KYRGYZSTAN · LICENSING
Business Licences and Permits in Kyrgyzstan
Kyrgyzstan licenses activities from a closed list. The Law on the Licensing and Permit System sets out every licence and permit that may be required, and a licensor may not demand one that is not on the list or ask for documents the law does not name. The licensor must decide within 30 calendar days of a complete application; if it gives no written refusal in time, the licence is treated as issued, except for narcotic drugs. A licence counts as issued only from the date it is entered in the single electronic register of licences and permits. The state duty for a company is ten calculation indicators, which is KGS 1,000, except for construction licences, which cost far more. Banks and other firms regulated by the National Bank, virtual asset businesses, subsoil users, telecoms operators and gambling businesses follow their own licensing rules.
This page covers Law No. 195 of 19 October 2013 on the Licensing and Permit System in its edition of 2 July 2026, the Regulation on Licensing of Certain Activities approved by Cabinet Resolution No. 678 of 14 December 2023 (edition of 15 October 2026), and the state duty rates. Financial licences are covered in more detail on Banking and Finance in Kyrgyzstan, and subsoil licences in Mining Licences in Kyrgyzstan.
Legal framework
| Instrument | What it governs | Key provisions |
|---|---|---|
| Law No. 195 of 19 October 2013 on the Licensing and Permit System (edition of 2 July 2026) | Closed list of licences and permits, procedure, register, licensing control, suspension and termination | Arts. 2, 9–12, 14–32 |
| Regulation on Licensing of Certain Activities, Cabinet Resolution No. 678 of 14 December 2023 (edition of 15 October 2026) | Time limits, documents, refusal grounds, and the licensor and requirements for each activity | Paras. 3–38; Section II by activity |
| Rates of state duty, Government Resolution No. 159 of 15 April 2019 (edition of 23 July 2026) | Duty for licences, permits and recognition of foreign licences | Para. 8(15), (17), (17-1) |
| Code No. 128 of 28 October 2021 on Offences; Criminal Code No. 127 of 28 October 2021 | Fines for unlicensed activity and breaches; criminal liability | Offences Code Arts. 284–285, 299, 495; Criminal Code Arts. 152, 218 |
The Law does not cover state registration of companies or conformity assessment (Art. 2(3)). Under Article 2(4), licensing of banks and other entities regulated by the National Bank follows the National Bank and banking legislation and the laws on payments, microfinance, credit unions, leasing and virtual assets; separate laws also govern subsoil use, foreign trade (with EAEU law), telecommunications operators and radio frequencies (the Digital Code), gambling, work permits, civil aviation and the Tamchy special financial investment territory.
Licences and permits: what the difference is
A licence confirms the right to carry on an activity that is subject to licensing. A permit confirms the right to perform a particular action in the course of an activity, such as blasting or discharging pollutants (Art. 4). Licences are listed in Articles 15 and 16, and permits in Article 17.
- Term. Licences are as a rule perpetual. A time limit is allowed only for licences to use limited state resources, foreign trade licences, licences for medical activity, road passenger transport, international road freight, sale of explosives, the manufacture, repair and sale of arms and ammunition, certain permits, and National Bank licences in a special regulatory regime (Art. 9(1)).
- Territory. A licence is valid throughout Kyrgyzstan unless the law limits it, as for medical and pharmaceutical licences tied to premises (Arts. 9(2), 10(2)).
- Transfer. A licence or permit may not be passed to another person (Art. 10(1)). Only licences to use limited state resources may be alienated (Art. 9(3)).
- Form. A licence may be issued on paper or as an electronic document (Art. 9(4); Regulation, para. 7).
Who may hold a licence
A licensee may be an individual or a legal entity, including a foreign one, whatever its form of ownership (Art. 14(1)). A legal entity must file a copy of its state registration certificate (Art. 18(1)(3)), so a foreign investor will usually apply through a Kyrgyz company; for setting one up see Business Formation in Kyrgyzstan. Some sector laws require a particular corporate form: a bank and a microfinance company must be joint stock companies, and so must a crypto exchange.
Recognition of foreign licences
A licence issued abroad may be recognised under a treaty, by mutual recognition, or unilaterally if it is on a list approved by the Cabinet of Ministers, which may include only licences whose requirements match or exceed the Kyrgyz ones (Art. 27(1)–(3)). The applicant files the foreign licence and proof of home-country registration, legalised or apostilled and translated; the licensor checks them within five working days and records the recognition in the register (Art. 27(5)–(6); Regulation, paras. 24, 31–32).
