Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the National Bank licence, including banking and payment rails.
Get a payment license in Kyrgyzstan.
The Law on the Payment System of the Kyrgyz Republic No. 21 of 21 January 2015 gives the National Bank two licences to grant: one for a payment organisation that accepts and executes payments, one for a payment system operator that runs the processing and clearing behind them. An amendment of 28 April 2025 added a third possibility, letting a payment organisation issue electronic money with an extra permission attached to its licence. Capital was raised the same year: 30 million som for a new payment organisation, 20 million for an operator, 50 million for both, and 90 million upward for e-money. The National Bank decides in 30 calendar days, the licence it grants is perpetual and cannot be transferred, and the register carried 57 payment organisations and 56 operators in August 2026.
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Licenses obtainedlicenses obtained
Updated
Kyrgyzstan in brief
Two licences, a 30-day clock, and e-money opened to non-banks in 2025.
Law No. 21 of 21 January 2015 sets the frame. A payment organisation is a legal person holding a National Bank licence to accept and execute payments; a payment system operator holds a licence for the processing and clearing that sits behind them. Article 26(1)(1) gives the National Bank the power to issue the permission, licence or certificate, and Article 3(5) leaves the application form, the documents and the procedure to the National Bank's own acts, which is where most of the working rules live. Law No. 86 of 28 April 2025 changed the shape of the market: Article 2(22) now counts a payment organisation holding the corresponding permission among the issuers of electronic money, alongside the National Bank and the banks. Article 6 governs that issue - e-money is put out as instruments, the issuer is obliged to redeem it to the bearer under Article 6(7), and distributors are allowed under Article 6(5). Agency contracts sit in Article 3(2). There is no passport and no registration-only route for small providers: a business either holds the licence or it does not.
The money moved in 2025. The National Bank's resolution of 30 April 2025, amended on 31 October, sets the minimum authorised capital for new applicants at 30 million som for a payment organisation, 20 million for a payment system operator and 50 million for both. A payment organisation issuing electronic money needs 90 million, 120 million with one additional service type and 150 million with both; cross-border payments or tax collection cost 60 million, card acquiring 80 million, the two together 110 million. Existing licensees climb a ladder instead: operators to 8, 15 and 20 million and payment organisations to 10, 20 and 30 million som by 1 October 2025, 2026 and 2027. The licensing regulation gives the National Bank 30 calendar days to decide, after a preliminary check of no more than 10 working days, and the licence it grants is perpetual and non-transferable. Electronic money is backed one for one: the payment organisation holds a special account whose balance matches the e-money in issue. The register created on 26 August 2026 lists 57 payment organisations and 56 operators. Profit tax is 10% and VAT 12%.
Law No. 21 of 21 January 2015 gives the National Bank two licences: payment organisation and payment system operator. Law No. 86 of 28 April 2025 lets a payment organisation issue electronic money on an extra permission. Article 6(7): the issuer must redeem to the bearer.
Capital since the 2025 resolution: 30 million som for an organisation, 20 million for an operator, 50 million for both, 90 to 150 million for e-money. Decision in 30 calendar days after a 10-working-day pre-check. Perpetual, non-transferable licence. 57 organisations and 56 operators in August 2026. Tax 10%, VAT 12%.
The routes
Payment organisation, payment system operator - and the e-money permission on top.
The law names two licences and the 2025 amendment added a permission that attaches to one of them. Most groups take both licences, because the e-money route is only open to a payment organisation that already holds the operator licence. We fix the combination first, then build once.
Payment organisation, payment system operator, or both with the e-money permission.
01 - PAYMENT ORGANISATION
Licence to accept and execute payments
The licence for a business that takes payments from users and passes them on - 30 million som of authorised capital for a new applicant, 50 million if the operator licence is taken with it, and 60 or 80 million where cross-border payments, tax collection or card acquiring go on the list. A joint-stock company or a limited liability company, owned by residents or non-residents.
The licence for a business that takes payments from users and passes them on - 30 million som of authorised capital for a new applicant, 50 million if the operator licence is taken with it, and 60 or 80 million where cross-border payments, tax collection or card acquiring go on the list. A joint-stock company or a limited liability company, owned by residents or non-residents.
- ✓Acceptance and execution of payments (Law, Article 2)
- ✓Capital KGS 30,000,000 for a new applicant
- ✓KGS 50,000,000 with the operator licence
- ✓Cross-border payments or tax collection: KGS 60,000,000
- ✓Card acquiring KGS 80,000,000 · both KGS 110,000,000
- ✓Perpetual, non-transferable licence
02 - OPERATOR AND E-MONEY
E-money from KGS 90MPayment system operator, with the e-money permission
The processing and clearing licence, on 20 million som - and the door to electronic money that the April 2025 amendment opened. A payment organisation already holding the operator licence may apply for the e-money permission on 90 million som of capital, rising to 120 million with one further service type and 150 million with both.
