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 Bank of Mongolia licence, including banking and payment rails.
Get a payment license in Mongolia.
The Law on the National Payment System of 2017 gives the Bank of Mongolia every licence in Article 10.1, ten categories running from payment services and system operation to money remittance and electronic money. A non-bank electronic money issuer needs MNT 2,500,000,000 of paid-in capital; the regulation prints no minimum for the other nine. Customer funds go into a guarantee account backed 100% and ring-fenced on insolvency, e-money runs at one unit to one tugrik with no interest, and balances stop at MNT 20,000,000. Decisions are due in 60 days and cannot take more than 180, and the licence runs four years.
27 yrs
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Licenses obtainedlicenses obtained
Updated
Mongolia in brief
Ten licence categories, one capital figure, and a guarantee account that cannot be touched.
The Law on the National Payment System, adopted on 31 May 2017 and in force since 1 January 2018, put every payment activity in Mongolia under one licence-granting body: the Bank of Mongolia. Article 10.1 lists ten licensed categories, and the list repays reading in full because it is broader than most - payment services, related activities, operating a payment system, issuing and acquiring payment instruments, acting as a settlement agent, providing services through contracted agents, outsourcing, money remittance, electronic funds transfer, and issuing electronic money. The Financial Regulatory Commission has no role here. The operating detail sits in the Payment System Regulation approved by Governor's Order A-91 of 10 May 2023 and amended by Order A-195 of 30 August 2024, which also capped card acquiring prices: a merchant fee of no more than 3% of transaction value and an ATM withdrawal fee of no more than MNT 500. Capital is where the framework is deliberately thin. Regulation 3.4.1 sets a minimum paid-in capital of MNT 2,500,000,000 for a non-bank electronic money issuer and prints no minimum for the other nine categories, leaving own funds to the central bank by service type and volume.
Electronic money is defined tightly. One unit equals one tugrik, no interest is calculated on a balance, and conversion back into money happens on the customer's first demand. The float goes into a guarantee account: 100% of funds received from customers, a balance that may never fall below e-money in circulation, no lending, no investing, no pledging, and on insolvency or liquidation the account may be used only to turn customers' e-money back into money. Balances stop at MNT 20,000,000 per customer account, and an unregistered customer may hold MNT 100,000 and send MNT 40,000 a day. Article 15 gives the regulator 60 days to decide on a licence and caps the whole process at 180; the licence runs four years and is renewed on an application filed 180 days before expiry, repeatable without limit. Chapter 7 of the regulation created an Innovation Office that any legal person may approach, licensed or not, for products that widen financial inclusion without threatening stability. Corporate tax runs at 10%, 15% and 25% by bracket with a 1% rate for the smallest taxpayers, dividends carry 10% and other non-resident income 20%, and VAT is 10%. The market is 3.54 million people. Plan on nine to twelve months.
The Law on the National Payment System of 2017 gives the Bank of Mongolia all ten licence categories in Article 10.1, from payment services and system operation to money remittance and electronic money. A non-bank e-money issuer needs MNT 2,500,000,000 of paid-in capital; no minimum is printed for the other nine.
Funds sit in a guarantee account backed 100%, which cannot be lent, invested or pledged and is ring-fenced on insolvency. One unit equals one tugrik, no interest, balances capped at MNT 20,000,000. Sixty days to a decision, 180 at the outside, licence four years. Tax 10/15/25%, VAT 10%.
The routes
Nine categories with no printed floor, and one with MNT 2.5 billion on it.
Article 10.1 lists ten licensed activities and the central bank grants all of them. Only the electronic money issuer has a published minimum capital; for the rest, own funds are set by service type and average payment volume. We fix the category first, then build once.
Ten categories under Article 10.1; only the e-money issuer has a printed capital floor.
01 - PAYMENT SERVICES AND SYSTEMS
Article 10.1 licence categories
Payment services, related activities, operating a payment system, issuing and acquiring payment instruments, settlement agency, agent distribution, outsourcing, money remittance and electronic funds transfer - each licensed separately by the Bank of Mongolia.
