Across most of the European Union, the NIS2 Directive has already become operational reality. Bulgaria’s path to transposition, however, has been materially delayed. The Cybersecurity Act amendments intended to implement the NIS2 Directive were first submitted to the Parliament in September 2024, passed at first reading in February 2025 and reached final adoption in February 2026, with the new framework entering into force on 17 February 2026. This delay has consequences that go beyond the mere legal uncertainty. While Bulgaria was still preparing its implementation framework, in January 2026 the European Commission proposed a new EU cybersecurity package, including amendments to the NIS2 Directive and a draft Regulation
Directive (EU) 2024/927, commonly referred to as AIFMD II, marks the most significant reform of the Alternative Investment Fund Managers Directive (AIFMD) since its original adoption in 2011. Member States are required to transpose AIFMD II into national law by 16 April 2026. On 22 January 2026, the Austrian Federal Ministry of Finance has published a ministerial draft regarding the implementation of AIFMD II by amending the Austrian Alternative Investment Fund Managers Act (Alternative Investmentfonds Manager-Gesetz, AIFMG). The key objectives are a stronger liquidity risk management, a harmonised EU legal framework for loan originating funds, greater transparency and reporting obligations, as well as stricter
On 13 January 2026, the National Bank of Ukraine (NBU) announced a new package of updates to the existing currency (FX) restrictions that were introduced in February 2022 in response to Russia’s full-scale invasion. The regulatory changes are aimed at further developing the incentive-based FX liberalisation framework gradually implemented by the NBU since 2025, as well as better supporting Ukrainian businesses operating under martial law. The key amendments entered into force on 14 January 2026 and include: 1. Dividend payments, repayment of "old" loans and other transactions within the "loan limit" The cornerstone of the new package is the introduction of a so-called “loan limit”, a special
Kinstellar has successfully advised PPF Group and its shareholders on the sale of Home Credit Bank Kazakhstan to ForteBank, which was completed in December 2025 following receipt of all required approvals from the relevant state authorities in Kazakhstan. As a result of the transaction, ForteBank acquired 100% of the shares in Home Credit Bank, becoming its sole shareholder. The transaction represents one of the most notable M&A deals in Kazakhstan’s banking sector in 2025 and reflects the ongoing consolidation of the local financial market. For the client, the deal enabled a fully regulated and structured exit from the Kazakh banking market while ensuring continuity of operations and stability for customers
The Austrian ministry responsible for Foreign Direct Investment (FDI) matters, the Federal Ministry for Economy, Energy, and Tourism (“the Ministry”), recently released guidance on the assessment of the filing obligation for foreign direct investments in Austria. In particular, it provided clarification on the scope of critical infrastructure and offered information regarding the acquisition of key assets, controlling influence, as well as the micro-enterprise exemption. In general, Austrian FDI rules apply to foreign direct investments into Austria by non-EU, non-EEA, and non-Swiss persons or undertakings. The Austrian FDI regime applies when such persons or entities acquire an Austrian undertaking, obtain 10%
The Republic of Serbia has adopted a new Law on Information Security (Zakon o informacionoj bezbednosti) (“Serbian NIS2”), marking a significant reform of the national cybersecurity framework and alignment with the EU NIS2 Directive. The Serbian NIS2 broadens the range of regulated entities, strengthens institutional coordination, and introduces clearer obligations for organisations operating ICT systems of special importance. Secondary legislation is expected in 2025–2026, and the previous law remains partially applicable until the end of 2025 to secure continuity during the transition period. This article provides an overview of the key novelties introduced by the Serbian NIS2, together with an outline of the
Kinstellar has advised Citigroup Global Markets, J.P. Morgan Securities, and Standard Chartered Bank (Joint Lead Managers), alongside Halyk Finance and Teniz Capital Investment Banking (Kazakhstan Lead Managers), on the successful issuance of USD 1.5 billion sovereign Eurobonds by the Ministry of Finance of the Republic of Kazakhstan. The bonds, with a 4.412% coupon rate and maturing in 2030, were issued under Kazakhstan’s USD 15 billion Global Medium Term Note Programme. The issuance was highly successful, with the orderbook significantly oversubscribed, reflecting significant demand from global investors. The final yield of 4.412% is the lowest ever achieved by Kazakhstan in its sovereign Eurobond market, demonstrating
Kinstellar has advised the joint global coordinators, bookrunners and lead managers, Bank of China (Hong Kong), BOCI Asia, China CITIC Bank International, China International Capital Corporation Hong Kong Securities, Citigroup Global Markets, Industrial and Commercial Bank of China (Asia) and SkyBridge Invest, on Kazakhstan law matters in connection with the debut issuance by National Company "KazMunayGas" (“KMG”) of CNY 1.25 billion five-year senior unsecured Dim Sum bonds with a coupon rate of 2.95% and a yield of 3.15%, under its newly established CNY 10 billion Medium Term Note Programme. The issuance, rated Baa1 by Moody’s, marks KMG’s first-ever entry into the Chinese yuan bond market and represents the
On 24 October 2025, the European Banking Authority (“EBA”) published a consultation paper on revised guidelines on common procedures and methodologies for the supervisory review and evaluation process (“SREP”) and supervisory stress testing (EBA/CP/2025/21). The consultation period will last three months, until 26 January 2026. The revised SREP Guidelines are expected to apply from 1 January 2027. New SREP Guidelines will integrate recent legislative changes and address lessons learned Since the issuance of the initial SREP Guidelines in 2014 and its subsequent revisions in 2017 and 2021, the European regulatory framework has significantly advanced. Mainly, the CRR III/CRD IV banking package, the Digital
On 23 October 2025, following a European Commission proposal issued on 19 September 2025 and extended negotiations among Member States, the Council of the EU adopted its 19th sanctions package against Russia in response to its ongoing aggression against Ukraine. The latest package reinforces existing restrictions targeting Russia’s military-industrial complex, energy sector and financial system, building on the measures introduced under the 18th package. It further strengthens the EU’s efforts to combat circumvention, including by designating additional entities and individuals located in third countries. In parallel, the EU has adopted additional sanctions against Belarus, including trade-related measures
Kinstellar is delighted to announce that Miriam Broucek, a highly regarded banking & finance lawyer, has joined our newly launched Vienna office as a Partner. Her arrival marks the launch of our Banking & Finance practice in Austria, a significant step in expanding our capabilities in this core area. With her outstanding track record and expertise, Miriam will play a key role in building and leading our finance offering in Vienna, ensuring we provide clients with seamless support on complex local and cross-border matters. Miriam is a recognised expert in financial markets law with many years of experience advising Austrian and international financial institutions on a broad range of regulatory matters, including
Kinstellar has advised Baiterek National Managing Holding (“Baiterek”) on the placement of USD 500 million Eurobonds with a five-year maturity and a 4.65% coupon rate. The bonds were placed among a wide range of international investors from the United States, the United Kingdom, Europe, and Asia, and are listed on the Vienna Stock Exchange (Wiener Börse) and the Kazakhstan Stock Exchange (KASE). The joint bookrunners were J.P. Morgan, Société Générale, Alatau City Invest, Halyk Finance, and Teniz Capital Investment Banking. The new placement follows Baiterek’s debut Eurobond issuance in May 2025, in which Kinstellar also acted as legal counsel. That transaction involved USD 500 million senior unsecured Eurobonds