Instruction on Conducting Inspector Checks of Payment System Operators and Payment Organizations

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Creation date: 2026-07-16

Appendix to the Resolution of the Board of the National Bank of the Kyrgyz Republic of July 6, 2026

No. 2026-P-12/35-3-(PS)

INSTRUCTION

on the supervision of the activities of payment system operators and payment organizations

Chapter 1. General Provisions

1. This Instruction on the supervision of the activities of payment system operators and payment organizations (hereinafter – the Instruction) defines the basic principles and procedures for carrying out external (remote) supervision and inspector checks of the activities of payment system operators and payment organizations (hereinafter – supervised organizations) conducting activities based on license(s) of the National Bank of the Kyrgyz Republic (hereinafter – the National Bank).

2. The National Bank supervises supervised organizations' compliance with the requirements of the legislation of the Kyrgyz Republic, including requirements in the field of combating the financing of criminal activities and money laundering (hereinafter – AML/CFT). Information on the results of supervision in the field of AML/CFT is sent by the National Bank to the financial intelligence agency in the manner established by legislation in the field of AML/CFT.

3. Supervision of the activities of supervised organizations is carried out by the National Bank through inspector checks and external (remote) supervision.

These forms of supervision mutually complement each other in the implementation of the National Bank's supervisory functions.

4. Interaction and information exchange between the National Bank and supervised organizations are important elements of supervision. The National Bank, within the framework of carrying out supervisory functions, interacts with supervised organizations through negotiations, meetings, and correspondence, including when considering the report on the results of an inspector check and during external (remote) supervision.

5. For the purposes of this Instruction, the following abbreviations and definitions are used:

• curator – an employee of the National Bank authorized to carry out external (remote) supervision of the activities of supervised organizations assigned to him;

• inspection group – a group of employees of the National Bank specified in the inspection order, whose powers include performing tasks and functions for conducting an inspector check of the activity of a supervised organization, as defined in this Instruction;

• authorized structural subdivision – a structural subdivision of the National Bank carrying out supervision functions over the activities of supervised organizations;

• supervisory management body – the management body of a supervised organization carrying out general management of its activities and accountable to the highest management body of the supervised organization in accordance with the legislation of the Kyrgyz Republic and the organization's constituent documents;

• executive management body – the management body of a supervised organization carrying out current management of its activities and accountable to the supervisory (if any) or highest management body of the supervised organization in accordance with the legislation of the Kyrgyz Republic and the organization's constituent documents.

Other terms and definitions in this Instruction are used in the meanings established by the legislation of the Kyrgyz Republic.

6. During supervision, the National Bank, as well as authorized employees of the National Bank (inspection group/curator), have the right to request and receive any information and documents necessary for carrying out supervisory functions, concerning the activities of supervised organizations, participants, agents, sub-agents, goods/service providers, electronic money acquirers, trade and service enterprises, and other counterparties participating in providing payment services based on contractual relations, as well as persons associated with supervised organizations, subsidiaries, and dependent organizations; require explanations on the received information and, if necessary, receive copies of confirming documents certified by the signature of the head/other authorized person and the seal of the supervised organization.

The requested information and documents are provided within the timeframes specified in the request of the National Bank, inspection group, and/or curator.

Chapter 2. Principles and Procedure for Carrying Out External (Remote) Supervision

7. External (remote) supervision represents continuous interaction between the National Bank and supervised organizations, based on monitoring and analysis of the activities of supervised organizations.

Within the framework of carrying out external (remote) supervision, a curator from among the employees of the authorized structural subdivision is assigned to each supervised organization. In order to ensure continuity of supervision, curators may replace each other during their temporary absence.

8. Within the framework of carrying out external (remote) supervision, the curator has the right to hold meetings with employees and officials of the supervised organization, other authorized representatives, members of the executive management body, members of the supervisory management body (if any), as well as with founders/participants/shareholders (including at the initiative of the supervised organization). If necessary, meetings may be recorded/documentary, including by audio recording.

9. For the purposes of external (remote) supervision, the curator has the right to send requests to the supervised organization, including by email from the National Bank domain (***@nbkr.kg), for the provision of necessary information (statistical data, tables, questionnaires, reports, opinions, and other information concerning the activities of the supervised organization).

