Regulation on the Special Regulatory Regime

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Date of creation: 2026-01-16

Appendix

to the Resolution of the Board of the National Bank of the Kyrgyz Republic

of August 12, 2020 No. 2020-P-12/45-3-(NPA)

REGULATION

on the special regulatory regime

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of July 27, 2022 No. 2022-P-12/47-4, December 14, 2022 No. 2022-P-12/78-10, December 13, 2023 No. 2023-P-12/77-1, December 27, 2024 No. 2024-P-12/71-2-(NPA), December 17, 2025 No. 2025-P-14/67-5-(NPA))

Chapter 1. General Provisions

1. This Regulation "On the Special Regulatory Regime" (hereinafter - the Regulation) defines the procedure for creating a special regulatory regime for the pilot testing (testing) and implementation of innovative technologies/solutions in the field of banking and payment operations/services (hereinafter - banking operations/services), including operations/services related to virtual assets backed by national or foreign currency (hereinafter - virtual asset operations), in a limited controlled environment. It also defines the procedure for participation and requirements for participants of the special regulatory regime, including within the framework of state initiatives aimed at implementing digital technologies and improving financial accessibility.

The requirements of regulatory legal acts of the National Bank of the Kyrgyz Republic (hereinafter - the National Bank) apply to participants of the special regulatory regime taking into account the conditions of the special regulatory regime and features provided for by this Regulation and decisions of the Committee of the National Bank, whose function is to introduce the special regulatory regime (hereinafter - the Committee). The Committee, when considering an application for participation in the special regulatory regime, has the right to involve independent specialized experts.

Banking operations/services within the special regulatory regime must be ready for testing in real market conditions on a limited scale and at the stage of a minimum commercially viable product.

Implemented innovative technologies/solutions in the field of banking operations/services within the special regulatory regime must meet the following criteria:

• innovative technologies/solutions offered for use in banking/payment operations and/or provision of banking/payment services are new in the field of banking operations/services and are aimed at expanding financial accessibility for users compared to traditional banking products;
• the provision of banking operations/services has been restricted by regulatory legal acts of the Kyrgyz Republic;
• there are no restrictions on combining their activities with other activities, including restrictions on the type and list of provided operations, according to the legislation of the Kyrgyz Republic, except for virtual asset operations;
• operations and services are not regulated by regulatory legal acts of the Kyrgyz Republic and/or there is no direct prohibition on conducting operations;
• banking operations/services are based on new technologies/solutions previously not used in the banking or payment sector;
• the implemented innovative technology/solution has the potential to reduce risks, reduce costs, as well as increase transparency and cybersecurity;
• implemented innovative technologies/solutions, including operations related to virtual assets, in the field of banking and payment operations/services are an addition, not a replacement for the main business activity.

Compliance of the proposed innovative technologies/solutions in the field of banking operations/services for pilot testing (testing) with the above criteria is mandatory for the creation of a special regulatory regime.

The special regulatory regime is not intended and cannot be used as a means to bypass the requirements of the legislation of the Kyrgyz Republic and the requirements imposed on participants providing similar types of banking operations and/or services.

Within the framework of the special regulatory regime, it is not allowed to provide preferences to individual legal entities that ensure them more favorable conditions for participation in special regulatory regimes and/or in connection with participation in special regulatory regimes.

(As amended by the Resolution of the Board of the National Bank of the Kyrgyz Republic of December 17, 2025 No. 2025-P-14/67-5-(NPA))

2. The main tasks of the special regulatory regime for the implementation of innovative banking operations and services, including operations related to virtual assets, are:

• reducing legal uncertainty and legal risks for market participants;
• defining acceptable and accessible rules for the pilot use of innovative banking operations and services, as well as virtual asset operations;
• accelerating the selection and introduction into the market of innovative banking operations and services;
• developing legal and other regulatory requirements for new public relations arising from the implementation of innovative banking operations and services;
• increasing the accessibility and customer orientation of banking operations/services for consumers, as well as reducing the costs of their implementation, including tasks for checking new technologies in a real environment to assess their stability, applicability, and economic feasibility for effective integration into the banking infrastructure.

(As amended by the Resolution of the Board of the National Bank of the Kyrgyz Republic of December 17, 2025 No. 2025-P-14/67-5-(NPA))

3. The National Bank, for the implementation of innovative operations and/or, including virtual asset operations, services in the field of banking operations and/or services within the special regulatory regime, exercises control over the process of implementing this regime and makes a decision in accordance with the norms of this Regulation.

Information on the creation of a special regulatory regime based on a license issued by the National Bank for the right to conduct a limited list of banking operations, including virtual asset operations, within the special regulatory regime is posted on the official website of the National Bank.