Payment services, related activities, operating a payment system, issuing and acquiring payment instruments, settlement agency, agent distribution, outsourcing, money remittance and electronic funds transfer - each licensed separately by the Bank of Mongolia.
- ✓Payment services and related activities (10.1.1-10.1.2)
- ✓Operating a payment system (10.1.3)
- ✓Issuing and acquiring payment instruments (10.1.4)
- ✓Settlement agent (10.1.5) · money remittance (10.1.8)
- ✓Agents and outsourcing licensed separately (10.1.6-10.1.7)
- ✓No minimum capital printed for these categories
02 - ELECTRONIC MONEY ISSUER
E-money - MNT 2.5 billionNon-bank electronic money issuer
Category 10.1.10, the one activity with a published capital figure: MNT 2,500,000,000 of paid-in capital under Regulation 3.4.1, a guarantee account holding the full float, and the balance and authentication rules of Regulation 5.40.
Electronic money issuer: MNT 2,500,000,000 paid-in capital, guarantee account at 100%, one unit to one tugrik, no interest, balance cap MNT 20,000,000.
- ✓Paid-in capital MNT 2,500,000,000 (Regulation 3.4.1)
- ✓Guarantee account holding 100% of customer funds
- ✓One unit of e-money equals one tugrik (5.40.9)
- ✓No interest on e-money balances (5.40.10)
- ✓Balance cap MNT 20,000,000 per customer account
- ✓Unregistered users: MNT 100,000 balance, MNT 40,000 a day
Costs and timelines are confirmed for your case before any work begins. The licensing portal states that an application fee is due on filing and a licence fee on approval, but neither amount is published, so both are confirmed in writing before the budget is fixed.
Why Mongolia
One supervisor, ten categories, and a float the law puts beyond reach.
Mongolia wrote its payment law from scratch in 2017 and gave the central bank all of it. Six reasons the licence is worth looking at, and the limits of a 3.54-million market.
✓
Ten categories, one supervisor
Article 10.1 lists every licensed activity and the Bank of Mongolia grants all ten. The Financial Regulatory Commission does not license payment services, so there is only one file and one counterparty.All granted by one supervisor.
✓
A printed clock
Article 15.2 gives the central bank 60 days to decide on granting or extending a licence, and Article 15.3 caps the total period at 180 days.60 days, 180 at the outside.
✓
A capital figure only where it matters
MNT 2,500,000,000 for a non-bank electronic money issuer under Regulation 3.4.1. The regulation prints no minimum for the other nine categories.MNT 2.5bn for e-money only.
✓
A ring-fenced float
The guarantee account may not be lent, invested or pledged, and on insolvency or liquidation it may be used only to convert customers' e-money back into money.No lending, investing or pledging.
✓
The Innovation Office
Chapter 7 of the regulation opens the sandbox to any legal person, licensed by the central bank or not, for products that widen financial inclusion without threatening stability.Sandbox open to any legal person.
✓
ACH+ and RTGS
Transfers above MNT 3 million settle through RTGS and everything at or below runs on ACH+ around the clock, with card traffic clearing through NETC.Round-the-clock below MNT 3 million.
How it compares
How Mongolia differs from its Central Asian neighbours.
Mongolia licenses more activity types than any of its neighbours and prices only one of them, and its licence is the only four-year term in the group. The honest comparison is below.
