VASP license in Kyrgyzstan

Kyrgyzstan

Jurisdiction	Kyrgyzstan
License type	VASP license
Regulator	Service for Regulation and Supervision of the Financial Market under the Ministry of Economy and Commerce of the Kyrgyz Republic (FSA (fsa.gov.kg))
Minimum capital	40,000,000

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Requirements

Before applying for a VASP licence, the operating entity must be incorporated in the Kyrgyz Republic. Companies are registered by the Ministry of Justice of the Kyrgyz Republic (State Registration Service). For licensing purposes, the recommended default vehicle is the ОсОО (Общество с ограниченной ответственностью) — the Kyrgyz Limited Liability Company (LLC) equivalent — which is the simplest and most commonly used general-purpose form. Other legal forms (joint-stock companies, partnerships, cooperatives, sole proprietorship, and branch/representative office of a foreign company) are also available under Kyrgyz law and may suit larger or more specialised structures (see Basic company reference).

Once incorporated, the company can open a corporate account with a local bank, such as Optima Bank, RSK Bank (Eldik Bank), or Bakai Bank, all of which offer business/corporate accounts, corporate cards, and business lending products.

Kyrgyzstan operates a dedicated, sector-specific regulatory track for virtual assets rather than folding VASPs into general financial-licensing rules, with the FSA maintaining a standalone Virtual Assets section covering News, Regulatory legal documents, Draft regulatory acts, and Reporting forms for operations under ПУВА (the virtual-asset reporting/operations regime), as well as a general Licenses and Permits section with instructions applicable across the sectors it regulates.

The regime is structured as two distinct licence tiers, each with its own capital threshold:

Virtual Asset Exchange Operator — for bilateral, own-account exchange of virtual assets — requires minimum capital of 40,000,000 KGS.
Virtual Asset Trading Operator (crypto-exchange, multilateral third-party trading platform) — requires minimum capital of 10,000,000,000 KGS.

The FSA issues, supervises, and can revoke these licences, and it maintains the official register of licensed entities. FSA enforcement is active: on 15.07.2026 the regulator revoked previously issued licences of both a virtual asset exchange operator and a virtual asset trading operator/crypto exchange, confirming that supervision and enforcement of the two-tier system are operational in practice.

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Service for Regulation and Supervision of the Financial Market under the Ministry of Economy and Commerce of the Kyrgyz Republic (FSA (fsa.gov.kg))

Regulates and licenses virtual asset activities in Kyrgyzstan, including the two-tier system of 'Virtual Asset Exchange Operator' (bilateral own-account trading, 40,000,000 KGS capital) and 'Virtual Asset Trading Operator' (multilateral third-party exchange platform, 10,000,000,000 KGS capital), and maintains the official register of licensed entities. https://fsa.gov.kg/

Overview

Kyrgyzstan regulates virtual asset activity through a two-tier VASP (Virtual Asset Service Provider) regime supervised by the Service for Regulation and Supervision of the Financial Market under the Ministry of Economy and Commerce of the Kyrgyz Republic (FSA). Depending on the business model, an operator is licensed either as a Virtual Asset Exchange Operator (bilateral, own-account exchange of virtual assets) or as a Virtual Asset Trading Operator — known locally as оператор торгов виртуальных активов (криптобиржа), i.e. a crypto-exchange operator running a multilateral third-party trading platform. Both are VASP-equivalent authorisations issued and supervised by the same regulator.

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Licensing Process

Engraved gold medallion of official documents with the Kyrgyzstan skyline

Step 1

Register the operating entity as an ОсОО (LLC equivalent) with the Ministry of Justice of the Kyrgyz Republic (State Registration Service).

Engraved gold medallion of a document being filed with the Kyrgyzstan skyline

Step 2

Open a corporate bank account with a local bank such as Optima Bank, RSK Bank (Eldik Bank), or Bakai Bank.

Engraved gold medallion of an ornate certificate with the Kyrgyzstan skyline

Step 3

Determine and meet the applicable capital threshold with the FSA — 40,000,000 KGS for a Virtual Asset Exchange Operator licence or 10,000,000,000 KGS for a Virtual Asset Trading Operator licence.

Engraved gold medallion of an appointment ledger with the Kyrgyzstan skyline

Step 4

Submit the licence application to the FSA under its Licenses and Permits process and the Virtual Assets regulatory framework.

Engraved gold medallion of a bank ledger with the Kyrgyzstan skyline

Step 5

Upon approval, commence operations under the reporting obligations set out under ПУВА and appear on the FSA's official register of licensed virtual asset entities.

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Frequently Asked Questions

What does VASP mean in the Kyrgyz context?

VASP (Virtual Asset Service Provider) is the international term; in Kyrgyzstan the regime is split into two locally defined licence types — Virtual Asset Exchange Operator and Virtual Asset Trading Operator (оператор торгов виртуальных активов / криптобиржа) — both issued by the same regulator, the FSA.

What is the difference between the two Kyrgyz licence tiers?

A Virtual Asset Exchange Operator conducts bilateral, own-account exchange of virtual assets and needs 40,000,000 KGS minimum capital. A Virtual Asset Trading Operator (crypto exchange) runs a multilateral third-party trading platform and needs 10,000,000,000 KGS minimum capital.

Who regulates virtual asset businesses in Kyrgyzstan?

The Service for Regulation and Supervision of the Financial Market under the Ministry of Economy and Commerce (FSA), which issues, supervises, and can revoke VASP licences and maintains the official register of licensed operators.

Can a VASP licence be revoked?

Yes. The FSA has demonstrated this in practice — on 15.07.2026 it revoked previously issued licences of both a virtual asset exchange operator and a virtual asset trading operator/crypto exchange.

What company type should I use to hold the licence?

The ОсОО (LLC equivalent), registered with the Ministry of Justice of the Kyrgyz Republic (State Registration Service), is the recommended default vehicle for licensing purposes, though other legal forms exist for larger or specialised structures.