Operator licence on KGS 20,000,000; the e-money permission needs KGS 90M-150M, two years of operation and a clean supervisory record.
- ✓Processing and clearing (KGS 20,000,000)
- ✓E-money permission for payment organisations since 2025
- ✓Capital KGS 90M / 120M / 150M for e-money
- ✓Two years of operation and a clean 12 months required
- ✓Special account backing e-money in full
- ✓Systemically important operator: KGS 310,000,000
Costs and timelines are confirmed for your case before any work begins. The state duty for an application is set by legislation rather than printed in the licensing regulation, so it is confirmed in writing with the rest of the budget.
Why Kyrgyzstan
A 30-day decision written into the rules, and e-money opened to non-banks in 2025.
Kyrgyzstan pairs the lowest profit tax in Central Asia with a written decision period and, since April 2025, an electronic money route open to non-banks. The price of entry is the capital.
✓
A statutory 30-day clock
The licensing regulation gives the National Bank 30 calendar days from the application, with a preliminary completeness check capped at 10 working days before that.Written into the licensing rules.
✓
E-money without a bank
Since Law No. 86 of 28 April 2025 a payment organisation may issue electronic money on an extra permission. Before that amendment only the National Bank and the banks could.Open since April 2025.
✓
A licence that does not expire
The licensing regulation makes it perpetual and non-transferable, so there is no renewal cycle to budget for - and no way to sell the licence separately from the company.Perpetual, non-transferable licence.
✓
Non-residents may own it
Shareholders may be individuals or legal persons, resident or not. The regulation refuses holders registered in offshore zones, persons under United Nations sanctions and undisclosed beneficial owners.Residents and non-residents alike.
✓
A crowded register
The register created on 26 August 2026 lists 57 licensed payment organisations and 56 payment system operators, with 22 licences revoked and 5 terminated.57 organisations, 56 operators.
✓
QR rails already carrying volume
The National Bank's board adopted a concept for interoperable QR-based fast payments on 26 March 2025, with phases in December 2025, October 2026 and March 2027. QR carried 67.8 million payments worth 88.4 billion som between May 2022 and 1 January 2025.Fast-payment phases to March 2027.
How it compares
How Kyrgyzstan differs from the other Central Asian routes.
Kyrgyzstan asks for more capital than its neighbours and gives back the lowest tax rate and a decision period written into the rules. The honest comparison is below.
Kyrgyzstan vs other jurisdictions
| Feature |  Kyrgyzstan | Other jurisdictions |
|---|---|---|
| Capital | KGS 30M organisation · 20M operator · 90M e-money | EUR 20,000-350,000 in the EU |
| Decision | 30 calendar days · 10-working-day pre-check | 3 months, or none |
| Licence term | Perpetual, non-transferable | Perpetual with annual supervision fees |
| Corporate tax | 10% · VAT 12% | 15-20% in the region |
Capital
KyrgyzstanKGS 30M organisation · 20M operator · 90M e-money
Other jurisdictionsEUR 20,000-350,000 in the EU
Decision
Kyrgyzstan30 calendar days · 10-working-day pre-check
Other jurisdictions3 months, or none
Licence term
KyrgyzstanPerpetual, non-transferable
Other jurisdictionsPerpetual with annual supervision fees
Corporate tax
Kyrgyzstan10% · VAT 12%
Other jurisdictions15-20% in the region
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Kyrgyzstan | Payment organisation · operator (NBKR) | 10% · VAT 12% | KGS 30M · 30-day decision |
 Kazakhstan | NBK registration · AFSA PMS | 20% · AIFC 0% | USD 50k base in AIFC |
 Uzbekistan | Payment organisation (CBU) | 15% CIT | CBU licence · 30-day review |
 Armenia | Payment organisation (CBA) | 18% CIT | AMD 100M total capital |
KyrgyzstanLicense typePayment organisation · operator (NBKR)
Taxation10% · VAT 12%
RequirementsKGS 30M · 30-day decision
KazakhstanLicense typeNBK registration · AFSA PMS
Taxation20% · AIFC 0%
RequirementsUSD 50k base in AIFC
UzbekistanLicense typePayment organisation (CBU)
Taxation15% CIT
RequirementsCBU licence · 30-day review
ArmeniaLicense typePayment organisation (CBA)
Taxation18% CIT
RequirementsAMD 100M total capital
Before you apply
Requirements for the NBKR licence.Requirements for the licence.
The law sets the categories and the National Bank's acts set everything else: the legal form, the capital, the documents and the clock. The checklist below is what a passing file contains.
01
A joint-stock company or a limited liability company registered in the Kyrgyz Republic - the licensing regulation admits no other legal form.
