The National Bank of Ukraine has published for the first time a list of significant insurers as of January 1, 2026. It includes 13 companies — 11 non-life and two life insurers. This is the first such registry in the history of Ukrainian insurance supervision.

What does "significant" mean and why it's not about reputation

The criteria are simple and quantitative. A non-life insurance company enters the list if the average annual volume of premiums from the population over the last three years exceeded 1 billion hryvnias. For life insurers, the threshold is different — average technical reserves exceeding 2 billion hryvnias. The NBU enshrined these criteria in Resolution No. 194 from December 2023, with the first calculation scheduled for January 1, 2026.

An important nuance: the status becomes effective from the date of meeting the criteria — that is, from January 1, 2026 — not from the moment of the NBU registry publication. This means the countdown for compliance deadlines has already begun.

What these 13 companies are now obligated to do

Enhanced corporate governance requirements are being introduced for significant insurers. The main requirement is the mandatory establishment of a supervisory board with independent directors. Additionally, companies must establish a full-fledged risk management system, internal audit, and compliance with dedicated departments and key persons subject to NBU oversight.

"Significant insurers, identified as such as of 01.01.2026, are obligated by 31.12.2026 to bring their activities into compliance with enhanced requirements"

From NBU clarifications on the application of Resolution No. 194

For comparison: in the banking sector, such differentiation between "significant" and other market participants has existed for a long time — the NBU applies different supervision modes to them, including more frequent stress tests and stricter capital requirements. The insurance market is following this path with a delay of several years.

Context: market growth, but concentration

According to preliminary data from Forinsurer magazine, in 2025 total gross insurance premiums in Ukraine grew by 43% — to 53 billion hryvnias, despite the war. At the same time, the number of players is shrinking: companies are leaving the market due to license cancellations and non-compliance with new regulatory requirements.

Thirteen significant companies represent less than 10% of the total number of insurers on the market, yet they accumulate the lion's share of collected premiums. Concentration makes corporate governance in these companies not just an internal matter but a systemic one: a failure in any of them could damage confidence in the market as a whole.

• Deadline: December 31, 2026 — bringing activities into compliance with enhanced requirements
• Key requirement: supervisory board with independent directors
• Regulator: The NBU supervises key persons — auditor, compliance manager, risk manager, actuary
• Legal basis: NBU Resolution No. 194 of December 27, 2023

Independent directors on supervisory boards — an element that looks like protection against conflicts of interest on paper, but in practice depends on who and how verifies their actual independence. If by the end of 2026 the NBU does not publish a mechanism for verifying the independence of directors and does not apply any sanctions to those who formally complied with the requirement — will management in these companies actually change, or only in form?