Mongolia vs other jurisdictions
| Feature |  Mongolia | Other jurisdictions |
|---|---|---|
| Licence categories | Ten, listed in Article 10.1 | Two or three |
| Capital | MNT 2.5bn for e-money only | Every category priced |
| Licence term | Four years, renewable | Open-ended elsewhere |
| Decision | 60 days, 180 at the outside | 30 days to a year |
Licence categories
MongoliaTen, listed in Article 10.1
Other jurisdictionsTwo or three
Capital
MongoliaMNT 2.5bn for e-money only
Other jurisdictionsEvery category priced
Licence term
MongoliaFour years, renewable
Other jurisdictionsOpen-ended elsewhere
Decision
Mongolia60 days, 180 at the outside
Other jurisdictions30 days to a year
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Mongolia | Ten categories (Bank of Mongolia) | 10/15/25% · VAT 10% | MNT 2.5bn e-money · 4-year licence |
 Kazakhstan | NBK registration · AFSA PMS | 20% · AIFC 0% | USD 50k base in AIFC |
 Kyrgyzstan | Payment organisation · operator (NBKR) | 10% · VAT 12% | KGS 30M · 30-day decision |
 Uzbekistan | Payment organisation (CBU) | 15% CIT | CBU licence · 30-day review |
MongoliaLicense typeTen categories (Bank of Mongolia)
Taxation10/15/25% · VAT 10%
RequirementsMNT 2.5bn e-money · 4-year licence
KazakhstanLicense typeNBK registration · AFSA PMS
Taxation20% · AIFC 0%
RequirementsUSD 50k base in AIFC
KyrgyzstanLicense typePayment organisation · operator (NBKR)
Taxation10% · VAT 12%
RequirementsKGS 30M · 30-day decision
UzbekistanLicense typePayment organisation (CBU)
Taxation15% CIT
RequirementsCBU licence · 30-day review
Before you apply
Requirements for the Bank of Mongolia licence.Requirements for the licence.
Article 12 of the law sets the conditions and Article 15 the procedure; the Payment System Regulation adds the operating rules and the e-money chapter. The checklist below is what a passing file contains.
01
A legal person established under Mongolian law, per Article 12.1.1; the law prints no foreign-ownership limit and no management-residency rule.
02
Paid-in capital of MNT 2,500,000,000 for a non-bank electronic money issuer under Regulation 3.4.1; for the other nine categories the central bank sets own funds by service type and average payment volume under Articles 12.1.2 and 12.2.
03
Internal control and risk management arrangements under Article 12.1.3, and a system that protects customer funds under Article 12.1.4.
04
A five-year business plan under Article 12.1.5, management that meets the knowledge, experience and qualification requirements of Article 12.1.6, and evidence of liquidity under Article 12.1.7.
05
A guarantee account holding 100% of funds received from customers, whose balance never falls below e-money in circulation, at a bank that has met the central bank's prudential ratios for the last four quarters.
06
Product rules matching Regulation 5.40: one unit of e-money to one tugrik, no interest on balances, conversion on first demand, and authentication by PIN, biometrics or an equivalent above MNT 100,000.
07
Balance limits built into the product - MNT 20,000,000 per customer account, MNT 100,000 for an unregistered customer and MNT 40,000 of outgoing payments a day for the same customer.
08
AML and counter-terrorist-financing internal rules and controls, a business continuity plan and complaint-handling rules under Chapter 2 of the regulation.
09
Compliance with the central bank's QR-code data standard, joint technical testing with the system operator before joining a clearing or settlement system, and a designated settlement agent bank where the applicant is an indirect participant.
10
Service levels the regulation prints: unplanned downtime of no more than 0.1% a month and planned stoppages of no more than four hours.
01
Legal person established under Mongolian law.
02
MNT 2,500,000,000 for a non-bank e-money issuer.
03
Other categories: own funds set by the central bank.
04
Internal control, risk management, fund protection.
05
Five-year plan; management qualifications; liquidity.
06
Guarantee account at 100% of customer funds.
07
One unit to one tugrik; no interest; conversion on demand.
08
Balance caps 20,000,000 · 100,000 · 40,000 a day.
09
AML rules, continuity plan, complaint handling.
10
QR standard, technical testing, settlement agent.
Reflects the Law on the National Payment System of 31 May 2017 (in force 1 January 2018) and the Payment System Regulation approved by Order A-91 of 10 May 2023 and amended by Order A-195 of 30 August 2024, as of 2026.Law on the National Payment System (2017); Payment System Regulation A-91 of 10 May 2023 as amended by A-195 of 30 August 2024.
