2010-05-26 | 130311

Regulation on Basic Requirements for Commercial Banks' Activities When Concluding Agency Agreements for Providing Retail Banking Services

The National Bank of the Kyrgyz Republic issued this Regulation to establish core requirements for commercial banks operating retail agency networks that provide banking services on behalf of the bank through licensed agents. It mandates that banks assume full liability for agents' obligations, define extended and limited service spectra, enforce strict risk management, client verification, and data security protocols, and set operational limits such as daily cash withdrawal caps. The framework standardizes agency agreements, mandates electronic data exchange and co-branding opportunities, and ensures regulatory compliance for branchless banking expansion across the Kyrgyz Republic.

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Created date: 2026-02-12

Approved by the Board of Directors Resolution of the National Bank of the Kyrgyz Republic dated May 26, 2010 No. 36/7

REGULATION on the basic requirements for commercial banks' activities when concluding an agency agreement for providing retail banking services

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated August 28, 2013 No. 32/5, September 30, 2015 No. 59/5, June 28, 2017 No. 2017-P-14/28-3, March 14, 2018 No. 2018-P-14/8-11, August 15, 2018 No. 2018-P-14/33-5, March 18, 2020 No. 2020-P-14/12-3, July 27, 2022 No. 2022-P-14/47-7, December 7, 2022 No. 2022-P-14/76-6, December 26, 2025 No. 2025-P-12/70-6-(PS))

  1. General Provisions

  2. (Lapsed in accordance with the Board Resolution of the National Bank of the Kyrgyz Republic dated June 28, 2017 No. 2017-P-14/28-3)

  3. The purpose of the Regulation "On Basic Requirements for Commercial Banks' Activities When Concluding an Agency Agreement for Providing Retail Banking Services" (hereinafter - the Regulation) is to define basic requirements for commercial banks (hereinafter - bank) when carrying out activities to expand access to financial services by attracting retail agents to provide retail banking services to the population on behalf of the bank and creating off-branch banking infrastructure (branchless banking).

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated June 28, 2017 No. 2017-P-14/28-3)

  1. The scope of this Regulation extends to banks and retail agents who have concluded an agency agreement on providing retail banking services to the population on behalf of the bank in accordance with the Civil Code of the Kyrgyz Republic, laws of the Kyrgyz Republic "On Banks and Banking Activity", "On the Payment System of the Kyrgyz Republic", "On Microfinance Organizations in the Kyrgyz Republic", "On Credit Unions", "On Countering Financing of Criminal Activities and Legalization (Money Laundering) of Criminal Proceeds" (hereinafter - legislation of the Kyrgyz Republic), this Regulation, and other normative legal acts of the National Bank of the Kyrgyz Republic (hereinafter - National Bank).

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated June 28, 2017 No. 2017-P-14/28-3, March 18, 2020 No. 2020-P-14/12-3, December 7, 2022 No. 2022-P-14/76-6, December 26, 2025 No. 2025-P-12/70-6-(PS))

  1. The bank may attract as a retail agent a legal entity or an individual entrepreneur in accordance with the requirements of this Regulation. In doing so, the bank bears responsibility for fulfilling agents' obligations within the contract.

Retail agents may provide:

  • an extended spectrum of retail banking services;
  • a limited spectrum of retail banking services.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated March 14, 2018 No. 2018-P-14/8-11)

  1. The extended spectrum of retail banking services includes:
  • receiving and processing payments and settlements for goods and services not resulting from their own activity on behalf of third parties through payment systems based on information technology and electronic means, and payment methods;
  • making money transfers through money transfer systems;
  • issuing and receiving blank forms for opening bank accounts to forward them to the bank;
  • issuing and receiving blank forms for issuing/re-issuing bank payment cards;
  • organizing the exchange of blank forms and client questionnaires for issuing/re-issuing bank payment cards in electronic form, followed by forwarding bank payment cards to clients;
  • issuing and receiving blank forms for accessing remote distance banking services, including electronic wallets, to forward them to the bank;
  • issuing and receiving blank forms for issuing/re-issuing access codes to remote distance banking services to forward them to the bank;
  • providing issued codes for accessing remote distance banking services while complying with information/data security and confidentiality conditions;
  • issuing and receiving blank forms for processing loans to forward them to the bank;
  • loan repayment;
  • replenishing a bank account;
  • distributing/repaying electronic money;
  • conducting client identification and verification procedures, including electronic wallet holders;
  • concluding agreements with acceptors for receiving electronic money of a local electronic money system;
  • concluding agreements with commercial organizations for paying salaries to electronic wallets;
  • dispensing cash from bank cards, including virtual cards;
  • dispensing cash to banking clients from payment terminals with cash-out function from these banking clients' accounts;
  • receiving payments to the budget (fines, taxes, customs duties), including using mobile applications and QR codes;
  • concluding agreements with state-owned/commercial organizations for paying salaries to bank payment cards.

