Digital Payments & Fintech - Kyrgyzstan

NBKR is the sole licensing authority and issues perpetual, non-transferable licenses across three distinct categories: payment organizations (acceptance/processing), payment system operators, and e-money issuers/operators, each carrying different permitted activities and capital thresholds.

Issuance of electronic money is an explicitly licensed activity. Operators of local and international settlement systems using e-money, issuers, and their agents/subagents must all obtain NBKR authorization; instruments covered include prepaid cards, virtual prepaid cards, and electronic wallets.

An NBKR Board Resolution (April 30, 2025, No. 2025-P-14/20-2-(PS)) raised minimum authorized capital: 15 million KGS for limited-volume payment organizations, 30 million KGS for payment system operators, 40 million KGS for cross-border transfer operators, and 100 million KGS for independent acquirers; existing licensees have until January 1, 2027 to comply.

NBKR Board Resolution approved a five-year national strategy covering RTGS, retail clearing, payment cards, money transfers, and e-money systems; a subsequent 2027–2030 phase plans cross-border interoperability with other countries' platforms and smart-contract support.

From January 1, 2025, all card-payment processing centres must be physically located within Kyrgyzstan, strengthening data security and regulatory oversight. Instant payment capabilities exist for non-bank payment system operators within the retail payment framework.

Legislation signed in 2024 granted legal tender status to the Digital Som; NBKR is running a three-phase pilot (interbank transfers → government/treasury payments → offline use) with a full implementation decision expected by late 2026. No dedicated open banking mandate or BNPL-specific regulatory regime has been identified in current Kyrgyz law.