How it works
From first call to the Bank of Mongolia register.
01
Category and capital
Which of the ten Article 10.1 categories you need, and whether Regulation 3.4.1 puts MNT 2,500,000,000 on the table - fixed in writing with the budget.Which of the ten, and MNT 2.5bn or not.
02
Company and management
Mongolian legal person established, capital paid in, management assessed against the knowledge and experience test of Article 12.1.6.Established, paid in, assessed.
03
The application file
Five-year business plan, internal control and risk documents, the fund-protection design and liquidity evidence - complete before filing.Plan, controls, liquidity evidence.
04
Central bank review
Sixty days to a decision under Article 15.2 and 180 at the outside under 15.3, with technical testing against the system operator run in parallel.60 days; 180 at the outside.
05
Licence and launch
Four-year licence issued, guarantee account funded, ACH+ and card access live, and renewal diarised for 180 days before expiry.Four years; renewal at 180 days.
Quick facts
RegulatorBank of Mongolia
LawLaw on the National Payment System (2017)
CategoriesTen, Article 10.1
E-money capitalMNT 2,500,000,000
Client fundsGuarantee account, 100% backing
Decision60 days · up to 180
Licence term4 years, renewable
Corporate tax10/15/25% · VAT 10%
The four-year term is the part founders forget. Renewal is applied for 180 days before expiry, so the second file is drafted while the first licence is still young.
Your Mongolia desk
Run from our CIS and Central Asia desk.
Prifinance - CIS & Central Asia desk
Tallinn · coordinating Mongolian mandates
Roseni 13, Tallinn
01
Mongolian company formation
A legal person established under Mongolian law, with paid-in capital of MNT 2,500,000,000 where the application covers electronic money.Legal person; capital where e-money.
02
The Bank of Mongolia file
Five-year business plan, internal control and risk documents, management qualifications and liquidity evidence under Article 12 - filed against the 60-day clock.Article 12 documents against 60 days.
03
Guarantee account and rails
The guarantee account opened at a bank that has met the central bank's prudential ratios for four quarters, with RTGS, ACH+ and NETC access planned alongside the licence.Qualifying bank; RTGS, ACH+, NETC.
04
Substance in Ulaanbaatar
Managers who meet the Article 12.1.6 requirements, AML rules, a continuity plan and the complaint-handling procedures Chapter 2 of the regulation requires.Managers, AML, continuity, complaints.
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 Mongolia.
Three corporate brackets and a 1% rate for the smallest taxpayers, 10% on dividends, 20% on other non-resident income and 10% VAT.
Corporate tax 10, 15 and 25%
As restated on 26 June 2026 with effect from 1 January 2027: 10% on taxable income up to MNT 6 billion, MNT 600 million plus 15% between 6 and 10 billion, and MNT 1,200 million plus 25% above 10 billion.By bracket from 1 January 2027.
The 1% micro rate
Taxpayers with annual taxable income up to MNT 300 million pay 1%, outside the sectors listed in Articles 22.1.1 to 22.1.3 of the corporate income tax law.Income up to MNT 300 million.
Dividends 10%
Article 20.2.1 taxes royalties, dividends and interest at 10%. Interest and dividends from openly traded securities are taxed at 5% under Article 20.2.5.5% on listed securities.
Non-residents 20%
Article 20.2.4 taxes branch profits remitted to a head office and the Mongolian-source income of non-resident taxpayers at 20%.Branch profits and other income.
VAT 10%
The standard rate under the 2015 VAT law, with a registration threshold of MNT 400 million of turnover.Threshold MNT 400 million.
Payroll
Income tax and social insurance on Ulaanbaatar salaries. In a market of 3.54 million people, the hiring plan for compliance and technical staff is made early.Income tax + social insurance.