Transmission of information to the bank regarding types of extended spectrum retail banking services in electronic form is permitted in accordance with the Law of the Kyrgyz Republic "On Electronic Signature".

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated July 27, 2022 No. 2022-P-14/47-7)

  1. The limited spectrum of retail banking services includes:
  • receiving and processing payments and settlements for goods and services not resulting from their own activity on behalf of third parties through payment systems based on information technology and electronic means/methods;
  • loan repayment;
  • distributing/repaying electronic money;
  • dispensing cash from bank cards;
  • receiving payments to the budget (fines, taxes, customs duties), including using mobile applications and QR codes.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated March 18, 2020 No. 2020-P-14/12-3)

6-1. When attracting a retail agent to distribute/repay electronic money, the bank must comply with National Bank requirements established in the Regulation "On Electronic Money in the Kyrgyz Republic", approved by the Board Resolution of the National Bank dated April 20, 2022 No. 2022-P-14/25-3-(PS). In case of non-compliance, the National Bank may apply enforcement measures in accordance with Kyrgyz legislation.

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated March 18, 2020 No. 2020-P-14/12-3, July 27, 2022 No. 2022-P-14/47-7)

  1. Conditions for providing banking retail services to a client through a retail agent are established in the agreement between the bank and its agent.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5)

7-1. Agents providing an extended spectrum of retail banking services and agents providing a limited spectrum are prohibited from:

  • receiving lottery stakes, except for state (national) lotteries conducted in real-time;
  • receiving payments for lottery tickets, receipts, and other documents certifying the right to participate in a lottery;
  • repaying electronic money from non-identified electronic wallets.

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated March 14, 2018 No. 2018-P-14/8-11, March 18, 2020 No. 2020-P-14/12-3)

Note! In accordance with the Board Resolution of the National Bank dated March 18, 2020 No. 2020-P-14/12-3, amendments introduced into paragraph 7-1 of this Resolution enter into force on October 1, 2020.

  1. Used Terms and Definitions

  2. (Lapsed in accordance with the Board Resolution of the National Bank of the Kyrgyz Republic dated August 15, 2018 No. 2018-P-14/33-5)

  3. Banking agency network - a system including a settlement bank and retail agents carrying out activities to provide specific types of banking services based on concluded agency agreements between them.

9-1. Barcode - a linear code, machine-readable code, a set of geometric symbols whose arrangement is described in corresponding goods/objects, etc.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated March 14, 2018 No. 2018-P-14/8-11)

9-2. Blank form - a paper sheet or electronic form (form) with the bank's printed name and partially pre-printed text, intended for preparing a document in a specific form, where entries are made by hand in designated places (for opening bank accounts/electronic wallets, issuing bank payment cards, receiving remote distance banking services, etc.) and certified by the client's signature.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated March 18, 2020 No. 2020-P-14/12-3)

  1. Retail agent - a legal entity or individual entrepreneur that has signed an agency agreement with the bank to provide retail banking services on behalf of the bank, including through the retail agent's network. Retail agents are divided into agents providing an extended spectrum of services and agents providing a limited spectrum of retail banking services in accordance with paragraph 25 of this Regulation.

(Paragraph lapsed in accordance with the Board Resolution of the National Bank of the Kyrgyz Republic dated March 14, 2018 No. 2018-P-14/8-11)

(Paragraph lapsed in accordance with the Board Resolution of the National Bank of the Kyrgyz Republic dated March 14, 2018 No. 2018-P-14/8-11)

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5, March 14, 2018 No. 2018-P-14/8-11)

  1. Retail agent's own network - branches and offices of the retail agent carrying out activities based on a Charter or agreements concluded with the retail agent.

  2. Guarantee (insurance) deposit - monetary funds in an amount determined by the agency agreement or its annex, serving as security for payment settlements, credited by the agent to the bank's account with the condition of adjusting their balance depending on the difference between incoming and outgoing payments. By mutual agreement between the settlement bank and retail agent, the account may be blocked by the bank within a limit agreed upon by the parties until the end of the contract term, with the bank's right to change limit amounts depending on the retail agent's turnover. The limit amount is set as a standard expressed in percent, taking into account all risks inherent to this activity.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated March 18, 2020 No. 2020-P-14/12-3)

  1. Mobile payment - an instruction to the bank to debit monetary funds from a client's account, initiated by the client using a mobile phone via SMS/USSD message, to make a settlement for goods/services on behalf of the recipient and/or retail agent.

