From the beginning of 2024, 01 of January, we have the changes of the local insurance legislation. The main goal of these changes to make the local Ukrainian insurance market more transparent and closer to the European legislative norms and procedures.
These changes may be divided for 3 main categories are the key changes for the customers, insurance companies and intermediaries (such as brokers and agents):
Transparency and Customer Protection at Forefront of Ukraine’s 2024 Insurance Overhaul
The list of insurance classes are now unified for all of the market and reduced from 50 to 23. The insurers updated their forms of the insurance policies, but the coverage, list of risks and exclusions remained the same. In every insurance policy the customer may see the name of insurance intermediary, by assistance of which the risk was placed. This is the requirement to the insurers to undertake the customer protection policy internally in the company. The insurance product, which is bought by the client is supposed to be clear and transparent for the local customer.
International and Local Insurers Navigate New Rules and War-Related Exclusions in Ukraine
The new requirements for insurance companies also came into force in 2024, the insurers have the updated requirements for solvency, min. authorized capital, management and ownership structure. The key functions of the insurance companies such as compliance policy, internal audit and underwriting are now also regulated by the new insurance law.
The main requirements the brokers and agents under new law are: obligatory insurance of professional liability, information about insurance products, partners, registration information should be placed on the website in local language. The professional qualifications, business reputation and experience of insurance intermediaries are also the norm of the new law.
The number on insurance companies we experienced to have 2 years ago has significantly decreased from 137 insures operating in 2022 to 60 insurers for October 2025. The reasons of such decline are the sanction policy (no Russian or Belorussian capital can operate now on the local market), changes of the insurance law.
War Drives Market Adaptation: Insurers Tackle Military Risks and Workforce Challenges in Ukraine
The war also leads to such trends as the shortage of the employees, the closure of the branches on occupied regions and affected areas, relocation of the employees within the country and abroad, mobilization of the employees.
The other important issue on the market except the change of the insurance law is the coverage of the military risks, which is still in the process of development despite some local solutions which are available on the market. This is not an easy question to provide the war risks coverage in the country where the war takes place, but the local market tries to find the solutions and what we have for now:
Some of the local insurers provide not very big limits of the self-retained capacities under both P&C and H&B lines. And we have already some examples of such policies, as well as the indemnity under military damages.
We have also some solutions to support investments, local population and local origin manufacturers.
Regional exclusions, such as occupied, active military zones, close for the Russian borders less then 100km is applied, as well as all the critical infrastructural objects all over Ukraine.
Additional Market Mechanisms
Lloyds market provides EUR 5–10M capacity per 1 location under PD, the coverage can be realized via one of the local insurers.
Among the solutions with the support of international investment funds regulated by international law aimed to provide guarantees for investments to Ukraine, local insurers have capacity from DFC (for PD), EBRD (for inland transit).
Among the other initiatives of the government on the local level, the insurer with the special status “Export Credit Agency” was created recent years which works with other export credit agencies in the other countries to support the Ukrainian origin manufacturers by providing the guarantees for the credit loans for export of their goods.
For H&B lines, usually military risks are excluded from the coverage and can be covered with certain limitations under health insurance policies and in a small limit per 1 person under life/pa insurance.
For the population, in Ukraine there are the solutions supported by the local authorities such as compensation for destroyed or damaged residential property in a result of the military aggression, as well as self-retained solutions provided by the local insurers.
Insurance Premiums in Ukraine Recover to Pre-War Levels Despite Ongoing Conflict
Among international insurers who are presented in Ukraine are such groups as Fairfax, presented by Colonnade, ARX and Universalna brands; UNIQA, VIG, Bulgarian Euroholding, Allianz and Metlife. All the others participants are local companies (INGO, TAS, VUSO), which also have good reputation on the local market.
Despite the martial law active in Ukraine, we may see the small growth of the market, up to the pre-war level in 2021. The premiums were critically decreased at the beginning of the war in 2022 and now by the results of 6 months of 2025 we may see the prewar results, in local currency we may see the growth of the premiums. The local market currently operates EUR 1.22 billion GWP (12 months of 2024).
Among other important points which we want to mention is that at the beginning of the war, we have certain restrictions for international payments from Ukraine, but starting from 2023 the list of critical import was expanded and among it the reinsurance payments were allowed to pay, as well as other obligations of the companies such as dividends for 2024, 2023 years.
All the pre-war type of insurance for both P&C and H&B are possible to place in Ukraine, with a certain adaptation to territorial exclusions for occupied and active military actions territories, critical activities and exclusion of military risks, despite the availability of certain solutions mentioned above.
Thank you, if you have any questions, please advise and we will share more information.