10. Requests for the provision of information and documents sent by the head of the authorized structural subdivision of the National Bank by email from the National Bank domain (***@nbkr.kg) within the framework of carrying out supervisory functions with notification of the curator of the supervised organization are equated to requests of the curator of the supervised organization.

11. In case of a visit to the supervised organization by the curator within the framework of carrying out external (remote) supervision, the supervised organization must ensure access to the premises of the supervised organization, to the requested documentation, materials, and to the automated/information systems of the supervised organization (in view mode). The visit to the supervised organization is carried out by the curator based on a corresponding notification signed by the head of the authorized structural subdivision or a person replacing him.

The curator has the right to receive detailed explanations on the activities of the supervised organization from officials and employees of the supervised organization.

12. Supervised organizations are obliged to timely submit reports, documents, and any information concerning the activities of the supervised organization at the request of the National Bank. The date of receipt of correspondence on paper is considered the date of its registration in the National Bank. Electronic correspondence should be sent to the email address of the National Bank mail@nbkr.kg, unless another email address with the National Bank domain (***@nbkr.kg) is specified in the request of the authorized subdivision of the National Bank. The date of receipt of electronic correspondence is considered the date indicated in the system message about the delivery/receipt of the corresponding message.

13. External (remote) supervision of the activities of supervised organizations is carried out on a continuous basis through the analysis of provided reporting and other information about the activities of supervised organizations, as well as interaction with employees and officials of supervised organizations.

14. External (remote) supervision is a continuous activity of the National Bank, which includes, at a minimum, the following:

1. analysis of the activities of the supervised organization based on data from periodic regulatory reporting, materials of inspector checks of the activities of the supervised organization, internal and external audits, as well as other information received from the supervised organization, structural subdivisions of the National Bank, and/or other sources;

2. analysis of quantitative and qualitative indicators of activities for accepting and conducting payments and settlements for goods and services;

3. analysis of activity indicators for accepting, processing, and issuing financial information (processing, clearing) for payments and settlements of participants of the payment system;

4. analysis of indicators for the issuance, distribution, and redemption of electronic money by the supervised organization;

5. analysis of indicators for providing acquiring services by the supervised organization;

6. analysis of other operations and services carried out by the supervised organization in accordance with the legislation of the Kyrgyz Republic and the license issued by the National Bank;

7. identification of risks and factors capable of affecting the stability of the activities of the supervised organization and the continuity of providing payment services;

8. control over the compliance of the supervised organization with the requirements of the legislation of the Kyrgyz Republic and the execution of recommendations/warnings and impact measures adopted in relation to the supervised organization.

15. The results of external (remote) supervision are used by the National Bank, including when determining the need to conduct an inspector check, its subject, and scope.

16. Based on the results of external (remote) supervision, the National Bank, if necessary, applies impact measures in relation to the supervised organization and its officials in accordance with the legislation of the Kyrgyz Republic and normative legal acts of the National Bank.

Chapter 3. Goals of Conducting Inspector Checks

17. The main goals of conducting inspector checks of the activities of a supervised organization are:

• assessment of the overall financial condition of the supervised organization, as well as the effectiveness of the risk management system and internal control;

• identification and assessment of risks in the activities of the supervised organization that may threaten the continuity of functioning and efficiency of the payment system or the settlement system using electronic money;

• verification of compliance by the supervised organization with the requirements of the legislation of the Kyrgyz Republic and normative legal acts of the National Bank;

• assessment of the reliability of financial reporting and other information provided by the supervised organization to the National Bank;

• development of recommendations for eliminating identified violations and deficiencies of the supervised organization and reducing its risks, and if necessary – applying preventive measures and/or impact measures;

• assessment of the performance by the supervised organization of recommendations and directives of the National Bank, sent as a result of the previous inspector check and/or during external (remote) supervision.

Chapter 4. Types of Inspector Checks

18. Inspector checks, depending on the tasks set, can be comprehensive and targeted.

19. A comprehensive check is aimed at assessing the overall financial condition of the supervised organization, the effectiveness of the risk management system and internal control, compliance with the requirements of the legislation of the Kyrgyz Republic and normative legal acts of the National Bank of the Kyrgyz Republic regulating the activities of the supervised organization, as well as identifying risks, deficiencies in the activities of the supervised organization that may threaten its stability and stability.

