RegAlert

Kyrgyzstan: fintech & payments regulation — 2026-09

Regulated

NBKR licenses PSOs/PSOs; VASPs via banks; no open banking

Frozen snapshot — the guide as it stood at the end of 2026-09. See the live guide for the current state.

The National Bank of the Kyrgyz Republic (NBKR) is the sole supervisor for payment organizations (POs) and payment system operators (PSOs). The regime is centralized, requiring a perpetual license and strict capitalization. Virtual assets are restricted to bank-led custody/transfers under a special regime. Open banking is not yet regulated.

Which licence do you need?

Your activityRequirementCapitalTimelineAuthority
Payment processing / gatewayLicencePayment Organization License[1][2]

Perpetual license; IFRS reporting required

KYD 100m3-6 monthsNBKR
E-money & wallet issuanceLicenceE-money Issuer License[3][2]

Domestic issuance only; strict reserve rules

KYD 100m3-6 monthsNBKR
Domestic money transferLicenceMoney Transfer System License[4][2]

Covers domestic cashless transfers

KYD 100m3-6 monthsNBKR
Cross-border remittanceLicenceMoney Transfer System License[4][5]

Cross-border transfers require NBKR registration

KYD 100m3-6 monthsNBKR
Agent networkLicencePayment Organization License[3][1]

Agents must be registered with the PSO

KYD 100m3-6 monthsNBKR
Open banking / account informationUnregulatedverify with regulator

No open banking framework exists

———
Foreign-exchange servicesLicencePayment Organization License[6][2]

FX services allowed for licensed POs

KYD 100m3-6 monthsNBKR

New — what changed recently

  • 2025-04-30Resolution No. 2025-P-14/20-1-(PS) — Established new minimum authorized capital thresholds for POs and PSOs based on service type and systemic significance.[2]
  • 2025-10-31Regulation on Anti-Fraud Systems — Mandated minimum requirements for anti-fraud systems, including real-time monitoring and risk assessment mechanisms.[7]
  • 2026-06-25Regulation on Financial Statements — Mandated IFRS compliance for financial statement preparation and submission by POs and PSOs.[8]

Market-entry checklist

  1. 1Secure NBKR LicenseApply for a Payment Organization license with KYD 100m capital.
  2. 2Establish Settlement BankOpen a settlement account with an NBKR-approved bank.
  3. 3Implement AML/CFTAdopt NBKR risk-based AML framework and appoint a compliance officer.
  4. 4Deploy Anti-Fraud SystemInstall real-time monitoring and risk assessment tools per 2025 rules.
  5. 5Prepare IFRS ReportingSet up accounting systems compliant with NBKR's 2026 financial statement rules.

Sources

  1. Regulation on the Licensing of Payment Organizations and Payment System Operators · 2019-09-02
  2. On the Minimum Size of the Authorized Capital of Payment Organizations and Payment System Operators · 2025-04-30
  3. Regulation on Electronic Money in the Kyrgyz Republic · 2022-04-20
  4. Rules for Carrying Out Money Transfers via Money Transfer Systems in the Kyrgyz Republic · 2023-07-26
  5. Resolution of the Board of the National Bank of the Kyrgyz Republic No. 2023-P-14/45-4-(PS) on Suspension of Certain Provisions of Resolution No. 30/6 Regarding Money Transfer Rules dated July 26, 2023 · 2023-07-26
  6. Regulation on Cashless Payments in the Kyrgyz Republic · 2021-12-08
  7. Regulation on Minimum Requirements for the Anti-Fraud System Against Internal and External Fraud in Payment Organizations/Payment System Operators of the Kyrgyz Republic · 2025-10-31
  8. Regulation on Requirements for the Preparation, Publication and Submission to the National Bank of the Kyrgyz Republic of Financial Statements of Payment System Operators/Payment Organizations · 2026-06-25