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1. KYRGYZSTAN IMPOSES KGS 300 MILLION MINIMUM CAPITAL REQUIREMENT ON CRYPTO EXCHANGES
Pursuant to Presidential Decree of the Kyrgyz Republic dated 13 March 2026 No. 112, new requirements for the minimum authorized capital of virtual asset trading operators (crypto exchanges) will come into force on 1 July 2026.
Under the Decree, the minimum authorized capital is set at no less than KGS 300,000,000 (three hundred million soms) (approx. USD 3, 430, 532).
Existing virtual asset trading operators are required to bring their authorized capital into compliance with the new requirements by 1 July 2026. Failure to comply may result in the application of measures measures prescribed by applicable legislation.
The Decree further establishes a specific purpose for the authorized capital. Such capital must be used exclusively to ensure liquidity in virtual assets, in accordance with the procedures established by the legislation of the Kyrgyz Republic.
These changes are aimed at strengthening the financial stability of virtual asset trading operators, enhancing user protection, and increasing trust in the digital asset market.
The introduction of a high minimum capital threshold represents a significant regulatory tightening for crypto market participants. Existing operators may face recapitalization requirements or potential market exit, while new entrants will encounter higher barriers to entry. The liquidity-use requirement also suggests increased regulatory focus on market stability and customer protection.
2. KYRGYZSTAN INTRODUCES ELECTRONIC AUCTION FRAMEWORK FOR SUBSOIL USE RIGHTS
By Resolution of the Cabinet of Ministers of the Kyrgyz Republic dated 23 February 2026 No. 127, a Temporary Regulation on the procedure and conditions for conducting electronic auctions for the granting of subsoil use rights has been approved.
The adoption of this regulation is aimed at minimizing corruption risks and increasing transparency in the allocation of subsoil use rights.
Under the Temporary Regulation, all document flow between auction participants, the organizer, and the technical operator is carried out via the official electronic auction portal. Information exchange is conducted electronically using:
- electronic documents;
- electronic copies of documents generated by scanning paper-based originals;
- documents signed using an electronic digital signature (EDS).
The granting of subsoil use rights through electronic auctions applies to subsoil plots included in a designated register, which is formed and approved annually by the auction organizer.
Additionally, the Ministry of Natural Resources, Ecology and Technical Supervision of the Kyrgyz Republic has been instructed to implement a pilot project for conducting electronic auctions. The pilot phase will run until 30 September 2026.
The introduction of electronic auctions is expected to streamline access to subsoil rights, reduce administrative discretion, and enhance investor confidence. Market participants should ensure readiness for digital participation, including the use of EDS and compliance with electronic document requirements.
3. KYRGYZSTAN APPROVES INCREASE OF RENEWABLE ENERGY CAPACITY THRESHOLD TO 50 MW
On 31 March 2026, the Committee of the Jogorku Kenesh of the Kyrgyz Republic on Industrial Policy, Transport, Fuel and Energy Complex, Architecture and Construction reviewed and approved in the third reading the draft law “On Amendments to the Law of the Kyrgyz Republic ‘On Electric Power Industry’”.
The key provision of the draft law is the increase of the installed capacity threshold for renewable energy (RES) facilities from 30 MW to 50 MW. This measure is aimed at creating more favorable conditions for attracting investment and promoting the development of the renewable energy sector.
It is expected that raising the threshold will enable the implementation of larger-scale, economically sustainable projects, as well as the introduction of modern technological solutions in the industry. The draft law aligns with international practices and the strategic priorities of the Kyrgyz Republic in the field of green economy development and energy security.
The increase in the capacity threshold is expected to facilitate the development of larger renewable energy projects and may improve project bankability for investors. It may also reduce regulatory constraints for mid-sized projects and bring the Kyrgyz regulatory framework closer to international standards. Market participants should monitor the final adoption and implementation of the amendments, particularly with respect to licensing and grid connection requirements.
The draft law is now pending formal adoption and entry into force.
4. KYRGYZSTAN ADVANCES LEGAL FRAMEWORK FOR ELECTRONIC PROMISSORY NOTES
The Committee of the Jogorku Kenesh of the Kyrgyz Republic on International Affairs, Defense, Security and Migration has reviewed and approved, in the first reading, a draft law “On Amendments to the Law of the Kyrgyz Republic ‘On Accession of the Kyrgyz Republic to the Convention Providing a Uniform Law for Bills of Exchange and Promissory Notes’.”
According to the Ministry of Finance, the proposed amendments are aimed at modernizing the financial infrastructure and digitalizing instruments for the circulation of debt obligations within the existing legal framework.
In particular, the draft law introduces the concept of an electronic promissory note (e-note), which is considered promising instrument for settlements and liquidity management, offering a number of practical advantages.
At the same time, the draft law does not envisage the abolition of paper-based promissory notes. Instead, it provides for the parallel use of both paper and electronic forms, thereby expanding the range of financial instruments available to market participants and improving the efficiency of document circulation.
Practical Implications
The proposed introduction of electronic promissory notes represents a step toward the digitalization of financial instruments in Kyrgyzstan. If adopted, the amendments may enhance transactional efficiency, facilitate liquidity management, and support the development of digital financial markets. Financial institutions and corporate participants should monitor further legislative developments and assess their readiness to implement electronic debt instruments.
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