20. A targeted check involves checking one or several areas of activity of the supervised organization. Targeted checks can be planned and unplanned. A planned check of a supervised organization is carried out in accordance with the National Bank's inspection plan and, as a rule, no more than once a year.

21. Inspector checks may be conducted with prior notification of the supervised organization, as well as without prior notification of the upcoming check (unplanned checks).

22. An inspector check of a supervised organization is conducted based on an order for conducting an inspector check (hereinafter – inspection order). The inspection order may be signed by:

• the head of the authorized structural subdivision or a person replacing him;

• the head of the regional management/Director of the National Bank's Representation in the Batken region or persons replacing them, at the location of the supervised organization.

23. During the inspector check, the inspection order is presented to the head of the supervised organization or other authorized person directly upon the arrival of the inspection group.

24. Conducting unplanned inspector checks may be carried out based on the decision of one of the persons specified in paragraph 22 of this Instruction, in the following cases:

• identification of facts violating the continuity of functioning of the payment system and the settlement system using electronic money;

• the presence of signs of fraud, abuses, and other violations of the legislation of the Kyrgyz Republic and normative legal acts of the National Bank of the Kyrgyz Republic in the activities of the supervised organization, including based on appeals from individuals and legal entities and/or other sources;

• identification through monitoring/analysis of provided reporting of negative trends capable of leading to a deterioration in the stability of the activities of the supervised organization, violation of the continuity of providing payment services or the settlement system using electronic money, or the emergence of doubts about the completeness and reliability of reporting/information provided to the National Bank;

• identification of violations by the supervised organization of the requirements of the legislation of the Kyrgyz Republic and normative legal acts of the National Bank;

• non-execution of requirements, directives, and/or decisions of the National Bank;

• the need to check the execution by the supervised organization of directive(s) and/or requirements of the National Bank, adopted in relation to the supervised organization within the framework of applying impact measures;

• there is information/appeals about disagreements (conflicts) between founders/participants/shareholders, officials of the supervised organization (associated with the supervised organization), as well as other events or circumstances that may lead to a violation of the uninterrupted functioning of the payment system, and/or settlement systems using electronic money, and/or non-performance of obligations to users of payment services;

• receipt of information from law enforcement and other state bodies about illegal activities of the supervised organization or other circumstances requiring the conduct of an inspector check.

Chapter 5. Procedure for Conducting Inspector Checks

25. An inspection group consisting of at least two people is formed for the inspector check, which may include representatives of structural subdivisions of the National Bank and/or the regional management/National Bank's Representation in the Batken region. A head and a member/members of the inspection group are appointed within the inspection group (hereinafter – authorized representatives of the National Bank). The document confirming the powers of the authorized representatives of the National Bank to conduct an inspector check of the supervised organization is the inspection order signed by the person specified in paragraph 22 of this Instruction (Appendix 1 to this Instruction).

26. The term of the inspector check is specified in the order for conducting an inspector check of the activities of the supervised organization.

If necessary, the term of the inspector check may be extended in the manner provided for in paragraph 33 of this Instruction.

At the same time, the total term of the inspector check, including the extension of the term, cannot exceed 60 (sixty) working days.

27. If the inspector check is not unplanned, the head of the check sends a notification letter to the supervised organization with an attachment of the list of documents/information/accesses to systems (in view mode) necessary to be provided on the subject of the check (according to the form of Appendix 2 to this Instruction) no later than 10 (ten) working days before the start of the inspector check.

The list of documents/information/accesses to systems specified in Appendix 2 to this Instruction may change/be supplemented in each specific case depending on the tasks, goals, terms of the inspector check, and the specifics of the activities of the supervised organization.

28. The date of the start of the inspector check is considered the date specified in the inspection order, or the date of handing over the inspection order by the National Bank inspection group to the head/other authorized person of the supervised organization.

29. The original of the inspection order is transferred to the head/other authorized person of the supervised organization. A copy of the inspection order with a mark of the date and time of handing over, certified by the signature of the head/other authorized person and the seal of the supervised organization, is transferred by the supervised organization to the authorized representatives of the National Bank.

30. Upon arrival at the location of the inspector check, the head of the inspection group holds a meeting with the head of the supervised organization (or a person performing his duties) for the following purposes:

• for handing over the inspection order, informing about the scale and tasks of the inspector check;

• for discussing the upcoming process of conducting the inspector check;

• for introducing the member/members of the inspection group with the indication of the areas of work assigned to him/them;

• for determining the order of interaction and contacts with officials and employees of the supervised organization;

• for providing explanations to representatives of the supervised organization on the subject of the inspector check.