Main licensed activities for foreign investors
| Sector | Licensed activity | Law No. 195 |
|---|---|---|
| Energy | Production, transmission, distribution, sale, export and import of electricity, except renewable generation, own-use generation up to 1,000 kW and microgeneration; heat; oil and gas refining; natural gas supply | Art. 15(1)–(4) |
| Alcohol | Production and turnover of ethyl alcohol; production, storage and wholesale of alcoholic products | Art. 15(5)–(6) |
| Healthcare | Private medical activity; manufacture, import, wholesale and retail of medicines and medical devices; veterinary medicines | Art. 15(7)–(9) |
| Telecoms and post | Telecommunications operators (under the Digital Code); postal services | Arts. 2(4), 15(11)–(12) |
| Construction | Urban planning, design and survey work, and construction and installation work for category I to III buildings, except individual houses | Art. 15(15)–(16) |
| Transport | Road passenger transport; international road freight; water transport | Art. 15(17), (18), (21) |
| Finance | Banking operations, credit unions, microfinance companies, pawnshops, cash currency exchange, credit bureaus, payment and processing services, leasing, virtual asset service providers | Art. 15(22)–(28), (62), (63) |
| Insurance and pensions | Life, personal, property, liability, compulsory and annuity insurance, reinsurance, takaful; non-state pension funds | Art. 15(39)–(45), (64)–(66) |
| Securities | Organising trading, brokerage, registrar, depository and dealer activity, investment funds, trust management | Art. 15(46)–(52) |
| Education | Educational activity, with exceptions for state and municipal schools, pre-school and most additional education | Art. 15(56) |
| Hazardous activity | Radioactive and toxic materials; hazardous waste of classes I to V; explosives sales; fire protection systems | Arts. 15(31), (34), (55); 16(4) |
| Subsoil | Rights to use subsoil, under the subsoil legislation | Arts. 2(4), 16(5) |
Common permits include blasting and mining works, environmental permits for waste, discharges and emissions, carriage of dangerous goods, radio frequencies and work permits (Art. 17). Work permits follow the external labour migration law; see Employment and Work Permits in Kyrgyzstan.
Section II of the Regulation names the licensor for each activity; insurance and securities licences, for example, come from the non-bank financial market regulator (paras. 291, 326).
Restrictions on foreign ownership by activity
A foreign investor may invest in any activity not prohibited by law and receives treatment no less favourable than a national investor (Law on Investments, Arts. 10(1), 11). Sector laws set the main exceptions.
| Activity | Restriction | Source |
|---|---|---|
| Mass media | Foreign individuals and legal entities and stateless persons may not own, use, dispose of or manage more than 35% of the shares or interests in the legal entities through which a media outlet is set up | Law No. 188 of 6 August 2025 on Mass Media, Art. 8(3) |
| Banks | No founders or shareholders resident or registered in offshore zones listed by the National Bank, or under UN Security Council sanctions; non-financial legal entities may not hold 20% or more of voting shares; National Bank permission to cross 10%, 20%, 33%, 50% and 67% | Law No. 93 of 11 August 2022 on Banks and Banking, Arts. 16(3), (5), 22 |
| Virtual asset service providers | No founders, shareholders or officers resident in offshore zones, with accounts in offshore banks, or on sanctions lists | Law No. 12 of 21 January 2022 on Virtual Assets, Art. 24(2) |
| Land | A Kyrgyz company wholly owned or controlled by foreign persons, or in which they hold 20% or more of the shares or votes, is a foreign person and generally cannot own land | Land Code No. 149 of 18 July 2025, Arts. 2(74)–(75), 8; see Company Law and M&A |
| Gold and silver deposits | The State holds at least 30% in the licence company for large and medium deposits won at auction or tender | Law No. 49 on Subsoil, Art. 19; see Mining Licences |
Procedure step by step
- Confirm the activity and the licensor. Each licensor publishes on its website the forms, the full list of documents, time limits and its register (Art. 13).
- Register the company and prepare the documents Section II of the Regulation requires for the activity.