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of December 27, 2024 No. 2024-P-12/71-2-(NPA), December 17, 2025 No. 2025-P-14/67-5-(NPA))

4. The creation of a special regulatory regime is carried out based on the principles of voluntariness, publicity, equality of reporting, and the introduction of restrictions regarding all participants of the special regulatory regime, as well as taking into account recommendations of international standards for banking activities and effective supervision. At the same time, the implementation of the special regulatory regime should not affect the change in the main goal, operations, and principles of the activity of the National Bank specified in the legislation of the Kyrgyz Republic.

(Paragraph lost force in accordance with the Resolution of the Board of the National Bank of the Kyrgyz Republic of December 27, 2024 No. 2024-P-12/71-2-(NPA))

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of July 27, 2022 No. 2022-P-12/47-4, December 27, 2024 No. 2024-P-12/71-2-(NPA))

4-1. Risk management methods must correspond to the scale of the participant's activity and risks associated with the implementation of an innovative banking service or technology, including virtual asset operations, within the special regulatory regime.

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of December 27, 2024 No. 2024-P-12/71-2-(NPA), December 17, 2025 No. 2025-P-14/67-5-(NPA))

5. Responsibility for compliance with the conditions of the special regulatory regime is borne by the Applicant jointly with the Co-applicant (if any).

At the same time, the Applicant for entering the special regulatory regime is a legal entity registered on the territory of the Kyrgyz Republic, which must meet the following requirements:

1. absence of violations of mandatory economic standards, prohibitions, and restrictions, as well as unexecuted enforcement measures in the field of combating the financing of criminal activities and legalization (money laundering) of criminal proceeds (hereinafter - CFT/AML), related to the innovative banking operations and/or services proposed for pilot testing (testing), as well as virtual asset operations, on the date of submitting the application;

2. the Applicant must not be in the process of liquidation, bankruptcy, or special regime;

3. absence of a ban regarding the Applicant (Co-applicant) or its manager or founder (shareholder, participant) to engage in this type of activity by court decision or according to the legislation of the Kyrgyz Republic;

4. absence in the composition of founders of the Applicant (Co-applicant) of affiliated persons registered in offshore zones, or physical persons residing on the territory of offshore zones or being shareholders (participants) of legal entities registered in offshore zones, the list of which is established by the National Bank;

5. the Applicant (Co-applicant) must be solvent and have a satisfactory financial condition, or the Applicant (Co-applicant) must have sufficient own financial resources for conducting the special regulatory regime for the last reporting financial year at the time of submitting the application;

6. presence of professional, technical competence and reputation, equipment, and other material capabilities necessary for participation in the special regulatory regime.

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of December 27, 2024 No. 2024-P-12/71-2-(NPA), December 17, 2025 No. 2025-P-14/67-5-(NPA))

Chapter 2. Terms and Definitions

6. The following terms and definitions are used in this Regulation:

Provision of service - carrying out operations and providing services within the special regulatory regime in accordance with Article 48 of the Constitutional Law of the Kyrgyz Republic "On the National Bank of the Kyrgyz Republic" and the requirements of the National Bank.

Special regulatory regime - a set of rules that allow participants engaged in the implementation of innovative services/technologies in the market of banking and payment services of the Kyrgyz Republic to pilot test them in a limited controlled environment (by territory, time, number and volume of operations and users, and other), according to the requirements of the National Bank.

Pilot testing (testing) - the process of providing, researching, monitoring, and analyzing a service/technology, the purpose of which is to pilot test the service in accordance with the requirements and conditions of the special regulatory regime.

Applicant - a legal entity supervised by the National Bank that has submitted an application for the creation of a special regulatory regime for the implementation of innovative banking operations and services/technology, including virtual asset operations, and their subsequent testing.

Co-applicant - a legal entity that, together with the Applicant, has submitted an application to the National Bank for the testing of innovative banking operations and services/technology, including virtual asset operations, within the special regulatory regime.

Participant of the special regulatory regime - the Applicant and Co-applicant (if any), conducting testing of innovative banking operations and services, including virtual asset operations, in accordance with the conditions of the special regulatory regime.

License for the right to conduct a limited list of banking operations within the special regulatory regime - a document (Appendix 5 to this Regulation) certifying the participant's right to carry out activity (separate banking operations) within the special regulatory regime.

Technical Specification - an Appendix to the license (Appendix 6 to this Regulation) for the right to conduct a limited list of banking operations within the special regulatory regime, is an integral part of the license with the display of permitted operations.

During the testing process, the content of the technical specification must remain unchanged.

In case of a decision to extend the special regulatory regime, an increase in the established restrictions is not allowed.

Definitions and terms regarding innovations and virtual assets correspond to definitions and terms according to the legislation of the Kyrgyz Republic. Depending on the type of operation, service/technology undergoing testing within the special regulatory regime, main definitions and terms may be contained in the technical specification for the operation, service/technology.

