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Regulation on Access to Financial Services via Financial Platforms (Marketplaces) Using Open APIs in the Kyrgyz Republic

The National Bank of the Kyrgyz Republic issued this Regulation to establish a unified legal framework for financial platforms (marketplaces) utilizing open APIs, defining the operational roles of platform operators, service providers, and end users. It mandates that qualified financial institutions operate or connect to these platforms through standardized API interfaces while ensuring 24/7 online access, robust data protection, and transparent information placement. The Regulation further requires operators to maintain a National Bank registry, submit quarterly service reports, and adhere to strict operational rules regarding risk assessment, dispute resolution, and secure transaction processing.

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Kyrgyzstan

National Bank of the Kyrgyz Republic

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Version for print Date of creation: 2026-02-12

Appendix to the Resolution of the Board of the National Bank of the Kyrgyz Republic dated June 2, 2022 No. 2022-P-14/35-3-(NPA)

REGULATION on the regulation of access to financial services through financial platforms (marketplaces) using open application programming interfaces in the Kyrgyz Republic (As amended by the Resolution of the Board of the National Bank of the KR dated December 26, 2025 No. 2025-P-12/70-6-(PS))

Chapter 1. General Provisions

  1. This Regulation on the regulation of access to financial services through financial platforms (marketplaces) using open application programming interfaces in the Kyrgyz Republic (hereinafter - the Regulation) governs relations arising from the placement of information on financial services and the execution of transactions using a financial platform, as well as defines the legal basis for the activities of participants in the financial platform and the operator of financial platform services (marketplace).

  2. Within the framework of this Regulation, operators of financial platform services (marketplaces) may include commercial banks, microfinance organizations, payment organizations, and payment system operators, as well as other legal entities established in the organizational-legal form of an open/closed joint-stock company or limited liability company, whose shareholders/members are organizations supervised by the National Bank in accordance with the legislation of the Kyrgyz Republic, as well as associations of banks, non-bank financial and credit institutions of the Kyrgyz Republic, payment system operators, and payment organizations, for the purpose of creating a single window for access to financial services in the Kyrgyz Republic. The decision to create a legal entity for a financial platform (marketplace) is made by the board of directors, shareholders/members of associations of banks, non-bank financial and credit institutions of the Kyrgyz Republic, payment system operators, and payment organizations, and/or by concluding accession agreements with an operator of financial platform services (marketplace).

  3. In cases where the operator of financial platform services (marketplace) is a commercial bank, microfinance organization, payment organization, or payment system operator, the provision of services related to the financial platform must be highlighted in a separate section on the website/showcase and/or in the mobile application.

  4. Organizations supervised by the National Bank and other legal entities holding permits from the authorized state body of the Kyrgyz Republic to conduct financial services, in accordance with the Law of the Kyrgyz Republic "On the Licensing and Permitting System in the Kyrgyz Republic", may connect to the operator of financial platform services (marketplace).

  5. The operator of financial platform services (marketplace) is responsible for placing information and providing services (transactions) on the financial platform and ensuring the confidentiality of information constituting bank secrecy, in accordance with requirements established by normative legal acts of the National Bank.

