whether what is written matches the substance of the transaction.
Hence a typical mistake, the same at our end and at a bank. The service gives out not a ready string but a template with substitutions; a person copies it as it is, without substituting the order number — and the payment arrives effectively without a reference. The field is filled in, and there is no information in it.
And a rule that an exchange service introduces by its own terms before any bank does: the sender and the payee on an order must be one and the same person, transfers in favour of third parties are prohibited. The bank looks at the same thing from its side and, as can be seen above, has separate indicators for it.
An honest line, without which the section would be advertising: the service does not make bank payouts in hryvnia and euro at all today. As of 19.09.2026, of 66 directions three are connected with the banking side, the rest are cash and blockchain. The article deals with the general case, not with our own payment.
Timings: how a standard differs from the fact
The NBU's Electronic Payment System was moved to a new generation on 1 April 2023, and since then it has worked around the clock; according to the NBU page as of 19.09.2026 — more than 99% of interbank payments. Since 1 December 2024 it has an instant credit transfer with a standard of ten seconds — Article 49-1 of Law № 1591-IX.
But “the system works 24/7” and “the money will arrive at three in the morning” are different statements. Under Article 47 of the same law, execution of an instruction and crediting are tied to the operating day, whose boundaries each payment service provider sets itself. The bottleneck here is the bank, not the NBU.
In the euro area an ordinary transfer under the SEPA scheme has a deadline under Article 83(1) of PSD2 — Directive (EU) 2015/2366, consolidation of 17.01.2025: the amount is credited to the account of the payee's bank by the end of the next business day. That is not the same as “the money is with the payee”. The extra day for paper instructions is recorded in the second sentence of the same paragraph, not in a separate subparagraph.
In the same place are two limits that get forgotten: Article 78 allows a bank to set a cut-off time after which an instruction is deemed received on the next business day, and Article 82(2) — to extend the deadline by agreement, but to no more than four business days.
The system in which an ordinary transfer is settled is closed on Saturday and Sunday and on six more holidays a year. The consequence is simple: a transfer sent on Friday evening is credited on Monday, and before holidays later. The dates of the moving holidays are different every year.
An instant credit transfer knows no weekends. The standard is less than ten seconds, and this is an end-to-end deadline along the whole chain, from the moment the payer's bank receives the instruction, not the deadline of a single hop. This is Article 5a of Regulation № 260/2012 as amended by Regulation (EU) 2024/886: euro-area banks have been receiving such transfers since 9 January 2025 and sending them since 9 October 2025.
Two figures around instant credit transfers go around wrong. The hard timeout in the scheme rules is 7 seconds, not 20: the twenty are out of date. And the ceiling of €100,000 was removed not by Regulation № 260/2012 but by the scheme's own manager; there is no rule in the regulation prohibiting maximum amounts.
About the future briefly: as of 19.09.2026 PSD3 and the PSR have not been adopted, both procedures are awaiting the Council's position at first reading. The procedure numbers are 2023/0209(COD) and 2023/0210(COD); “2023/0367” and “2023/0368”, which turn up in publications, do not exist.
And the main caveat of the section: everything named above is regulatory ceilings and scheme standards, not measurements. No measured actual crediting time was to be found, either for an ordinary transfer or for an instant one — the ECB publishes volumes and shares, but not timings.
Of the shares one is known, and it has to be given with its period: for the second half of 2025 instant transfers made up 25% of euro-area credit transfers by number and 8% by value. The publication is dated 22.07.2026; there is no data for 2026.
Verification of Payee: the name must match
Article 5c of the same Regulation № 260/2012: from 9 October 2025 the payer's bank in the euro area is obliged to check the payee's name against their account number and to warn about a mismatch. The detail that usually gets missed: the rule applies to all credit transfers, not only instant ones, and free of charge (Article 5b(2)). Outside the euro area the obligation arises from 9 July 2027.
The everyday sense of it: if the payee's name at the bank differs from the one the sender wrote, it is the sender who will see the warning — before the money goes.
What is worth doing with this
For the payer — to fill in the reference so that it is clear what the money is for: the type of goods or service, not only an invoice number. How full it is, the payer decides, and it is the payer who answers for whether what is written matches the substance of the transaction too. This is not a formality but a distribution of responsibility.
For the payee — to keep the document that explains the incoming funds, and not to be surprised by a question about the payer. A transfer carries more data about the payer than about the payee: that is a property of the rule, not a suspicion about a particular person.
For both — to remember that meaningless text in the fields of a transfer is not “neutral”. For the bank it equals an absence of information, and a reference without an understandable purpose is an indicator in its own right. If a question has already arrived, how to build an answer is dealt with separately: what to do when the card has been blocked.
And what is deliberately absent here is advice on how to make sure no questions arise. The decision is taken by the bank. The rules can be known and complied with; the result cannot be guaranteed on their strength.
We are an exchange service: we exchange USDT for cash hryvnia and back, and the service does not make bank payouts in hryvnia. If that is exactly the exchange you need, here is the USDT to hryvnia direction — the terms and the procedure are described on the page itself.
Short answers
What should be written in the payment reference?
There is one rule — clause 41 of NBU Instruction № 163: full information about the payment and about the documents it goes on. In practice that is the type of goods or service, not only an invoice number: the absence of an understandable and clear purpose in the payments of a business entity is described in indicator 53 of Annex 20 to NBU Resolution № 65.
Is it mandatory to state the contract number and VAT?
Instruction № 163 does not require this: it is banking and contractual practice plus the needs of tax accounting. The format is prescribed only for a direct debit, an enforced debit and payments to the budget. If the contract number is asked for by a bank or a counterparty, that is their requirement, not an NBU rule.
Does the bank see that the money came from a company?
Yes. The payer's name and details travel in the transfer and are passed on unchanged, however many intermediaries there are in the chain — this is Article 40 of Law № 1591-IX. The bank needs no separate “legal entity marker”: the payer's name and the text of the reference are visible in the statement.
Why is there more data about the payer than about me as the payee?
That is how Article 14 of Law № 361-IX is built: the full set on the payer includes one more identifying feature beyond the name and the account number, and the set on the payee does not. The same principle is in Regulation 2023/1113. This is not an assessment of you but the construction of the rule.