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of July 27, 2022 No. 2022-P-12/47-4, December 14, 2022 No. 2022-P-12/78-10, December 13, 2023 No. 2023-P-12/77-1, December 27, 2024 No. 2024-P-12/71-2-(NPA), December 17, 2025 No. 2025-P-14/67-5-(NPA))

Chapter 3. Submission and Consideration of an Application for the Creation of a Special Regulatory Regime

7. An application for the creation of a special regulatory regime (hereinafter - the Application) is submitted by the Applicant and Co-applicant (if any) to the National Bank. The Applicant in the provision of virtual asset operations can only be commercial banks, payment system operators, and payment organizations.

In the special regulatory regime for testing similar operations and services or applied technologies in the conduct of operations and provision of services, simultaneous participation of several participants of the special regulatory regime is allowed, taking into account paragraph 14-1 of this Regulation, in the following cases:

• if the initiator of the special regulatory regime is the National Bank;
• if no more than 6 (six) months have passed from the date of entry into force of the special regulatory regime for similar tested operations and services.

At the same time, the term of simultaneous participation of participants of the special regulatory regime cannot exceed the term of the existing special regulatory regime testing a similar operation and/or service.

(As amended by the Resolution of the Board of the National Bank of the Kyrgyz Republic of December 17, 2025 No. 2025-P-14/67-5-(NPA))

8. The Application includes:

• an application in the form of Appendix 1 to this Regulation, formatted on the Applicant's letterhead, with a petition for the creation of a special regulatory regime in accordance with this Regulation, containing an inventory of documents attached to the application, signed by the head and sealed by the Applicant and Co-applicant (if any), according to the requirements of the legislation of the Kyrgyz Republic;

• information about the Applicant and Co-applicant (if any) in the form of Appendix 2 to this Regulation and written consent of the Co-applicant;

• information about the operation, service/technology in the form of Appendix 3 to this Regulation, the testing of which is proposed by the Applicant;

• detailed information for assessing the necessity of creating a special regulatory regime for the proposed pilot service/operation;

• notarized copies or electronic forms of the constituent documents of the Co-applicant (if any) with details for obtaining confirmation from the corresponding state bodies, indicating the amount of the declared charter capital;

• audited accounting/financial reporting of the applicant for the last reporting financial year;

• a document confirming payment for the license. The amount of the state duty for the license is determined in accordance with the legislation of the Kyrgyz Republic;

• original power of attorney for receiving the license;

• written consent of the Co-applicant to conduct planned/unplanned inspector checks on-site within the special regulatory regime by the National Bank, if the Co-applicant is not a legal entity supervised by the National Bank (Appendix 1-1);

• forecast economic calculations of results expected from the conduct of the proposed operation and service.

The requirement to provide constituent documents and accounting/financial reporting does not apply to persons supervised by the National Bank acting as Co-applicants (if any).

(As amended by the Resolution of the Board of the National Bank of the Kyrgyz Republic of December 17, 2025 No. 2025-P-14/67-5-(NPA))

9. Information about the operation, service/technology (Appendix 3) must briefly disclose the content and essence of the proposed operation, service/technology with justification of the innovativeness of the product. At the same time, a detailed description of the operation, service/technology must be additionally attached in free form, including in graphical and schematic forms.

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of July 27, 2022 No. 2022-P-12/47-4, December 17, 2025 No. 2025-P-14/67-5-(NPA))

10. The Application is considered by the National Bank within 30 (thirty) working days from the moment of receipt of the documents specified in paragraphs 8 and 9 of this Regulation.

The time spent by the Applicant (Co-applicant) on refining documents is not included in the consideration period of documents by the National Bank, unless otherwise provided by this Regulation.

At the same time, the original document and/or duly certified copies must be submitted to the National Bank. Documents submitted by foreign founders (shareholders) must be legalized in the manner established by the legislation of the Kyrgyz Republic. Documents submitted in a foreign language must contain a duly certified translation into the state and/or official languages.

If the documents received by the National Bank do not meet the requirements imposed by the National Bank and/or do not contain information (description) sufficient for their consideration and decision-making on them, the consideration period for documents starts from the date of receipt by the National Bank of documents meeting the imposed requirements.

(As amended by the Resolution of the Board of the National Bank of the Kyrgyz Republic of July 27, 2022 No. 2022-P-12/47-4)

11. During the consideration of the application, the National Bank:

• establishes the compliance of the Applicant (Co-applicant) with the requirements established by this Regulation;
• checks the compliance of the Application with the requirements established by this Regulation;
• conducts an examination of the regulatory legal acts of the Kyrgyz Republic regarding the possibility of implementing innovative technologies/solutions in banking operations/services, including virtual asset operations, within the current requirements of the legislation of the Kyrgyz Republic.