  2. Payer - a client, physical or legal entity, making monetary funds to the retail agent or bank to fulfill monetary obligations to a supplier (recipient of monetary funds), including prepayment for the supplier's services.

  3. Payee - a supplier of goods and/or services, a legal entity (excluding credit institutions), having a banking service agreement with the bank, to whom monetary funds from payers for consumed goods and/or services are transferred through the banking agency network.

  4. Settlement bank - a bank or its branch, where the retail agent has a settlement account for accounting monetary funds received from payers and used to conduct settlements only on behalf of certain payees.

  5. Terminal - a hardware-software complex of various types, including POS terminals, specialized cash-desk devices, stationary equipment, pocket mobile devices, portable terminals and cash registers, self-service machines (specialized machines and ATMs for receiving payments), as well as a settlement web server for authorizing transactions on the Internet, allowing connection with the main processing center, forming and sending messages to the bank's payment system network, and receiving messages from it.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5)

17-1. (Lapsed in accordance with the Board Resolution of the National Bank of the Kyrgyz Republic dated March 14, 2018 No. 2018-P-14/8-11)

  1. Co-branding - a set of marketing activities by the bank and agent for joint promotion of products or services that combine the brand names of the bank and agent.

  2. USSD message (USSD - Unstructured Supplementary Services Data) - a text messaging technology, alternative to SMS, characterized by the fact that sent messages are not stored in the mobile operator's database. It may be used by communication operators to report account balance to the payer, activate payment cards, and other services, including initializing mobile payments.

  3. Procedure for Concluding an Agency Agreement and Risk Management

  4. Banking retail services are provided by the retail agent based on an agency agreement with the bank, which must stipulate:

  1. a list of banking retail services specifying limit amounts that may be performed by the retail agent;
  2. method of providing banking retail services and accessing them (via Internet, dial-up and other communication channels, using Internet kiosks, telephone, personal computer, or other devices);
  3. tariffs for banking retail services taking into account the retail agent's commission. When calculating commissions, the bank takes into account the type of banking retail service, costs for ensuring security and reliability of providing the service to clients, costs for organizing, managing, and supporting the technical and technological process of service provision, expenses for ensuring risk control and data confidentiality in accordance with Kyrgyz legislation;
  4. rights and obligations of the parties arising from providing banking retail services through the banking agency network, including the bank's right to supervise the retail agent's activities;
  5. security and technical strengthening procedures, including authentication order and confirmation of the client's right to receive banking retail services;
  6. liability of the parties for non-fulfillment or improper fulfillment of their obligations arising from providing banking retail services by the retail agent. The agency agreement must necessarily stipulate the bank's liability for improper or non-fulfillment of its obligations by its retail agent to clients;
  7. order, terms, and volumes of the retail agent's reporting to the bank regarding client operations;
  8. grounds for suspending and terminating provision of banking retail services with prior and/or without prior notification of the parties;
  9. methods for resolving conflicts arising from providing banking retail services by the retail agent;
  10. contact phone numbers and addresses for inquiries to the bank regarding banking retail services;
  11. requirements for proper client verification and data storage in accordance with Kyrgyz legislation on countering financing of criminal activities and legalization (money laundering) of criminal proceeds (hereinafter - CFT/AML), if the bank transfers proper client verification functions to the retail agent;
  12. terms for providing necessary information about the client and beneficial owner, copies of client and beneficial owner questionnaires, as well as copies of other documents obtained as a result of proper client verification, if the bank transfers these functions to the retail agent in accordance with the Regulation "On the Procedure for Conducting Proper Client Verification", approved by the Cabinet of Ministers Resolution dated November 14, 2025 No. 739. Subparagraphs 11 and 12 of paragraph 20 do not apply to agents providing a limited spectrum of retail banking services.

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated March 18, 2020 No. 2020-P-14/12-3, December 26, 2025 No. 2025-P-12/70-6-(PS))

  1. When concluding a contract, the bank provides information about banking retail services to the retail agent. Rules, order, and conditions for providing banking retail services are determined by internal bank documents approved by the authorized body of the bank. This information must be posted on the bank's website if the bank provides banking retail services through retail agents.