- Pay the state duty for consideration of the application and issue of the licence (Art. 18(1)(4)).
- File the application. The application, registration certificate, proof of payment, any power of attorney, an inventory and the activity-specific documents (Regulation, para. 30) may be filed on the licensor's website or the State Portal of Electronic Services (Art. 18(2)), and an electronic licence may be requested (Art. 18(3)). A refusal to accept documents must be given in writing within one working day (Regulation, para. 35).
- Pre-licence inspection. Where needed, the licensor checks the applicant's specialists, premises, transport and equipment before issuing the licence (Art. 28(3)(1)).
- Decision within 30 calendar days. The licensor decides within 30 calendar days of filing a complete application and notifies the applicant in writing (Art. 20(1)–(3); Regulation, para. 15). The radio spectrum licence is excepted where cross-border coordination is needed.
- Entry in the register. The licence counts as issued from the date it is entered in the register (Art. 20(4)). The entry is made within one working day of the decision and the original is handed over within five working days (Regulation, paras. 26, 28).
Silence means consent. If the licensor does not refuse in writing within the 30 days, the licence is deemed issued, except for the licence for narcotic drugs, psychotropic substances and precursors and the permit for their import, export or transit. The licensor must then enter it in the register the next day. If the applicant receives neither a refusal nor the licence, it notifies the licensor in writing, within 30 calendar days after the deadline, that it is starting the activity (Art. 20(5)–(6)).
Refusal. A licence may be refused only for a statutory prohibition for that category of applicant, a court ban, false or incomplete information, documents that do not meet the requirements, or non-payment of the duty (Art. 21(1), (4)). The licensor may refuse in writing only once, stating all the grounds; once the defects are cured the application is reconsidered and the 30 days run again (Art. 21(2)–(3)). A refusal may be appealed, and losses from an unfounded refusal may be claimed under civil law (Art. 22).
State duty
| Action | Duty (calculation indicators) | KGS |
|---|---|---|
| Issue or re-issue of a licence, a duplicate, or recognition of a foreign licence: legal entity | 10 | 1,000 |
| Same: individual without a legal entity | 5 | 500 |
| Construction licence, legal entity, responsibility level III / II / I | 1,500 / 7,000 / 15,000 | 150,000 / 700,000 / 1,500,000 |
| Construction licence, individual | 500 | 50,000 |
| Duplicate construction licence | 50 | 5,000 |
| Permit for an activity, other than the listed special permits: legal entity / individual | 3 / 1 | 300 / 100 |
Rates are set by the Cabinet of Ministers with the consent of Parliament (Non-Tax Revenues Code, Art. 139) in the state duty rates, para. 8(15), (17) and (17-1). The calculation indicator is KGS 100. No duty other than those provided for may be charged on applicants and licensees (Law No. 195, Art. 19(2)).
Ongoing obligations and licensing control
- Re-issue. On reorganisation, a change of name or extension, the licensee applies within 15 working days and the licensor decides within five working days (Art. 23).
- New services or premises. Where an activity needs an annex for additional work or a new site, the licensee notifies the licensor electronically (Art. 18(1-2)); any pre-licence inspection for the annex takes up to ten working days (Art. 28(5)).
- Inspections. Scheduled inspections take place no more than once a year under a plan published by 15 December of the preceding year; unscheduled ones follow complaints, the expiry of a deadline to cure or of a suspension, or the licensee's own request (Art. 28(3), (6)–(7)).
- Suspension. The licensor suspends a licence for three breaches in a year, uncured breaches after a written warning, false documents, or breaches endangering life, health, the environment, property or security. The licensee has 90 calendar days to cure, and the licence term is not extended during suspension (Art. 29(1), (3)).
- Annulment by a court only. If the breach is not cured, the licensor applies to court, and only a court decision annuls the licence, except for medical and pharmaceutical education (Arts. 29(4), 32). A licence also ends on the licensee's application, liquidation, expiry or removal of the activity from the list (Art. 31).
Electronic register and data exchange
The single automated (electronic) register of licences and permits is the only source that confirms a licence and its status (Art. 12(1)). It records the licensee's tax number, the activity, any territorial limit, the term, and any suspension or termination, and its information is open to the public subject to personal data law (Art. 12(4), (6)). Licensors obtain documents held by other state bodies through the system of interdepartmental electronic interaction, and ask the applicant for paper copies only if they cannot obtain them that way (Art. 18(1-1); Regulation, para. 8). Where licensing is done with information technology, every step from issue to annulment is carried out electronically (Regulation, para. 6). The body responsible for business development monitors licensors' compliance with the procedure (Art. 13-1).