(As amended by the Resolution of the Board of the National Bank of the Kyrgyz Republic of December 17, 2025 No. 2025-P-14/67-5-(NPA))

12. If, during the consideration of the Application, it is established that the legislation of the Kyrgyz Republic does not prevent the provision of the service to the Applicant (Co-applicant) or licensing norms are provided for in the legislation of the Kyrgyz Republic, the Applicant (Co-applicant) is sent a corresponding explanation.

(As amended by the Resolution of the Board of the National Bank of the Kyrgyz Republic of December 17, 2025 No. 2025-P-14/67-5-(NPA))

13. When considering the Application, the National Bank may request additional information from the Applicant (Co-applicant) to ensure the completeness and accuracy of the information within the Application in accordance with the requirements of this Regulation, establishing a deadline for providing the information.

14. A letter with a refusal to create a special regulatory regime is sent to the Applicant (Co-applicant) indicating the reasons for the refusal, if upon completion of the consideration of the application, non-compliance of the Applicant (Co-applicant) with the requirements established by this Regulation is found, or it is revealed:

• significant risks regarding the violation of rights and/or interests of consumers of the banking operation and service;
• significant operational risks and risks related to the financing of terrorist activities and legalization (money laundering) of criminal proceeds;
• the presence of unreliable information and data in the provided documents;
• the presence of similar banking activity provided or used in accordance with the legislation of the Kyrgyz Republic;
• recognition of the service/operation proposed for testing as not meeting the criteria specified in paragraph 1 of this Regulation;
• a special regulatory regime has been initiated for testing similar operations and services or applied technologies in the conduct of operations and provision of services, more than 6 (six) months having passed since its start;
• upon submission of documents not meeting the requirements of this Regulation, or not in full volume, more than 3 (three) times, or with a violation of established deadlines.

The application of the Applicant who received a letter with a refusal to create a special regulatory regime indicating the reasons for the refusal, resubmitted within 6 (six) months from the date of official refusal to consider documents on a similar issue, shall not be considered.

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of July 27, 2022 No. 2022-P-12/47-4, December 13, 2023 No. 2023-P-12/77-1, December 17, 2025 No. 2025-P-14/67-5-(NPA))

14-1. Acceptance of applications for the creation of a special regulatory regime for testing banking operations/services and virtual asset operations, which are already provided by other subject(s) within the special regulatory regime, is carried out with the additional provision of the following information:

a) a comprehensive assessment of factors (SWOT analysis) of the proposed operation and service compared to existing special regulatory regimes testing similar operations and services. Minimum disclosure of components of the comprehensive assessment of factors (SWOT analysis) is required:

• S - strengths, with a description of the advantages of parallel testing of operations and services provided by other subject(s) within the special regulatory regime;
• W - weaknesses, with a description of the difficulties of parallel testing of operations and services provided by other subject(s) within the special regulatory regime;
• O - opportunities of the external environment, with a description of the result of implementing innovative services/technologies in the market of banking and payment services;
• T - threats of the external environment, with a description of possible risks of parallel testing of operations and services provided by other subject(s) within the special regulatory regime;

b) proposals for improving the regulatory legal acts of the National Bank, which will contribute to the implementation of innovative services/technologies in the market of banking and payment services.

(As amended by the Resolutions of the Board of the National Bank of the Kyrgyz Republic of December 13, 2023 No. 2023-P-12/77-1, December 27, 2024 No. 2024-P-12/71-2-(NPA), December 17, 2025 No. 2025-P-14/67-5-(NPA))

Chapter 4. Creation of a Special Regulatory Regime

15. The Committee, based on the considered documents included in the Application, makes the following decisions:

• on the creation or refusal to create a special regulatory regime;
• on the issuance or refusal to issue a license for the right to conduct a limited list of banking operations within the special regulatory regime;
• on determining the restrictions of the special regulatory regime;
• on approving the criteria for evaluating success based on quantitative and qualitative indicators of the proposed testing;
• on the conditions for providing services and/or full/partial exemption of participants from the execution of individual requirements of the regulatory legal acts of the National Bank during testing;
• on establishing the conditions for terminating the validity of the special regulatory regime;
• on authorizing a structural department with responsibility for conducting the special regulatory regime;
• on extending the term of the special regulatory regime;
• on establishing additional requirements for economic standards for the Participant of the special regulatory regime, taking into account the features of the proposed operation for testing;
• upon successful testing, on extending the term of the license until the introduction of corresponding changes into the regulatory legal acts of the Kyrgyz Republic;
• on recognizing the testing within the special regulatory regime as successful or unsuccessful;
• on suspending or revoking the license for the conduct of banking operations/services and virtual asset operations within the special regulatory regime upon detection of violations of the requirements of the legislation of the Kyrgyz Republic.