Tax summary
Corporate tax10% / 15% / 25% by bracket
Micro rate1% up to MNT 300M of income
Dividends10% · 5% on listed securities
Non-resident income20%
VAT10% · threshold MNT 400M
PayrollIncome tax + social insurance
*Figures as of 2026 per the Corporate Income Tax Law as amended on 26 June 2026 and the VAT Law of 9 July 2015. The bracket rates take effect from 1 January 2027.
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: Mongolian legal person, 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 issuer.
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The Mongolian payment licence, answered.
What licence does a payment business need in Mongolia?+
One granted by the Bank of Mongolia under Article 10.1 of the Law on the National Payment System. The article lists ten categories, from payment services and operating a payment system to money remittance, electronic funds transfer and issuing electronic money. The Financial Regulatory Commission does not license payment services.
How much capital is required?+
Regulation 3.4.1 sets a minimum paid-in capital of MNT 2,500,000,000 for a non-bank electronic money issuer. For the other nine categories the regulation prints no minimum: the law leaves own funds to the central bank, set by service type and average payment volume under Articles 12.1.2 and 12.2.
How long does the central bank take?+
Article 15.2 gives it 60 days to decide on granting or extending a licence, and Article 15.3 says the total period may not exceed 180 days. With drafting, translation and technical testing, plan on nine to twelve months from first call to launch.
How long does the licence last?+
Four years under Article 15.1. Renewal is applied for 180 days before expiry under Article 15.5 and may be repeated indefinitely while the requirements are met, under Article 15.6.
How is electronic money backed?+
By a guarantee account. Regulation 5.40.3 requires 100% of funds received from customers to sit in it, with a balance that never falls below e-money in circulation. Those funds may not be used for lending, investment or pledge, and on insolvency or liquidation they may be used only to convert customers' e-money back into money.
What limits apply to electronic money?+
One unit equals one tugrik and no interest is calculated on a balance. A customer account may hold up to MNT 20,000,000. An unregistered customer may hold MNT 100,000 and send MNT 40,000 a day, and any transaction above MNT 100,000 needs PIN, biometric or equivalent authentication.
Is there a sandbox?+
Yes. Chapter 7 of the Payment System Regulation created an Innovation Office at the central bank, open to any legal person whether or not it holds a licence, for innovative products that widen financial inclusion, do not threaten financial stability and cannot be used for money laundering or terrorist financing.
What rails does a licensee use?+
RTGS for transfers above MNT 3 million and ACH+ for anything at or below that figure, running around the clock. Card traffic clears through the interbank card system operated by NETC.
How are payment companies taxed?+
Corporate tax at 10% up to MNT 6 billion of taxable income, MNT 600 million plus 15% between 6 and 10 billion, and MNT 1,200 million plus 25% above that, with a 1% rate for income up to MNT 300 million. Dividends carry 10%, other non-resident income 20%, and VAT is 10%.
Why Mongolia rather than Kazakhstan or Kyrgyzstan?+
Mongolia licenses ten separate activities from one supervisor, prints a decision clock and ring-fences the float by statute, and its market is 3.54 million people. Kazakhstan offers the AIFC with a nil corporate rate and a lower entry figure; Kyrgyzstan decides in 30 days on KGS 30 million. If the product is electronic money and you want the float protected in law, license here.
Which licence?+
One of ten Article 10.1 categories from the central bank.
Capital?+
MNT 2.5bn for e-money; none printed elsewhere.
How long?+
60 days; 180 maximum; 9-12 months realistic.
Licence term?+
Four years; renewal 180 days before expiry.
How is e-money backed?+
Guarantee account at 100%, ring-fenced.
Limits?+
MNT 20,000,000; 100,000 unregistered.
Sandbox?+
Yes - the Innovation Office, Chapter 7.
Rails?+
RTGS above MNT 3 million; ACH+ below.
Taxes?+
10/15/25%, dividends 10%, VAT 10%.
vs Kazakhstan / Kyrgyzstan?+
Float protected in law; smaller market.
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 Bank of Mongolia or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.