I. Why this post exists now
The last post here ended on a claim I still hold: the market sets the price of money, and the regulator mostly accompanies it. This one is the uncomfortable sequel, because the market only does that where it is let in.
The premise I have grown tired of arguing – in seminars, in valuation reviews, in conversations with people who build discount rates for a living – is that the risk-free rate is a lookup. Find the currency, take the number, move on. The canon appears to license exactly that: under Aswath Damodaran, the local-currency risk-free rate is the government bond yield minus the sovereign’s default spread, while the base for the dollar and the euro comes from US and German government bonds. The whole construction hangs on one unstated word – can. It assumes an investor who can actually buy the instrument being quoted. For a Ukrainian institution today, neither US Treasuries nor German Bunds are within reach, so the international table describes somebody else’s choice rather than theirs.
What made me write this up rather than grumble about it again was the September issue of the risk-free rates CIRA publishes monthly. Two definitions sit on that page for the hryvnia, and this month they moved apart – 8.7 % against 9.2 %. The temptation is to treat the gap as noise and average it away. It is not noise. It is the shape of the problem.
The stake is not cosmetic. The risk-free rate is the first term of every other rate in the model: the cost of equity is that rate plus the equity risk premium and the country risk premium; the cost of debt is that rate plus the borrower’s credit spread. One percentage point of error at the base moves a company’s valuation by 5–20 %, depending on the level of rates and the growth rate. It is the single number in a DCF that people are least willing to argue about and least able to observe.
II. The identity everyone quotes is a result, not a definition
The theory itself is remarkably clean. A risk-free rate has only two components: a real reward for postponing consumption – the time premium – and compensation for the inflation of the currency the rate is quoted in. Inflation belongs to each currency alone; the time premium is roughly the same everywhere. Hence the textbook sentence that every valuation course repeats: the difference between the risk-free rates of two currencies is, in essence, the difference in their inflation rates, so a rate in one currency converts into another through the inflation differential.
The question usually skipped at that point is why the time premium should be roughly the same everywhere. It is not an axiom. It is an equilibrium, and the machine that produces it is arbitrage – a process that looks entirely mundane. A fund with dollar liquidity sees paper in another currency where the real reward over the same horizon is higher, and moves money there; its buying lifts the price of that paper and pushes the yield down. The reverse case is the mirror image. No single trade equalises anything. What equalises is the flow of such trades, and that flow compresses the difference in time premia for as long as the move still pays, leaving mostly the difference in inflation between the currencies.
So the identity that opens every textbook calculation is not a definition at all. It is an equilibrium result, and it holds for exactly as long as arbitrage can run. Communicating vessels equalise not because the vessels are alike but because liquid flows between them, and that flow is arbitrage. Shut the tap, and the levels diverge in every vessel, whatever the formula says.
III. Where the tap is shut
In Ukraine the tap is shut by regulation. The wartime currency regime rests on Resolution No. 18 of the Board of the National Bank of Ukraine of 24.02.2022, whose paragraph 14 permits cross-border transfers of currency values out of Ukraine only for a defined list of operations – everything is prohibited except what is permitted – and the purchase of foreign securities is not on that list now either.
The August easing is worth stating precisely, because it is easy to overstate and I have seen it overstated. Resolution No. 90 of 10.08.2026, in force since 11.08.2026, did not widen the paragraph 14 list. It added a separate paragraph 12, index 19, under which a bank may sell securities of foreign issuers to its own individual client, delivered inside Ukraine’s depository system, within a combined UAH 200,000 per calendar month at one bank – a limit shared with non-cash currency and bank metals. Under that construction no money crosses the border, and a transfer to an account with a broker abroad remains outside paragraph 14. The easing happens inside the circuit rather than through its wall.
The closure is older than the war, which is the part most commentary misses. Ukraine’s normalised Chinn–Ito index of capital-account openness – zero for a fully closed capital account, one for a fully free one – has read 0.000 at every annual observation since 2009, the latest available being 2023. The wartime regime sealed a circuit that was already closed; it did not create it.
