The cascade of windows 2026–2027: the digital euro, tokenised deposits and decision moments for Ukrainian public administration

Abstract

The article problematises the way in which Ukrainian public administration is responding to the European Union’s financial-sector regulatory decisions in the course of 2026–2027. The authors show that what is at stake is not a single integration “window” but a cascade of four windows with distinct deadlines: the closure of MiCA transitional regimes by 1 July 2026; the rollout of the European Digital Identity Wallet by December 2026; the expected adoption of the digital euro Regulation during 2026 with pilots in 2027–2028; and the continuous annual cycle of DORA with the recurring update of the list of critical ICT third-party providers. The article puts forward the concept of “asymmetric regulatory import” – a condition in which the Ukrainian financial sector is in everyday practice subjected to European requirements (through cloud providers, correspondent relations and access to SWIFT-equivalent rails) without formal membership and without representation in the European discussions concerned. Drawing on the practice of private banking in Luxembourg and on the legal construction of equivalence regimes, the article outlines a model of a sequence of Ukrainian normative decisions – from the SEPA package endorsed by the Cabinet of Ministers on
17 December 2025 to DORA-compatible standards of the National Bank of Ukraine – and demonstrates that this sequence is a natural substantive filling of the political formula “before, not instead of”, articulated in the Ukrainian expert debate of spring 2026