Kyrgyz Law on Virtual Assets (2022)

The law defines a virtual asset as electronic-digital data with value that may represent value or property and non-property rights, created, stored, and circulated using distributed ledger technology or similar technology. It also states that virtual assets are not a monetary unit, payment instrument, or security in the Kyrgyz Republic. This distinction is central to the framework: virtual assets may be objects of civil-law rights, but they do not replace the national currency or become legal payment instruments under the law.

The law applies to virtual-asset turnover in the Kyrgyz Republic. It excludes securities and other financial instruments governed by securities law, currencies, electronic money, reserves, deposits governed by banking law, gaming activity, and, after later amendment, financial institutions in the Tamchy special financial investment territory. The current framework therefore sits beside, rather than fully replacing, banking, securities, payments, and special-zone regimes.

Article 9 identifies three regulated categories: mining, issuance and primary placement of virtual assets, and activities of virtual asset service providers. The authorized public body is determined by the Cabinet of Ministers and supervises mining, issuance, primary placement, crypto exchanges, and other VASPs, while National Bank-supervised institutions are treated separately for certain services.

VASP services include buying and selling virtual assets, exchanging one virtual asset for another, transfers, custody or control, and financial services linked to initial placement or sale of an issuer’s virtual assets. VASPs must be registered Kyrgyz legal entities and operate on the basis of a regulator-issued license. Licensing requirements include a functioning platform, business and internal-control documentation, cybersecurity and business-continuity procedures, consumer-protection procedures, personal-data procedures, and minimum capital set by the Cabinet of Ministers.

Mining is divided into private and industrial mining. Hidden mining is prohibited, and miners must be registered under procedures tied to the digital register and certification framework. The law also provides for issuance and public placement of virtual assets by Kyrgyz business entities, with registration and implementing rules set through Cabinet instruments, including Resolution No. 514 of Sept. 16, 2022.

The law requires miners and VASPs to implement measures against terrorist financing and money laundering under Kyrgyz law. It also restricts certain persons from VASP ownership or management, including persons on sanctions lists and other excluded categories. Advertising rules require risk warnings and disclosure of potential loss, technical failure, theft, lack of state backing, and the fact that virtual assets are not a means of payment or acceptance of payment in the Kyrgyz Republic. Advertising may not present virtual-asset transactions as an easy route to enrichment.

Later amendments have updated the framework. Consolidated sources list amendments in 2022, 2023, 2025, and 2026. A Jan. 19, 2026 amendment revised the stablecoin definition and added concepts including real-world-asset tokens, state mining, and a state cryptocurrency reserve, with certain issuance and regulatory details assigned to presidential regulation. Editors should verify the latest consolidated official text before publication because some public sources differ on amendment effective dates.