Chapter 2. Terms and Definitions

  1. Within the framework of this Regulation, the following terms and definitions are used:
  • financial platform (marketplace) - an electronic online platform/showcase of the operator of financial platform services, on which information about financial services provided by financial service providers is placed and there is a technical possibility to execute a transaction on the financial platform through a personal account and/or by link via the financial platform of the financial service provider itself or using other technological solutions on the financial platform;
  • operator of financial platform services (marketplace) - a legal entity that ensures the interaction of financial service providers on one platform through open application programming interfaces (API) and/or financial service providers connected to the rules of the operator of financial platform services, and provides online "24/7" access to the platform for users of financial services;
  • provider of financial services - a legal entity (participant of the financial platform) that has concluded an agreement with the operator of financial platform services (marketplace) to place its financial services and/or execute transactions on the financial platform;
  • user (consumer) of financial services - an individual or legal entity that has joined the financial platform through a personal account/mobile application by signing a public offer agreement/service provision agreement with the operator of the financial platform for the purpose of executing financial transactions with providers of financial services;
  • personal account - an electronic/virtual personal account of users of financial services located on the servers of the operator of financial platform services, access to which is carried out after authorization (entering identification data and password known only to the user);
  • financial services - services of financial institutions defined in Part 1 of Article 5 of the Law "On Countering the Financing of Criminal Activities and Money Laundering" (hereinafter - CFAD/ML) by financial institutions conducting financial services in accordance with the legislation of the Kyrgyz Republic;
  • financial transaction - a transaction executed between the user and the operator of financial platform services in favor of providers of financial services. The list of financial transactions, conclusion (execution) of which is possible using the platform, is defined in Chapter 4 of this Regulation;
  • information service - placement of up-to-date information about financial services provided by providers of financial services and other legal entities providing financial services in accordance with the legislation of the Kyrgyz Republic;
  • open application programming interface (API) - a technology for data exchange between information systems of providers of financial services/participants of the financial platform through standard interaction protocols;
  • chatbot - a program that enables communication via text or audio messages on websites, in messengers, and mobile applications of operators of financial platform services and providers of financial services, ensuring confidentiality of information during the transmission of messages from users of financial services. (As amended by the Resolution of the Board of the National Bank of the KR dated December 26, 2025 No. 2025-P-12/70-6-(PS))

Chapter 3. Requirements for Documents of the Operator of Financial Platform Services (Marketplace) for Inclusion in the National Bank Registry

  1. The operator of financial platform services (marketplace) must, no later than 30 (thirty) calendar days from the moment of creation of the financial platform, send a notification about the commencement of providing services related to the creation of the financial platform to the National Bank, according to Appendix 1 of this Regulation, and provide the following documents:
  1. copies of founding documents:
    • articles of association and founding agreement (if there is more than one founder (shareholder/member));
    • certificate of state registration/re-registration;
    • decision of founders on the creation of a legal entity;
    • regarding the size of the authorized capital;
    • on the election of executive management bodies, certified by seal and signature of the head/other authorized person of the notifier;
    • information on the official responsible for providing financial platform services (full name, position, work experience, contact phone number, etc.) (these data requirements apply to a separate legal entity whose shareholders/members are organizations supervised by the National Bank);
  2. a copy of the operational rules of the operator of financial platform services, which must contain the following:
    • name of the website/showcase and/or mobile application and its address (hyperlink, etc.) and connection information;
    • detailed description of the architecture and its operating scheme;
    • developed API standards for interaction with participants of the financial platform and their direction (by interfaces);
    • categories of commercial tariffs and commissions for connection and provision of financial services (products) via the financial platform (marketplace);
    • list of anticipated financial services on the financial platform;
    • procedure, conditions, and procedures for connection to and exit from the platform by participants;
    • user access procedure for users of financial services;
    • information protection requirements;
    • dispute resolution procedure between providers and users of financial services;
    • procedure for providing up-to-date information;
    • rights, obligations, and responsibilities of the operator of financial platform services and participants in the payment system;
    • etc.;
  3. a copy of the passport of the automated software complex of the financial platform, containing at least:
    • general characteristics (purpose, implementation date, etc.);
    • system configuration (hardware, software/system, application/database management systems, disk partition sizes, backup map, etc.);
  4. developed open API standards for connection and necessary interaction of participants of the financial platform;
  5. draft agreement with providers of financial services;
  6. draft public offer agreement with users of financial services;
  7. internal normative documents on the separation of functions of a commercial bank, microfinance organization and/or interaction operator/payment system operator/payment organization with the functions of an operator of financial platform services.

