Yes, and in many cases this can be a good option for both the borrower and the MFO.
The modern online-lending market has long moved away from the "pay or face collectors" model. Financial companies often find it more beneficial to restructure the repayment schedule than to spend months on court proceedings, collection, and problem debt.
That is why restructuring is now one of the key tools for resolving debt in a structured and civilized way.
Legal Framework: What the Law Says
Debt restructuring in Ukraine is governed by specific provisions of Law No. 1734-VIII "On Consumer Lending," taking into account special provisions introduced for the period of martial law.
Restructuring as a change to material agreement terms is based on the following provisions:
Law No. 1734-VIII "On Consumer Lending," Article 17, "Restructuring of Obligations Under a Consumer Credit Agreement"
zakon.rada.gov.ua/laws/show/1734-19
The lender has the right, by agreement with the consumer, to restructure obligations under a consumer credit agreement — that is, to change material terms affecting the conditions and/or procedure for repayment of the loan.
Law No. 1734-VIII, Article 12, Part 7
Changes to the agreement terms are possible only with the consent of the parties. A clause allowing unilateral changes is void.
Civil Code of Ukraine, Article 651
zakon.rada.gov.ua/laws/show/435-15
Contractual terms may be updated by agreement of both parties when circumstances change materially.
Separate protection mechanisms are also provided: Law No. 1734-VIII, Article 17
What Is Restructuring?
Restructuring is a revision of the loan terms intended to reduce the borrower's financial burden.
Unlike an extension, which simply prolongs the loan for several days or weeks, restructuring changes the structure of the debt itself.
Restructuring may allow you to:
- Extend the repayment term
- Reduce the monthly payment
- Write off part of the fines or penalties
- Fix the debt amount without further interest accrual
- Revise the interest rate
Three Restructuring Scenarios
1. Standard Restructuring (for Most Borrowers)
In a standard situation, an MFO is not required to agree to changes in the loan terms. In practice, however, many companies are willing to work with clients, especially when they see a genuine effort to resolve the problem.
Your chances of obtaining restructuring are higher when:
- You contacted the lender before a significant overdue balance developed
- You explained the reason for your financial difficulties
- You have supporting documents (proof of job loss, illness, etc.)
- You stay in contact and do not ignore the lender
- You make partial payments or propose a repayment schedule you can realistically follow
The MFO is more likely to refuse when:
- The debt has already been overdue for months
- You have not communicated with the company
- There have been numerous extensions without repayment
- The company has already transferred the debt to collectors or taken the matter to court
2. Mandatory Restructuring (Limited Cases)
The law provides a mandatory restructuring mechanism that may be initiated by the borrower only for certain categories of loans concluded before February 24, 2022.
It should be noted that the mandatory restructuring mechanism does not apply to standard online MFO loans and is used only in certain specific cases.
This right may be exercised only when all legally specified conditions are met and only by certain categories of persons:
- Residents of territories where hostilities are or were taking place
- Residents of temporarily occupied territories
- People who were forced to leave the above-mentioned territories
Conditions for Loans Eligible for Mandatory Restructuring
| Condition | Explanation |
|---|---|
| Loan type | Consumer loan |
| Debt status | No final court decision |
| Date of agreement | Before February 24, 2022 |
| Borrower category | Resident of a combat zone / temporarily occupied territory / IDP |
How Mandatory Restructuring Works
Terms under the law:
- The debt may be divided into equal payments over a period determined as a result of the restructuring
- The rate may not exceed the NBU's maximum limits
- Excess interest and penalties are subject to write-off
Important: these mechanisms generally operate through individual settlement rather than automatic write-off or guaranteed restructuring based solely on a person's status. The borrower should stay in contact with the lender, submit the relevant request in writing or electronically, and support the circumstances with documents.
3. Special Conditions for Protected Categories of Borrowers
A special protection regime applies to military personnel, their family members, persons in captivity, and missing persons (Clause 6-2 of Section IV of Law No. 1734-VIII).
It provides for:
- Restriction or termination of interaction with lenders and collection companies after the relevant notice
- An enhanced level of legal protection when settling the debt
This means that during martial law an MFO and collectors may not contact a military service member with demands if the service member or family members have submitted the relevant application.
At the same time, belonging to a protected category does not itself release the borrower from the obligation to repay the loan principal.
If you are a military service member, you have a legal right not to pay interest on the loan (Law of Ukraine "On Social and Legal Protection of Military Personnel and Their Families," Article 14, Clause 15: zakon.rada.gov.ua/laws/show/2011-12), after providing the financial institution with the relevant certificate.
