Regulatory AlertsKyrgyzstan: crypto & digital assets regulation
Partially regulatedNBKR regulates bank VASPs; non-bank crypto regime uncertain
- Lead regulator
- National Bank of the Kyrgyz Republic (NBKR)
- Also involved
- —
- Core law
- Procedure for Providing Services Related to Virtual Assets (2023)
- Entry capital
- —
- Approval timeline
- —
- Customer assets
- Banks only; non-bank custody unregulated
- Data protection
- Law on Personal Data Protection · NBKR
- Sandbox
- Yes - Special Regulatory Regime
The National Bank of the Kyrgyz Republic (NBKR) regulates virtual asset services exclusively through the banking sector. The 2023 Procedure mandates that commercial banks obtain specific licensing and consent to provide virtual asset services, primarily transfers and custody. There is no publicly documented licensing regime for non-bank crypto exchanges or custodians, creating a regulatory gap for direct-to-consumer crypto businesses.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Exchange / trading platform | Uncertainverify with regulator Non-bank exchange licensing not defined in source docs | — | — | — |
| Custody of client assets | LicenceBank VASP Consent[1] Available only to licensed commercial banks under 2023 Procedure | — | — | National Bank of the Kyrgyz Republic |
| Token issuance / public offering | Uncertainverify with regulator No specific token issuance framework identified | — | — | — |
| Broker-dealer / OTC desk | Uncertainverify with regulator No specific broker-dealer regime for crypto identified | — | — | — |
| Stablecoin issuance | Uncertainverify with regulator No stablecoin regulation identified | — | — | — |
| Crypto payments acceptance | LicenceBank VASP Consent[1] Transfers allowed for banks under 2023 Procedure | — | — | National Bank of the Kyrgyz Republic |
| Mining / staking services | Unregulated Mining/staking not covered by banking VASP rules | — | — | — |
| Advisory / portfolio management | Uncertainverify with regulator No specific advisory licensing identified | — | — | — |
New — what changed recently
- 2023-02-03Procedure for Providing Services Related to Virtual Assets — NBKR established licensing and operational requirements for banks acting as VASPs.[1]
Market-entry checklist
- 1Secure banking partnershipPartner with a licensed commercial bank to access VASP services as non-banks are not regulated.
- 2Verify bank VASP consentConfirm the partner bank has obtained NBKR consent under Decision No. 2023-P-14/8-2-(NPA).
- 3Assess sandbox eligibilityExplore the Special Regulatory Regime for testing innovative services if standard licensing is unavailable.
- 4Review AML complianceEnsure strict adherence to NBKR AML/CFT requirements for virtual asset transactions.