Cancellation of order 108h: what will change for the participants of foreign economic activity after the lifting of limits on bank guarantees
Starting from December 14, 2025, the order of the Ministry of Finance No. 108n, regulating the maximum amounts of bank guarantees, ceases to be valid. This decision will be one of the most noticeable changes for participants in foreign economic activity (FEA) at the end of the year.
Previously, the order set limits on the maximum amount of one bank guarantee, as well as the cumulative limit of all guarantees that one bank could issue. These values directly depended on the size of the credit institution's own capital. In fact, the document limited the volume of guarantees, ensuring government control over the risks of the banking sector.
Now these limits will be completely abolished. This means that banks will be able to independently determine the size and number of guarantees issued without taking into account previous restrictions. For the financial market, this is a step towards greater flexibility, and for companies engaged in foreign economic activity, it is a step towards simplifying access to banking instruments.
Experts believe that lifting the limits will lead to noticeable consequences for the entire logistics and export-import industry. Firstly, competition between banks for customers will increase, which is expected to reduce the cost of guarantees. Companies will be able to receive financial instruments on more favorable terms, which is especially important for businesses operating with international contracts, where a bank guarantee is often a mandatory element of the transaction.
Secondly, the lifting of restrictions will increase the availability of guarantees for medium and small businesses. Previously, small companies often faced refusals due to the fact that banks could not exceed the established limit, even if the client had a positive credit history. Now this barrier will be removed, which opens up opportunities for expanding foreign economic activity and simplifies participation in large tenders.
However, along with the positive changes, there are also risks. Economists warn that liberalizing regulations could increase the share of high-risk bank guarantees. This will require credit institutions to conduct stricter internal assessments of borrowers in order to avoid an increase in defaults and financial losses. Perhaps the Central Bank will strengthen supervision of banks that actively work with large amounts of guarantees.
According to Grigory Grigoriev, CEO of the logistics company NOVELCO, the decision to cancel the limits is a logical step in the context of the adaptation of the Russian economy to the new structure of international settlements.:
"After the cancellation of order 108n, banks will have more freedom, and companies will have more tools for development. This will increase competition and reduce the cost of guarantees, but at the same time reduce the profits of banks. In general, the market will become more dynamic and accessible to foreign trade participants."
Thus, starting from December 14, 2025, businesses will receive new opportunities to optimize their foreign economic operations. The abolition of limits on bank guarantees is a step towards the development of the financial market, simplification of export—import procedures and reduction of barriers for entrepreneurs who work with foreign partners.
