Execution of the NBU Administrative Expenditure Budget: Audit Results

The National Bank of Ukraine’s (NBU) budgeting process for 2023–2025 generally complied with the established requirements. However, compliance with budgetary discipline requires additional attention. These are the conclusions reached by the Accounting Chamber of Ukraine following the compliance audit "Execution of the Administrative Expenditure Budget of the National Bank of Ukraine." The audit report was approved at the Accounting Chamber's meeting on 28 July. The audit was led by the Chairwoman of the Accounting Chamber, Olha Pishchanska.

The Accounting Chamber conducted the audit of the execution of the National Bank of Ukraine's administrative expenditure budget in accordance with the requirements of the relevant legislation.

This is the first time that such an audit has been conducted in accordance with international standards, and its results will be officially published.

KEY AUDIT FINDINGS

The audit covered the period from 2023 to 2025 and aimed to assess whether the National Bank of Ukraine's budgeting process complied with the requirements of applicable legislation and internal regulations.

The audit found that, overall, the National Bank of Ukraine ensured proper planning, approval and execution of its administrative expenditure budget, as well as the implementation of investments in accordance with established requirements.

The auditors identified certain shortcomings in budget planning, the use of funds, implementation of investment projects, and specific aspects of remuneration. These issues did not affect the reliability of the presentation of expenditures in the NBU's financial reporting.

EXPENDITURE VOLUME

The NBU Administrative Expenditure Budget is an annual document that plans the expenditures and investments necessary for the operation of the National Bank of Ukraine as an institution. It covers personnel costs, administrative and operational expenses, remuneration of members of the NBU Council, as well as investments in the establishment and development of the Bank's material and technical infrastructure. The budget is prepared by the National Bank and approved by the NBU Council. The expenditures included in the budget represent only part of the National Bank's total expenditures reflected in its consolidated financial statements.

Over the three-year period, the NBU's actual administrative expenditures amounted to UAH 15.4 billion, while investments totalled UAH 1.6 billion.

Personnel costs accounted for the largest share of the budget – 79%, or UAH 12.1 billion.

Overall, during the audited period, the planned budget indicators were executed at 92% for expenditures and 73% for investments.

PERSONNEL AND REMUNERATION

During the three-year audit period, the actual number of employees in the NBU's central office increased by 114, from 3,324 to 3,439 employees. At the same time, the approved staffing establishment increased by 214 positions, while the monthly payroll fund increased by 60.4%.

In 2025, personnel costs amounted to UAH 4.98 billion, representing an increase of 27.8% compared to 2024 and 52.7% compared to 2023. Salaries and other employee benefits accounted for the largest share of these expenditures. Within the remuneration structure, 61.8% consisted of basic salaries and 22.9% of bonuses.

The audit confirmed that remuneration of the central office staff was paid within the limits of the approved NBU Budget and in accordance with the Bank's internal regulations.

SHORTCOMINGS IN BUDGET PLANNING

Although the administrative expenditure budget was generally executed properly, the auditors identified several instances of non-compliance with budgetary discipline.

In particular, 12 out of 51 requests to amend budget allocations, amounting to UAH 69.2 million, were submitted only after the funds had already been spent. This indicates insufficient control over the timely observance of budgetary discipline and expenditure management.

The auditors also found that, during the procurement of repair services for an administrative building, amendments to the NBU Budget were not introduced in due time. The 2025 Budget allocated only UAH 1 million for this project, whereas the estimated cost of the repairs amounted to UAH 10.6 million. Before the budget amendments were approved, the National Bank concluded a contract worth UAH 9.7 million and made an initial payment of UAH 1.44 million, exceeding the approved budget allocation at that time by UAH 440 thousand. The amendments to the NBU Budget were officially approved only in June 2025.

PLANNING AND IMPLEMENTATION OF INVESTMENTS

During 2023-2025, the National Bank allocated UAH 1.63 billion for the development of its material and technical infrastructure, including UAH 720.5 million for the central office and UAH 908.2 million for the Banknote Printing and Minting Works.

Investment planning and implementation generally complied with established requirements. However, of the 11 investment projects scheduled for completion in 2025 under the National Bank of Ukraine Strategy, four remained unfinished.

The Banknote Printing and Minting Works planned 13 investment projects without the financial and economic justifications and expert assessments of expected returns and

benefits required by internal regulations. A total of UAH 468.6 million was actually spent on these projects.

Furthermore, in 28% of investment requests submitted by the NBU central office, representing actual expenditures of UAH 29.7 million, the expert opinions lacked information on the expected costs and benefits.

Nearly one-third of the reports on investment projects implemented in 2025, covering UAH 34.4 million, did not contain information confirming that the projects had been completed.

The audit also confirmed the implementation of 11 contracts worth UAH 330 million and the publication of reports on their execution. However, for three contracts amounting to UAH 43.5 million, the deadlines for fulfilling contractual obligations were extended without sufficient documentary evidence supporting such decisions.

"The recommendations resulting from this audit focus on introducing effective controls, particularly over the proper justification and expert assessment of investment projects, planning of expenditures and investments in the Budget, updating the National Bank of Ukraine Strategy, and ensuring documentary evidence confirming the full implementation of investment projects," said Olha Pishchanska, Chairwoman of the Accounting Chamber, while presenting the audit results.

To address the identified shortcomings, the Accounting Chamber recommended that the National Bank of Ukraine:

· strengthen control over compliance with budgetary discipline throughout all stages of budget planning and execution;

· improve internal methodologies for reviewing management salaries and bring working time recording forms into compliance with applicable requirements;

· update the National Bank of Ukraine Strategy and align it with planned investment projects;

· improve procedures for planning, expert evaluation and monitoring the implementation of investment projects, particularly construction, reconstruction and repair projects.

Deputy Governor of the National Bank of Ukraine Yaroslav Matuzka, who attended the meeting, agreed with the recommendations provided by the Accounting Chamber following the audit.

The audit report and the Accounting Chamber's decision will be submitted to the Verkhovna Rada of Ukraine and the National Bank of Ukraine.