The closure is also visible outside the regulatory text. The exit queue on restricted operations runs at around USD 47bn for 2026–2027 on the NBU’s own estimate, roughly USD 19bn of it already past due. Against that queue, USD 707m has actually been used out of the USD 1,271m of limits set for new money. This is no rebuke to the regulator: any protective regime has a price, and the price here has been counted – a CIRA study published on 27 July 2026 puts the contribution of the restrictions themselves over 2022–2025 at roughly USD 9–10bn. The arbitrageur who ought to equalise the time premia does not take the trade. Not because he cannot see the difference, but because a transfer of that size will not go through.
Picture 1. The closed circuit in three views: the non-resident share in domestic government bonds (OVDP) at three published observations, from 15.9 % at its February 2020 peak to 0.9 % at the end of June 2026; the exit queue set against the outflow the regime actually permits; and Ukraine at the closed end of the capital-account openness scale. Each indicator on its own is a detail of the regime; together they mark the boundary of a separate financial ecosystem, and inside that boundary the risk-free rate has to be built rather than imported.
With arbitrage switched off, the circuit becomes exactly that – a separate ecosystem. About a third of the hryvnia segment of domestic debt, UAH 656bn out of UAH 1,834bn, is held by the NBU itself. Neither Treasuries nor Bunds are within reach of capital locked inside, and a foreign-currency deposit at a Ukrainian bank or a foreign-currency government bond carries a different, Ukrainian risk. So in every currency of the circuit the rate stops being a single object.
Regimes like this are introduced as temporary, and the comparative record is short: Cyprus held one for 24 months, Greece for 50, Argentina for 67, Iceland and Nigeria for about 100. Ukraine’s has run for 53 months as at July 2026 – already longer than the whole Greek episode. As a researcher I find the case unusually interesting, because theory rarely gets to watch what happens to its most basic constant once the mechanism that keeps it constant is removed. But the tap here was shut by a war, not for an experiment: what interests me is the phenomenon, not its cause, and no experiment is worth that price. For those working inside the circuit the choice is not between studying it and ignoring it. It is between measuring and guessing.
IV. Two definitions, and why I would not pick one
The first definition is the international view, on a ten-year horizon: what the hryvnia rate would be if arbitrage were working. The dollar risk-free rate is the yield on ten-year Treasuries minus the US CDS spread (the market price of insurance against a US default), because the United States no longer carries an Aaa/AAA rating and Treasuries are therefore only quasi-risk-free. In the September issue, 4.73 % minus 0.33 p.p. gives 4.40 %, shown in the summary table as 4.4 %. The euro needs no subtraction, since ten-year Bunds are rated Aaa/AAA: 3.32 %, shown as 3.3 % – a rate in its own right for euro cash flows, not a second base for the hryvnia. The Fisher relation then carries the dollar rate into hryvnia through actual year-on-year inflation in both currencies for July 2026 – 7.7 % against 3.4 % – and lands us at 8.74 %, shown as 8.7 %. Actual rather than expected inflation is a deliberate choice: an observed number leaves no room for assumptions nobody can audit. This route openly borrows the identity that arbitrage produces beyond the circuit, which is precisely why it can anchor a long horizon.
The second definition never leaves the circuit. The nearest things to a risk-free instrument inside it are hryvnia government bonds from the Ministry of Finance’s primary auctions – but the sovereign is not default-free even in its own currency, so we deduct the credit spread implied by its local-currency rating from S&P and Fitch, taken from the default-spread ladder Damodaran publishes. That is a rating-based figure from outside CIRA, not a CIRA judgement on the sovereign’s creditworthiness, and the national rating scale plays no part in it. At the auction of 25.08.2026 the weighted average yield on the 329-day issue was 15.17 %; deduct a spread of 5.97 % and we have 9.20 %, shown as 9.2 %. It is a computed anchor, not a yield anyone can buy.
Two objects, then, not one rate computed two ways. This month they sit 0.5 p.p. apart. A month ago the distance was 0.1 p.p., and that near-coincidence confirmed nothing – current annual macro conditions simply happened to meet. What moved over the month is worth naming, because it was not the market: the deducted sovereign spread was reset from 6.37 % to 5.97 % in a new edition of the published ladder, while the yield on the one-year issue itself shifted by 0.02 p.p. A gap is more informative than a coincidence, but only over a longer series, and only if you remember which input moves it. The derivation travels with the inflation differential; the internal point travels with the government bond market.