Chapter 4. Types of Information/Financial Services and Transactions on the Financial Platform (Marketplace)

  1. The operator of financial platform services may provide the following information/financial services and transactions on the electronic venue/showcase:
  • placement of information about financial services (currency exchange rates, names of types of services provided by providers of financial services, tariffs/interest rates on banking operations, and other information in the form of comparison within the framework of an agreement with providers/participants of the financial platform);
  • financial services defined in the list of the Regulation "On Main Requirements for the Activities of Commercial Banks when Concluding Agency Agreements for Providing Retail Banking Services", approved by the Resolution of the Board of the National Bank dated May 26, 2010 No. 36/7, and directing confirmations of applications to providers of financial services by means of simple electronic signature with the consent of users of financial services, except for cash withdrawal services from bank cards and money transfers via money transfer systems, distribution/redemption of electronic money;
  • provision of forms for opening unallocated metal accounts linked to a bank payment card;
  • placement of services for the purchase and sale of official gold bars by providers of financial platform services;
  • placement of information about financial services of organizations not supervised by the National Bank within the framework of an agreement with the operator of financial platform services in accordance with the legislation of the Kyrgyz Republic and accession to the rules of the operator of financial platform services (marketplace);
  • introduction of electronic document management between the operator of financial platform services and providers of financial platform services for transmitting user documents signed with an electronic signature;
  • placement of information about other property for implementation by providers of financial services to interested parties in accordance with the legislation of the Kyrgyz Republic.
  1. Operations related to funds are carried out on the side of providers of financial services via a link on the financial platform.

  2. The provision of financial services on the financial platform must be carried out through the personal account of users of financial services. Funds of users of financial services may be transferred using the financial platform only to the account of providers of financial services with whom they have previously concluded a corresponding agreement and/or this must be explicitly indicated on the platform.

Chapter 5. Requirements for Placement of Information about Financial Services on the Financial Platform

  1. The placement of information about financial services provided by providers of financial services on the financial platform (marketplace) must not:
  1. mislead users of financial services about the services provided by providers of financial services through various promotions that are not up-to-date at the time of receiving the financial service;
  2. contain information inconsistent with reality, including about the existence of a financial organization's right to conduct certain banking operations and other operations;
  3. contain guarantees or promises of operational effectiveness (investment returns), including based on past actual indicators, if such operational effectiveness (investment returns) cannot be determined at the time of concluding the corresponding agreement.
  1. Operational rules of the operator of financial platform services, the date of commencement of providing financial platform services, as well as other normative documents necessary for users and providers of financial services to review, including tariffs for using and receiving information about financial services on the financial platform (if any), must be publicly available.

  2. The operator of financial platform services must place information about financial services in the state and official languages, without restricting the provision of financial services to users by their choice of service language.

  3. The operator of financial platform services (marketplace) must establish equal conditions for providers of financial services to access the financial platform.

Chapter 6. Connection to the Financial Platform Operator via Open Application Programming Interfaces (API)

  1. Providers of financial services may provide the operator of financial platform services with access to their open application programming interfaces (API), and/or the operator of financial platform services (marketplace) must have developed and standardized API solutions for processes to unify interaction between providers of financial services (API providers, third-party providers, payment service providers, third-party information service providers) and API users, including technical standards, requirements for protecting transmitted information, ensuring confidentiality of user data, and using user and provider information within the framework of the legislation of the Kyrgyz Republic.

  2. To connect to a financial platform (marketplace), providers of financial services may interact with and/or provide the operator of financial platform services with access to their existing APIs:

  1. information APIs - public data on available products and services of providers of financial products and services, as well as on the location and operating hours of bank customer service points, national currency exchange rates, etc.;
  2. service APIs - data on financial institution products used by a client, including information about the history of operations for these products. Providing the ability to manage connected client products and services, change data in profiles of existing clients;
  3. product APIs - requests to provide a product or connect a service for an existing or new client, receiving personalized offers for products or services of a financial organization.
  1. The use of APIs must be described in the technical documentation of the operator of financial platform services for each open application programming interface (API), which will be sent to the stated providers of financial services.

  2. API standards must be published on the platform of the operator of financial platform services.

Chapter 7. Requirements for Information Protection on the Financial Platform

  1. The operator of financial platform services (marketplace) must inform the National Bank about any incidents and abnormal situations in accordance with the timeframes established for payment system operators in the Regulation "On Abnormal Situations in the Payment System" approved by the Resolution of the Board of the National Bank dated September 2, 2019 No. 2019-P-14/46-2-(PS).