31. On the first day of the inspector check, the supervised organization is obliged to provide all documents/information/accesses to systems specified in the notification letter sent in accordance with paragraph 27 of this Instruction. In case of non-provision of the specified documents/information/accesses to systems, an act confirming the established facts and/or events of the inspector check is drawn up in accordance with paragraph 40 of this Instruction.

32. During the period of the inspector check, the supervised organization is obliged to provide the inspection group with a separate room with equipped workstations. The room must not contain audio and/or video recording devices. In case there are audio and/or video recording devices in the provided room, the supervised organization provides the inspection group with a written commitment that during the inspector check in this room the devices will be disconnected and audio and/or video recording will not be carried out.

33. In case of necessity to extend the term of the inspector check, change the composition of the inspection group, and/or include additional questions for checking, an addendum to the inspection order is drawn up, which is also handed over to the head/other authorized person of the supervised organization on the day of its entry into force (the day of entry into force of the addendum to the inspection order is considered the date of its signing and registration in the National Bank). The addendum to the inspection order is an integral part of the inspection order.

34. During the inspector check, the supervised organization provides the inspection group with original documents for familiarization and study. In exceptional cases, when it is impossible to provide original documents for objective reasons, the supervised organization provides copies of documents certified by the signature of the head/other authorized person and the seal of the supervised organization, with an indication of the reasons for non-provision of original documents in writing.

At the request of the inspection group, the supervised organization provides electronic versions of the requested documents (if available).

35. During the inspector check, the management and personnel of the supervised organization must provide the inspection group with comprehensive assistance.

36. The inspector check may be terminated before the expiration of the established check term in the event of circumstances preventing the inspection group from accessing the place of the check and necessary documents/records of the automated/information system, due to the sealing of the premises of the supervised organization by authorized state bodies.

In the event of circumstances specified in this paragraph, the inspector check may be initiated again after the completion of measures by the authorized state body.

37. Authorized representatives of the National Bank have the right:

• to receive free access to places of activity of the supervised organization;

• to timely receive and check documents and information of the supervised organization, including conducting checks of the activities of agents/sub-agents of the supervised organization. In this case, the supervised organization must provide assistance in obtaining information and access to the premises, systems, and records of the agent/sub-agent;

• if necessary, to receive copies of corresponding documents certified by the signature of the head/other authorized person and the seal of the supervised organization for inclusion in the materials of the inspector check;

• to receive oral and written explanations from the supervised organization, officials, and employees of the supervised organization on issues of its activities;

• to conduct discussions on issues arising during the inspector check directly with employees of the supervised organization who prepared and provided the requested information, with the agreement of the management or other authorized person of the supervised organization;

• at any stage of the inspector check, to keep minutes of meetings and negotiations with officials and employees of the supervised organization by audio and/or video recording. At the same time, before the start of negotiations, all participants must be warned about the carrying out of audio and/or video recording;

• to request documents and information to assess measures to ensure the effectiveness and continuity of functioning of the payment system and the settlement system using electronic money (if the corresponding license is present);

• upon request, to obtain the right of access to automated/information systems of the supervised organization with the ability to receive information about all operations conducted (reading, forming, and printing reports), as well as, if necessary, to receive data dumps and reports from the specified systems;

• to request and receive from the supervised organization and participants of the payment system any documents and information on issues concerning the functioning of the payment system and the settlement system using electronic money (if the corresponding license is present).

38. In the event of the introduction of a special regime, authorized representatives of the National Bank perform actions established by the decision of the National Bank's Supervision Committee on the introduction of a special regime and the Regulation "On Impact Measures Applied to Payment System Operators/Payment Organizations", approved by the Resolution of the Board of the National Bank of September 30, 2019 No. 2019-P-14/50-3-(PS).

39. In case of obstruction of the inspector check by the supervised organization, the head of the check draws up an act on obstruction of the inspector check according to the form specified in Appendix 3 to this Instruction (hereinafter – act on obstruction) in two copies (one copy for the National Bank and the supervised organization).

Obstruction in conducting the inspector check is considered:

• non-provision of access to authorized representatives of the National Bank to places of activity of the supervised organization;

• non-provision