02
Authorised capital at the level set by the resolution of 30 April 2025: 30 million som for a payment organisation, 20 million for a payment system operator, 50 million for both licences together.
03
For electronic money, 90 million som of capital, 120 million with one additional service type and 150 million with both, plus the permission attached to the licence.
04
At least two years of operation, the processing and clearing licence, and no enforcement measures in the previous twelve months before the National Bank grants the e-money permission.
05
Shareholders and participants identified - individuals or legal persons, resident or non-resident - with beneficial owners disclosed and the source of funds proved.
06
No shareholder registered in an offshore zone and no person subject to United Nations Security Council sanctions in the ownership chain.
07
A special account arrangement for electronic money, holding funds equal to the e-money in issue, with the issued balance matching the amount on the bank's balance sheet.
08
The application form and the documents in the shape the National Bank's acts prescribe under Article 3(5) of the law, since the statute itself sets none.
09
Information-security arrangements checked at least once every six months, five-year data retention and answers to the National Bank inside fifteen working days.
10
Operations started within twelve months of the licence being granted.
01
Kyrgyz joint-stock or limited liability company.
02
Capital KGS 30M / 20M / 50M by licence.
03
E-money: KGS 90M / 120M / 150M plus permission.
04
Two years of operation before the e-money permission.
05
Owners identified to the beneficial owner.
06
No offshore or sanctioned shareholders.
07
Special account backing e-money in full.
08
Documents in the form NBKR acts prescribe.
09
Security checks every six months, 5-year retention.
10
Operations started within twelve months.
Reflects Law No. 21 of 21 January 2015 as amended by Law No. 86 of 28 April 2025, the licensing regulation of 2 September 2019 as amended to 2 March 2026, the capital resolution of 30 April 2025 as amended on 31 October 2025 and the electronic money regulation of 20 April 2022, as of 2026.Law No. 21 (2015) as amended by Law No. 86 (2025); licensing regulation 2019 (am. 02.03.2026); capital resolution 30.04.2025; e-money regulation 2022.
How it works
From first call to the NBKR register.
01
Route and strategy
Payment organisation, operator, both, or both with the e-money permission; the capital level and budget fixed in writing.One licence, both, or both plus e-money.
02
Company and capital
Kyrgyz company formed, authorised capital paid to the 2025 resolution's figure, owners and beneficial owners documented.Formed, capital paid, owners documented.
03
The application file
Documents assembled in the form the licensing regulation prescribes, with the special-account arrangement where e-money is in scope.Prescribed documents; special account.
04
NBKR review
A preliminary check of up to 10 working days, then the 30-calendar-day decision; missing documents restart the period - plan on six to nine months end to end.10-day pre-check, 30-day decision.
05
Licence and launch
Perpetual licence granted and entered in the register, operations started inside the twelve-month window, reporting running.Register entry; start within 12 months.
Quick facts
RegulatorNational Bank of the Kyrgyz Republic
LawPayment System Law No. 21 (2015)
LicencesPayment organisation · system operator
CapitalKGS 30M / 20M / 50M
E-moneyKGS 90M-150M with permission
Decision30 calendar days
Timeline6-9 months realistic
Corporate tax10% · VAT 12%
The 30-day period runs on a file the National Bank accepts, and a request for more documents restarts it. Getting the first submission right is what keeps the review inside the month, and our job.
Your Kyrgyzstan desk
Run from our CIS and Central Asia desk.
Prifinance - CIS & Central Asia desk
Tallinn · coordinating Kyrgyz mandates
Roseni 13, Tallinn
01
Kyrgyz company formation
A joint-stock or limited liability company with the authorised capital paid to the resolution's level, and ownership documented to the beneficial owner.Capital paid, owners documented.
02
The NBKR file
Application, documents and policies in the form the National Bank's licensing regulation prescribes - drafted by us in Russian and defended through the review.Documents in the prescribed form.
03
E-money permission
The two-year operating record, the operator licence and the special-account arrangement prepared before the e-money application goes in.Operator licence and special account.
04
Substance in Bishkek
Management, information-security arrangements checked twice a year and the reporting calendar the National Bank's rules assume.Management, security checks, reporting.
We also have offices in
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Kyrgyzstan.
A 10% profit tax, 12% VAT, a sales tax of 1% to 5% by activity and a flat 10% on personal income - the lightest headline rates in Central Asia.
Profit tax 10%
The State Tax Service sets the profit tax rate at 10%, the lowest of the Central Asian jurisdictions a payment group usually compares.Lowest headline rate in the region.
VAT 12%
The standard rate. Which of a payment organisation's fees fall inside the VAT base is confirmed with the tax service against your product list, since the general regime pages print the rate rather than the exemptions.Exemption position confirmed per product.
