The financial market of Kyrgyzstan has undergone active modernization in recent years. One of the key directions has been the digitalization of payments and the growth of the fintech sector. To legally provide services for payment acceptance, processing, money transfers, and electronic wallets, companies must obtain a special permit — a license for payment services and systems. This license is issued by the National Bank of the Kyrgyz Republic (NBKR).
Why a Payment Services License is Required
A license grants an organization the legal right to:
- accept payments for goods and services of third parties;
- operate electronic settlement systems;
- carry out domestic and cross-border money transfers;
- provide processing and clearing between banks and non-bank institutions.
This is one of several types of financial licenses in Kyrgyzstan. Without it, a company cannot legally operate in the payments industry and risks heavy fines or a ban on activity.
Types of Licenses
Although formally the NBKR issues a single “license for payment services and systems,” within it there are different categories depending on the type of activity:
- Payment System Operators
- responsible for organizing the system itself;
- ensure processing, clearing, and settlements between participants;
- include both national and international systems.
- Payment Organizations (service operators)
- work directly with end users;
- provide services for payment acceptance, transfers, and e-wallets;
- most often these are non-bank fintech companies.
- Agents and Subagents
- act on behalf of a licensed operator;
- do not need a separate license, but must be registered with the NBKR.
Thus, a company may obtain authorization for individual services (e.g., acquiring or remittances) or a comprehensive license covering multiple areas.
Regulatory Framework
The main rules are set by:
- the Law of the Kyrgyz Republic “On the National Bank”;
- the Law “On the Payment System”;
- the Regulation on Licensing of Payment Organizations (approved by NBKR).
These documents establish requirements for charter capital, ownership structure, staffing, and the technical infrastructure of a company.
Requirements for Applicants
To obtain a license, an applicant must meet the following conditions:
- Minimum capital — at least 50 million KGS;
- Legal entity — must be registered in Kyrgyzstan (usually an LLC/OsOO);
- Shareholders and management — must undergo checks for business reputation and compliance;
- Staff — presence of specialists in IT, finance, and compliance;
- Technical base — secure servers, accounting systems, and AML/CFT procedures.
Licensing Procedure
- Document preparation: application, charter documents, details on beneficiaries, business plan, internal control rules.
- Submission: through the eLicense portal or directly to the NBKR.
- Regulator’s review: analysis of capital, security systems, and compliance.
- On-site inspection of the office — if deemed necessary.
- Decision: license issuance (review period — 1 to 3 months, longer if deficiencies are found).
The license is issued for an unlimited term, but the company must confirm compliance annually.
What if there is no office?
- For banks, MFOs, and payment operators, a physical office is mandatory — without it, a license will not be issued.
- For fintech companies (e-wallets, processors), a minimal office (legal address + server room) may be sufficient. However, the regulator must be able to inspect it.
- A “paper-only” company without a real office risks denial or revocation of its license.
- Requirements are more flexible for subagents (e.g., payment acceptance points in retail stores) — they don’t need a separate office but must be officially registered.
Market Impact
The payment services segment in Kyrgyzstan is growing rapidly. From 2020 to 2024, the number of cashless transactions more than doubled. New players emerged — mobile wallets, online acquiring, integration with marketplaces, and EAEU services.
Having a license allows companies to:
- cooperate with banks and international payment systems;
- build user trust;
- enter the EAEU market with simplified procedures;
- protect their business from illegal competitors.
Risks and Liabilities
If rules are violated, the license may be revoked. Risks include:
- failure to comply with AML requirements;
- technical failures compromising client funds;
- operating beyond the scope of declared services.
Unlicensed payment services may lead to fines and administrative penalties.
Outlook for 2025
Key trends include:
- growth of mobile payments and QR technologies;
- integration with government digital services;
- development of cross-border transfers within the EAEU;
- stronger cybersecurity requirements.
Kyrgyzstan aims to position itself as a convenient platform for fintech startups and international investors. That is why the payment services and systems license has become a fundamental tool for operating legally in this market.