- Block your card — they cannot
- Debit funds — only in cases clearly defined by law
1. Card Blocking: Who Actually Has This Right
An MFO cannot block your card at all. The company does not even have access to your card's payment infrastructure.
Under Law No. 1591-IX "On Payment Services" (Article 60, zakon.rada.gov.ua/laws/show/1591-20), only the issuing bank (your bank) has the right to block or restrict use of the card.
Important: If you are told "we will block your card," this is a pressure tactic that may indicate psychological pressure, manipulation, and a potential legal violation. Such statements may be grounds for a complaint to the NBU.
2. Debiting Funds: Three Possible Scenarios
Scenario A — debit with your consent (authorization)
This is the most common scenario in MFO microcredit lending.
When taking out a loan, you may agree to automatic debiting (direct debit from the account) when the payment due date arrives.
Important: A debit without additional confirmation is possible only if prior consent was provided (Law No. 1591-IX "On Payment Services," Article 32: zakon.rada.gov.ua/laws/show/1591-20).
All repayment terms (including automatic debit) must be clearly stated before the agreement is signed (Law No. 1734-VIII "On Consumer Lending," Article 12, Part 1: zakon.rada.gov.ua/laws/show/1734-19).
How it works:
- You signed the agreement
- You agreed to automatic debit
- On the payment date, funds are debited automatically
This is legal, but only if you agreed to it ("authorization" in the agreement).
Scenario B — debit through a court enforcement process
If there is a court decision, funds may be collected compulsorily.
Under Law No. 1404-VIII "On Enforcement Proceedings" (Article 48: zakon.rada.gov.ua/laws/show/1404-19), after enforcement proceedings are opened, the enforcement officer may freeze accounts and collect funds through the bank.
What may be debited:
- Personal funds in accounts
- Part of salary (usually up to 20%)
- Pension payments (within legal limits)
What is protected by law (Article 73 of Law No. 1404-VIII):
- Social benefits
- Assistance for internally displaced persons (IDPs)
- Alimony
- Disability benefits
- State assistance for children
- Combat-related payments to military personnel
Scenario C — unlawful debit without consent or a court decision
This is a serious violation, and you have the right to complain to the regulator about such actions by an MFO.
Law No. 1591-IX "On Payment Services" (Articles 32 and 60: zakon.rada.gov.ua/laws/show/1591-20) provides that unauthorized debits are unlawful payment transactions. The bank must challenge them and return the funds. Under Law No. 1023-XII "On Consumer Protection" (Article 19: zakon.rada.gov.ua/laws/show/1023-12), such actions may also qualify as an unfair business practice.
What to Do If an MFO or Collectors Threaten to Block Your Card
| Action | Where to Contact |
|---|---|
| Complaint to the NBU about threats and psychological pressure | NBU: bank.gov.ua/consumer-protection |
| Complaint about violations by collectors | Police: 102 |
| Claim for moral damages (without court fee) | Court |
What to Do If Funds Were Debited Without Your Consent
- Dispute the transaction with the bank — you can submit a refund request within 60 days
- File a complaint with the NBU — via the official portal bank.gov.ua/consumer-protection
- Go to court. The claimant does not pay a court fee in consumer-protection disputes.
How to Disable Automatic Debiting
Under Law No. 1591-IX "On Payment Services" (Article 60: zakon.rada.gov.ua/laws/show/1591-20), you may withdraw your consent to automatic debiting at any time.
How to do this:
- Submit the relevant request to the bank
- Use the bank's mobile app (if this function is available)
- Call the bank's hotline