Sales tax 1-5%
A turnover tax alongside profit tax, running from 1% to 5% by activity. The rate that applies to a licensed payment business is confirmed before the budget is signed off.By activity, alongside profit tax.
Personal income tax 10%
A flat 10% on salaries, withheld at source, which keeps the cost of a Bishkek compliance and technology team predictable.Flat, withheld at source.
Dividends to non-residents
The tax service's public pages do not print a non-resident dividend rate, and the Tax Code text was not readable at the source. The withholding position is confirmed for your structure before profits move.Rate not printed on public pages.
Payroll
Salaries carry the 10% income tax and social contributions. A licensee budgets for the compliance and information-security roles the National Bank's rules assume.Income tax + social contributions.
Tax summary
Profit tax10%
VAT12%
Sales tax1-5% by activity
Personal income tax10%
Dividend withholdingNot printed on public pages
PayrollIncome tax + social contributions
*Figures as of 2026 per the State Tax Service of the Kyrgyz Republic. Treaty and regime positions are assessed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Kyrgyz company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed organisation.
Follow Prifinance
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Kyrgyzstan · NBKR
Launch your payment project in Kyrgyzstan with expert support.
Full-service assistance - from company formation to the National Bank licence, the e-money permission, special accounts and ongoing compliance.
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The Kyrgyz payment licence, answered.
What licence does a payment business need in Kyrgyzstan?+
One of two from the National Bank under the Law on the Payment System No. 21 of 21 January 2015: a payment organisation licence to accept and execute payments, or a payment system operator licence for the processing and clearing behind them. Many applicants take both, on 50 million som of capital.
How much capital is required?+
Under the National Bank's resolution of 30 April 2025: 30 million som for a new payment organisation, 20 million for an operator and 50 million for both. Cross-border payments or tax collection raise it to 60 million, card acquiring to 80 million, and the two together to 110 million.
Can a payment organisation issue e-money?+
Since Law No. 86 of 28 April 2025, yes, with the corresponding permission attached to the licence. Capital is 90 million som, 120 million with one additional service type and 150 million with both. The National Bank expects at least two years of operation, a processing and clearing licence and a clean twelve months of supervision first.
What happens to licensees that held less capital?+
They climb the transition ladder in the same resolution: operators to 8, 15 and 20 million som and payment organisations to 10, 20 and 30 million by 1 October 2025, 2026 and 2027. Holders of both licences go to 18, 35 and 50 million.
How long does the National Bank take?+
The licensing regulation prints 30 calendar days for the decision, after a preliminary check of no more than 10 working days. If documents are missing, the applicant has 30 calendar days to supply them and the period restarts on resubmission. Plan on six to nine months from first call.
How long is the licence valid?+
It is perpetual and cannot be transferred. Operations have to start within twelve months of the grant, and the licence has no renewal date after that.
How is electronic money backed?+
The electronic money regulation requires a special account holding funds equal to the e-money in issue, and the issued balance must match the amount on the bank's balance sheet. Redemption to the bearer is an obligation under Article 6(7) of the law, and the regulation forbids extra charges or commissions on it.
Can foreigners own the licensee?+
Yes. Shareholders and participants may be individuals or legal persons, resident or non-resident. The regulation refuses persons registered in offshore zones, persons under United Nations Security Council sanctions, undisclosed beneficial owners and anyone who cannot prove the source of the funds.
How are payment companies taxed?+
Profit tax is 10% and VAT 12%, with a sales tax of 1% to 5% by activity and a flat 10% personal income tax. The tax service's public pages do not print a non-resident dividend rate, so that position is confirmed for your structure.
Why Kyrgyzstan rather than Kazakhstan or Uzbekistan?+
Kyrgyzstan has the lowest profit tax of the three at 10%, a 30-day decision written into the rules and, since 2025, an e-money route open to non-banks. Kazakhstan offers the AIFC with a USD 50,000 base and a 0% regime inside the centre. Uzbekistan is the larger domestic market at 15%. Kyrgyzstan's cost is the capital: 30 million som, and 90 million for e-money.
Which licence?+
Payment organisation or system operator (NBKR).
Capital?+
KGS 30M, 20M, or 50M for both.
E-money?+
Yes, with a permission; KGS 90M-150M.
Existing licensees?+
Ladder to 2027 under the same resolution.
How long?+
30 calendar days after a 10-day pre-check.
Licence term?+
Perpetual, non-transferable.
E-money backing?+
Special account, matched in full.
Foreign owners?+
Allowed; no offshore or sanctioned holders.
Taxes?+
Profit 10%, VAT 12%, sales tax 1-5%.
vs Kazakhstan / Uzbekistan?+
Lowest tax and a printed clock; higher capital.
Client notes
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the National Bank of the Kyrgyz Republic or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.