Banks’ “War-Related” Losses: The Deposit Insurance Fund Submitted Documents to the International Register of Losses

24 June 17:12

The Deposit Guarantee Fund for Individuals has begun submitting materials to the International Register of Losses for Ukraine. These materials pertain to the losses incurred by banks being forced out of the market and their creditors as a result of the full-scale war unleashed by Russia. The agency reports this, according to "Komersant Ukrainian".

The agency notes that the Registry was established in 2023 to record claims for compensation for losses, damages, or harm caused by Russian military aggression in or against Ukraine.

“This is the first step toward the practical implementation of an international compensation mechanism, which will subsequently involve reviewing and evaluating such claims from affected individuals, determining the amount of damages, and awarding compensation,” the statement reads.

The acceptance of applications from legal entities for inclusion in the Registry began in late April 2026, after which the Deposit Guarantee Fund initiated the transfer of relevant documents regarding the losses of banks that are being or have been withdrawn from the market.

“According to our estimates, the total ‘war-related’ losses of banks being phased out of the market by the Fund during the full-scale war have reached 17 billion hryvnias. As hostilities continue, the losses keep growing. These losses consist primarily of destroyed real estate and other damaged property, but there is also a category of assets such as loans to borrowers registered in currently occupied territories or in the combat zone, as well as lost collateral, etc.,” said Viktor Novikov, Deputy Director-Administrator of the Fund.

According to the statement, in particular, the Deposit Guarantee Fund ensured the submission to the Registry of materials regarding the destruction of part of the real estate owned by PJSC “PROMINVESTBANK,” which was transferred to the State of Ukraine after the start of the full-scale invasion.

“In addition to seeking compensation for losses incurred during the full-scale war, the Deposit Guarantee Fund is also fighting to recover from the aggressor country the losses it has caused since 2014. The Fund has filed a series of lawsuits against the aggressor country for such losses and is currently preparing new ones,” the statement reads.

According to the statement, to date, the DGF has received final, enforceable court rulings in its favor on four such lawsuits:

  • the decision of the Kyiv Commercial Court dated January 23, 2024, in the case of PJSC “KB “UFS” for over 1.9 billion UAH (Case No. 910/7444/23),
  • a ruling by the Kyiv Commercial Court dated July 17, 2025, for a total of 498.5 million UAH in a class-action lawsuit involving five banks: PJSC “GREEN BANK,” PJSC “ERDE BANK,” PJSC “UKRGASPROMBANK,” PJSC “BANK “TAVRIKA,” and PJSC “FORTUNA-BANK” (Case No. 910/731/25),
  • the decision of the Kyiv Commercial Court dated December 23, 2025, on the recovery of damages caused to PJSC “Promekonombank” in the amount of 651.0 million UAH (Case No. 910/8847/23),
  • the decision of the Kyiv Commercial Court dated February 25, 2026, regarding losses incurred by PJSC “VTB Bank” in the amount of over 3.1 billion UAH (Case No. 910/14761/25).

According to a preliminary estimate by the Deposit Guarantee Fund, as a result of Russia’s aggression in 2014–2022, the losses of the banks transferred to the Fund’s management amount to over 84 billion UAH.

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What the Registry Does

The Registry is designed to record all admissible claims for compensation for losses, damages, or harm caused as a result of the Russian Federation’s aggression in Ukraine or against Ukraine.

The Registry will operate exclusively with electronic documents and will use a secure digital platform to receive, process, and classify claims and evidence. The process of submitting claims—exclusively in electronic form—will be as simple and streamlined as possible.

In order for a claim to be entered into the Registry, it must meet three simple admissibility criteria set forth in the Registry’s Statute. Claims must be filed regarding damages, losses, or harm caused:

  • on or after February 24, 2022;
  • on the territory of Ukraine within its internationally recognized borders, including territorial waters;
  • by internationally wrongful acts of the Russian Federation in Ukraine or against Ukraine.

The Register’s primary task is to receive and process claims and related evidence. This includes categorizing, classifying, and systematizing these claims based on various criteria. The Registry, through the work of the Registry Council, will evaluate claims and determine their compliance with the established criteria. Acceptable claims will be registered in the Registry for further consideration and evaluation.

The procedures for submitting, processing, and entering applications will be governed by various rules and regulations, which are currently being developed. These will include a list of application categories, application forms, evidence requirements specified for each category of application, and other necessary information.

Applicants submit applications through the Ukrainian web portal “Diya,” designed to provide public services in Ukraine. This approach ensures a simplified and accessible way to submit applications to the Registry.

What the Registry Does Not Do

The Register of Damages will not review or evaluate the substance of the claims received, nor will it determine the amount of damages or award any payments.

These will be the functions of a future international compensation mechanism, which will be established as a separate international instrument. The Registry is only the first step toward such a mechanism.

Work on establishing the compensation mechanism is ongoing. The Registry’s mandate includes facilitating and actively participating in ongoing efforts to establish the compensation mechanism.

As the compensation mechanism is developed, the Registry will continue to support the implementation of this global initiative aimed at ensuring comprehensive accountability by gathering information about what happened in Ukraine. Once the compensation mechanism is established, the Registry’s work will continue within a new framework, to which all claims and supporting evidence will be transferred.

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