  2. The operator of financial platform services (marketplace) must ensure continuous interaction with service providers for the execution of financial transactions, uninterrupted and continuous operation of the platform, including in case of information threats, as well as restoration of service provision and platform functionality, ensuring confidentiality, integrity, and preservation of personal data in accordance with the legislation of the Kyrgyz Republic.

  3. Interaction between providers of financial services and information systems of the operator of financial platform services must be carried out via secure communication channels.

  4. Operators of financial platform services and providers of financial services must regularly conduct activities to inform users of financial services on the platform about: a) recommendations and requirements for information protection against harmful software code impacts that disrupt the normal operation of computing equipment, to counter illegal financial transactions; b) information about possible risks of unauthorized access to user information for the purpose of financial transactions by persons not entitled to carry them out; c) information on measures to prevent unauthorized access to protected information, including in case of loss (theft, misplacement) by the user of a device used for operations on the financial platform, control of the device configuration used by the user to perform actions on the financial platform, and timely detection of harmful code impacts.

  5. Operators of financial platform services and providers of financial services must conduct risk level assessments at least once a year in accordance with international standards.

Chapter 8. Final Provisions

  1. The National Bank maintains a registry of operators of financial platform services (marketplaces) within the territory of the Kyrgyz Republic. Exclusion from the registry of a financial platform (marketplace) operator is carried out by the National Bank within 5 (five) working days from the date of official notification by the operator of financial platform services about the termination of providing financial platform (marketplace) services.

  2. The operator of financial platform services must quarterly, no later than the 25th (twenty-fifth) day following the reporting quarter, in electronic form (scanned version of the document) with subsequent mailing of a paper version, provide information about services placed on the financial platform according to the form established in Appendix 2 of this Regulation.

  3. If necessary, the National Bank has the right to request additional information and documents related to the activities of a financial platform (marketplace) arising from provided reports, which must be submitted within timeframes established by the National Bank. The management of the operator of financial platform services is responsible for providing timely, accurate, and reliable information.

Appendix 1 to the Regulation "On the regulation of access to financial services through financial platforms (marketplaces) using open application programming interfaces in the Kyrgyz Republic" National Bank of the Kyrgyz Republic NOTIFICATION Hereby ______________________________________________________ notifies about the commencement (name of legal entity) of providing financial platform services (marketplace). The notification is accompanied by a list of documents in accordance with paragraph 7 of this Regulation. Appendix: on _________ p. 1) 2) 3) Signature and seal of the legal entity "_" ______________________ 20 y.

Appendix 2 to the Regulation "On the regulation of access to financial services through financial platforms (marketplaces) using open application programming interfaces in the Kyrgyz Republic" Name of legal entity


INFORMATION on connected providers of financial services to the financial platform (marketplace) for ___________ quarter 20__ y. Total number of active contracts: (indicate quantity) total __________ № | Name of organization | Legal address and contact details | Contract number and date | Type of services provided ... | ... | ... | ... | ... Contracts with providers of financial services ... ... ... ... ... Contracts with other participants of the financial platform ... ... ... ... ... Types of financial services placed on the financial platform ... ... ... ... ... Signature and seal of the legal entity "_" ______________________ 20 y.

Contacts Public Reception: +996 (312) 61-04-86, +996 (312) 66-90-15 ext. 1257, +1256 Consumer Rights Protection Department: +996 (312) 66-90-15 ext. 1671, +1666 Report Corruption: +996 (312) 66-90-15 ext. 2120, +996 (312) 61-04-00 Auto-informer of Official Currency Exchange Rates: +996 (312) 61-07-11 Numismatic Museum: +996 (312) 66-90-15 ext. 1232, +996 (312) 61-24-14 E-mail: mail@nbkr.kg Media Relations: press@nbkr.kg 720010, Kyrgyz Republic, Bishkek city, Kiev street, 189

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