Picture 2. Two routes to the hryvnia risk-free rate, each with its own inputs and its own horizon: on the left, from the dollar rate through the inflation differential over ten years; on the right, from the government bond yield at the auction of 25.08.2026 through the deducted sovereign credit spread, at about a year.
Every step is a choice, and each one is worth showing rather than assuming. The benchmark is the one-year point because it is the shortest clean market point on the curve. And each month the result is checked against an independent bottom-up estimate, built the same way the theory is: inflation plus the real reward for waiting, approximated by real growth. On actual data that gives 7.7 % plus 0.6 %, or 8.3 %, against the market’s 9.20 % – a divergence of 0.9 p.p. Run the same estimate on household inflation expectations instead, 9.95 % over twelve months in the NBU’s July survey, and it rises to roughly 10.5 %. Showing only the check that agreed would pass a choice of input off as the absence of one. The gap itself measures how much future disinflation the government bond market has already priced in and the household survey has not. It is a check, not a standalone estimate.
V. Where the curve ends
Beyond the one-year point the internal curve offers two further clean points: 9.7 % at 658 days and 10.5 % at 1,274 days. There, at about 3.5 years, it ends. That second figure carries the same digits as the forward-looking cross-check two paragraphs above, and the two are different objects entirely: one is a point on a curve of accepted auction bids, the other a macro reconciliation. A line cannot be extended into territory where no clean market point exists, and stretching the internal rate to ten years would pass invention off as observation.
Picture 3. The internal hryvnia curve across the maturities that actually exist, and the emptiness beyond them, set against the ten-year international derivation.
VI. The two objections, and the limits I keep
The first objection I get from an attentive reader is that country risk has been counted twice – deducted from the risk-free rate and then added back as a premium. It has not. The deducted spread returns as a separate term: the country risk premium in the cost of equity, the sovereign credit spread in the cost of debt. On the debt side the subtraction and the addition cancel exactly, reproducing the observed yield. Country risk is counted once; what changes is that it is now visible as its own line rather than buried in a base rate.
The second objection is sharper, and it is the one that makes people uncomfortable: the internal rate sits below the NBU’s key policy rate of 15.5 %, in force since 31.07.2026. There is no absurdity in that. It is the shadow yield of a hypothetical default-free hryvnia issuer, not a rate at which anyone places money. Even one-year government paper is placed below the key rate – 15.17 % against 15.5 % at the primary auction, a weighted average of accepted bids rather than a secondary-market print – which is itself another reading of a closed circuit carrying more hryvnia liquidity than it can lend out.
The limits belong in the open, because on a page like this they are part of the product rather than a footnote to it. The credit spread is rating-based rather than market-traded, from a ladder calibrated on long-dated dollar instruments, so for a one-year hryvnia point neither the maturity nor the currency matches, and the direction of the resulting bias is unknown. The international derivation rests on the current rather than the long-run inflation differential, and the dollar rate is overstated by roughly 0.1 p.p., because a monthly cycle uses the five-year US CDS where the canon would use the ten-year one. The most important limit is not methodological but temporal: the split into two definitions holds for exactly as long as the wartime regime does. It is a property of the regime, not of the hryvnia.
VII. What I’d say now
The conclusion is unsatisfying for anyone who wants one number, and more honest for that reason. For me, two numbers side by side are not a confession of uncertainty; they are an accurate description of a country where capital inside and capital outside live under different rules, and where reconstruction will be financed by both at once. Anyone discounting a cash flow is entitled to see what the rate doing the discounting is made of, and which of the two worlds it belongs to. A valuation that hides that choice inside a single imported figure is not more precise than one that shows it – it is only quieter about being wrong.
The vessels remain connected by design, and one day the tap will be opened. Arbitrage will flow again and pull the levels back together on its own, without any tables of ours. Until then, the level in each vessel has to be measured separately – and measuring it is still the cheaper of the two available options.