You may also ask the MFO to stop any demands and reminders concerning the debt during martial law (Clause 6-2 of Section IV of Law No. 1734-VIII).
Can Military Personnel Obtain Restructuring?
Yes, military personnel may obtain restructuring:
- Based on an individual agreement with a bank / MFO
- Under internal programs of financial institutions
Important: there is no provision requiring a lender to automatically restructure a military service member's debt. However, many banks and MFOs have programs for military personnel and are willing to accommodate this category of borrowers.
How to Request Restructuring Properly
1. Do Not Delay
The best time to negotiate is before a significant overdue balance develops.
After 30+ days overdue, an MFO may initiate early termination of the agreement and demand full repayment of the debt, except in cases specified by law.
2. Submit an Official Request
A phone conversation is not a legally significant formal request.
It is better to submit the request via:
- personal account
- registered letter
What to include in the request:
- Full name and agreement number
- Reason for the financial difficulties
- Requested restructuring terms
You may also attach supporting documents that could positively affect the MFO's restructuring decision.
Examples of Supporting Documents
| Category | Supporting Document |
|---|---|
| IDP | IDP certificate |
| War veterans | Relevant certificate / ID |
| Persons with war-related disabilities | Relevant certificate / ID |
| Large families | Documents confirming support of 3+ children under 18 |
| Families of fallen military personnel | Death certificate and relevant certificate / ID of the deceased |
| Military personnel in a combat zone | Certificate from the military unit |
3. Document the Request and All Communication
Keep:
- Screenshots
- Email confirmations
- SMS
- Registered-letter tracking number
4. Sign a New Credit Agreement or an Addendum
All new lending terms must be recorded in a new agreement or properly executed addendum — oral agreements have no legal force.
What New Terms an MFO May Agree to During Restructuring
| Terms | How Realistic It Is |
|---|---|
| Reduction of monthly payment | Often |
| Extension of the term | Very often |
| Payment holiday | Sometimes, for 1–3 months |
| Partial write-off of penalties | Often by agreement |
| Fixing the debt without new interest | Possible |
| Full write-off of the principal | Extremely rare, in special cases |
What to Check Before Signing a New Agreement
- Whether any new fees have been added
- Whether penalties exceed the legal limit
- Whether the final debt amount is fixed
Important: a smaller payment does not mean a cheaper loan.
This is one of the most common financial "psychological traps" in restructuring.
Example: Changing the Repayment Schedule Without Reducing the Rate
Debt: UAH 10,000
Rate: 1% per day
Without restructuring — 30 days
Overpayment: 10,000 × 0.01 × 30 = UAH 3,000
Total: UAH 13,000
After restructuring — 90 days
Overpayment: 10,000 × 0.01 × 90 = UAH 9,000
Total: UAH 19,000
Tip from iPay.ua: restructuring often makes the immediate payment easier but may increase the total overpayment over the longer term. Therefore, assess not only the new monthly payment but also the full final amount to be repaid.
If the MFO Refuses Restructuring
Restructuring is not an automatic right for all borrowers. For standard clients, an MFO may refuse without providing reasons.
Your options after a refusal depend on your situation.
1. What to Do After a Refusal If You Are a Standard Borrower
| Option | Description |
|---|---|
| Refinancing | Take out a new loan to repay the current one |
| Financial adviser | Assess the debt burden and optimization options |
| Personal bankruptcy | Legal procedure for debt write-off / restructuring |
2. What to Do After a Refusal If You Have a Legal Right to Mandatory Restructuring
| Action | Where to Contact |
|---|---|
| File a complaint against the MFO | NBU: bank.gov.ua/consumer-protection |
| File a claim for mandatory restructuring | Court (without court fee) |
| Contact the prosecutor's office | In cases of systemic violations |
Reminder: the right to mandatory restructuring applies only to certain consumer loans and only when all of the following conditions are met:
- The loan was concluded before February 24, 2022
- There is no final court decision on collection
- There is no completed enforcement proceeding (depending on the situation)
- The loan is unsecured
- The borrower lives or lived in a combat zone (or temporarily occupied territory) or was forced to leave it
This mechanism is highly specialized and applies only in cases clearly defined by law. In each individual situation, eligibility depends on the combination of legal circumstances and supporting documents.
If you are unsure whether your loan qualifies for mandatory restructuring under the law, it is advisable to seek individual legal advice from a specialist.