How many days you actually have
The general settlement deadline for Ukrainian export and import operations in 2026 is 180 calendar days. That is the number people quote, and for most operations it is correct.
For some goods it is wrong.
Part of agricultural output runs to 150 days for operations from 1 July 2026. Pipes and rail-transport components — customs codes 7304, 7305, 7306 and 8607 — run the other way, to 270 days for operations carried out from 15 June 2026.
So the deadline is set by two variables at once: the goods code and the operation date. Two contracts signed in the same week on different items can carry different deadlines, and a contract signed before a rule change lives under the old one.
The practical consequence is blunt. "What is our deadline" has no answer without a customs code and a date, and any confident answer to it is a guess.
What a delay costs
The penalty is 0.3% of the uncollected amount per day of delay, capped at 100% of that amount.
On a UAH 1,000,000 contract where the proceeds never arrive:
| Delay | Penalty |
|---|---|
| 30 days | UAH 90,000 |
| 90 days | UAH 270,000 |
| 334 days | UAH 1,000,000 — cap reached |
After that it stops growing, which is thin comfort: by then the sanction equals the whole contract.
When no penalty accrues at all
There is a threshold that gets less attention than it deserves. No penalty accrues on the outstanding amount of an incomplete operation if, at the date it arose, that amount is below UAH 400,000 — provided there are no signs of operations being split.
The second half of that condition matters more than the first. Breaking one contract into several small ones so each falls under the threshold is precisely what "signs of splitting" means. The rule exists so that a small residual is not punished, not as a structuring tool.
Three ways to pause the clock
All three work, at different prices and different levels of reliability.
A court claim. Acceptance of the claim suspends both the deadline and the accrual of penalty for the duration of proceedings. Here is the part that rarely gets explained: if the court refuses to open proceedings, or dismisses the claim in whole or in part, the deadline resumes and the penalty accrues for every day of delay — including the period during which it was suspended. A lost claim does not reduce the sanction, it defers it.
Force majeure. Requires documentary confirmation from an authorised body. Certificates are not issued on request, and the time to obtain one can consume the remaining runway by itself.
An extension via the Ministry of Economy. Available for an exhaustive list of operations. If yours is not on the list, no amount of justification opens the mechanism.
Our position: using a court claim to buy time is the worst of the three when the claim is weak. The risk of the penalty returning retroactively usually outweighs the value of the pause. If the claim is strong and you were heading to court anyway, the argument does not apply.
Before signing
- The customs code for every line item, written down rather than "somewhere in the specification".
- The deadline for each code as at the date of the intended operation.
- The date the clock starts, stated unambiguously in the contract.
- The buyer's payment terms reconciled against that deadline, with slack rather than to the day.
- Whether any likely residual falls under the UAH 400,000 threshold.
- Who inside the company owns the date. If nobody does, the owner does and has not been told yet.
This describes the position as at 15 September 2026. Deadlines and code lists change through National Bank resolutions during the year; check the current wording before signing.