Penalties
| Offence | Fine: individual / legal entity | Source |
|---|---|---|
| Business activity without a required licence or permit, including online | 75 / 230 indicators (KGS 7,500 / 23,000) | Offences Code, Art. 284(1), (1-1) |
| Breach of licence requirements or licensing law | 55 / 170 (KGS 5,500 / 17,000) | Art. 284(2) |
| Medical or pharmaceutical activity without a licence | 500 / 1,000 (KGS 50,000 / 100,000) | Art. 284-1 |
| False information to obtain a licence | 100 / 280 (KGS 10,000 / 28,000) | Art. 285 |
| Banking operations, including currency exchange, without a licence | 175 / 550 (KGS 17,500 / 55,000) | Art. 299 |
Licensors themselves impose the fines under Articles 284 to 285 (Art. 495). Unlicensed business or banking activity bringing income on a large scale is a crime, punished by community work or a fine of 200 to 300 calculation indicators, and on an especially large scale by a fine of 500 to 1,000 indicators or other penalties including a ban of up to two years (Criminal Code, Art. 218).
Common mistakes foreign investors make
- Starting before the register entry. The licence exists only from the date it is entered in the register.
- Relying on deemed issue without notifying the licensor. Silence counts as consent only if the application was complete, and the applicant must notify the start of activity within 30 days.
- Assuming a group company's licence covers a new subsidiary. Licences cannot be transferred, and a reorganisation triggers a 15-working-day re-issue duty.
- Underestimating construction licence costs. The duty for a level I construction licence is KGS 1.5 million.
- Overlooking foreign ownership caps in media, banking and land-holding companies when structuring the investment.
Frequently Asked Questions
How long does it take to get a licence in Kyrgyzstan?
The licensor must decide within 30 calendar days of a complete application; without a written refusal in time the licence is deemed issued, except for narcotic drugs (Law No. 195, Art. 20).
How much does a business licence cost?
For a legal entity the state duty is ten calculation indicators, KGS 1,000, for issue, re-issue, a duplicate or recognition of a foreign licence. Construction licences cost KGS 150,000 to KGS 1,500,000 depending on the level of responsibility.
Can a licence be transferred when a business is sold?
No. A licence may not be passed to another person (Art. 10(1)). On a share sale the licensee stays the same; on reorganisation or a change of name the licence must be re-issued within the deadlines in Article 23.
What happens if a company operates without a licence?
The licensor may fine it 230 calculation indicators (KGS 23,000), and criminal liability under Article 218 of the Criminal Code applies where the income is on a large scale.
Who licenses banks and crypto businesses?
Banks, microfinance and payment firms are licensed by the National Bank. Virtual asset service providers are licensed by the National Agency for Virtual Assets and Blockchain Technologies under the President; see Banking and Finance in Kyrgyzstan.
Bond Stone's Bishkek office advises foreign investors on licensing strategy, applications and licensing inspections in Kyrgyzstan.
Related pages
Kyrgyzstan Legal Guide · Business Formation in Kyrgyzstan · Company Law and M&A in Kyrgyzstan · Banking and Finance in Kyrgyzstan · Employment and Work Permits in Kyrgyzstan · Tax in Kyrgyzstan · Mining Licences in Kyrgyzstan · Business Licences and Permits in Kazakhstan · Legal Services in Kyrgyzstan
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Primary sources: cbd.minjust.gov.kg — Law No. 195 on the Licensing and Permit System, edition of 2 July 2026; Regulation on Licensing, Cabinet Resolution No. 678, edition of 15 October 2026; state duty rates, Government Resolution No. 159, edition of 23 July 2026; Non-Tax Revenues Code, Art. 139; Offences Code Arts. 284–285, 299, 495; Criminal Code Arts. 152, 218; Law on Investments Arts. 10, 11; Law on Mass Media Art. 8; Law on Banks Arts. 16, 22; Law on Virtual Assets Art. 24; Land Code Arts. 2, 8; Law on Subsoil Art. 19.