  2. When providing electronic banking services, information exchange between the bank and its retail agent is carried out using an electronic digital signature and/or via dynamic client identification or other methods ensuring secure data transmission.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5)

  1. Electronic banking services may be provided through a telephone and/or other devices (terminals of various types) without using an electronic digital signature and dynamic client identification based on applying security procedures established by internal bank rules and the agency agreement.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5)

  1. Requirements for Banks When Working with Retail Agents

  2. Depending on its strategy, the bank may develop a banking agency network for providing retail banking services with the aim of:

  1. optimizing branch activities by redistributing functions between the bank's branch and retail agent;
  2. expanding and segmenting the list of retail services by client categories or geographical location;
  3. expanding access points to its services for clients and attracting clients in remote regions with low income levels;
  4. providing distance banking and payment services without the need to expand the bank's branch network, and transferring to the retail agent authority to process mass payments for small amounts in remote regions with low income levels.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5)

  1. The bank, guided by risk management and information system management documents, must develop criteria for selecting a retail agent based on the following categories of agents in accordance with National Bank normative legal acts:
  1. Agents providing an extended spectrum of retail banking services are legal entities, residents of the Kyrgyz Republic, who have a National Bank license for one of the following types of banking activity and operations: a) conducting activities for microfinance organizations; b) conducting credit union activities; c) providing services for receiving and processing payments and settlements for goods and services not resulting from their own activity on behalf of third parties through payment systems based on information technology and electronic means, and payment methods; d) conducting foreign currency cash exchange operations.
  2. Agents providing a limited spectrum of retail banking services are agents not falling under extended spectrum agents, being legal entities/individual entrepreneurs, residents of the Kyrgyz Republic, who do not have/have a National Bank license for banking/payment services, as well as the state enterprise "Kyrgyz Post". 2-1) The state enterprise "Kyrgyz Post", in addition to providing the limited spectrum of retail banking services specified in paragraph 6, and provided that banks comply with proper client verification requirements, may additionally provide the following services:
  • issuing and receiving blank forms for opening bank accounts to forward them to the bank;
  • issuing and receiving blank forms for issuing/re-issuing bank payment cards;
  • issuing and receiving blank forms for accessing remote distance banking services, including electronic wallets, to forward them to the bank;
  • issuing and receiving blank forms for issuing/re-issuing access codes to remote distance banking services to forward them to the bank;
  • issuing and receiving blank forms for processing loans to forward them to the bank.

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated March 14, 2018 No. 2018-P-14/8-11, March 18, 2020 No. 2020-P-14/12-3)

25-1. When selecting a retail agent, the bank must take into account the following parameters:

  1. client trust in the agent and stability of its activity in the market segment where the bank intends to provide retail banking services;
  2. client access convenience regarding the location of the retail agent, availability of qualified personnel and premises, taking into account their technical strengthening;
  3. bank trust in the retail agent, credit history verification, existence of an accounting policy for economic activity, quality management of cash operations, and presence of control over cash transactions by the retail agent;
  4. existence of a bank account for the retail agent, qualified IT personnel, presence or ability to establish necessary communication channels for interaction with the bank, availability of premises for creating a banking retail service access point;
  5. potential to combine retail banking services with the retail agent's main activity, openness to operating within co-branding with the bank on behalf of the bank, as well as readiness and ability to increase business volumes.

(In the edition of the Board Resolution of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5)

  1. The bank concludes an agency agreement with the retail agent and opens a settlement account for the retail agent to reflect cash and non-cash monetary operations performed by clients in accordance with the conditions of the concluded agency agreement between the bank and retail agent. The agency agreement must stipulate that the bank bears responsibility to clients for the actions of its retail agents within and in accordance with the signed agreement between the bank and agent.

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5, March 14, 2018 No. 2018-P-14/8-11)

  1. The bank develops and provides the retail agent with a limit structure for each banking operation, guidelines, and procedures for carrying out operations, compiled taking into account operational risks and liquidity risks for retail agents. Limits on cash withdrawal through bank payment cards via retail agents must not exceed 150 calculation indices per day for one cardholder.

(In the edition of Board Resolutions of the National Bank of the Kyrgyz Republic dated September 30, 2015 No. 59/5, August 15, 2018 No. 2018-P-14/33-5)

  1. The bank develops and provides the retail agent with unified standards and rules for each type of banking operation offered through the retail agent, to ensure full awareness by the retail agent and to provide operational compatibility with the retail agent's information system if necessary, for reliable, secure, and quality client service. Responsibility for the quality provision of retail banking services by the retail agent rests with the bank.

  2. Within the banking agency network, the bank creates a unified

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