The National Bank will be able to carry out unannounced inspections of payment organisations

The National Bank of the Kyrgyz Republic has been granted the right to carry out unannounced inspections of payment system operators and payment organisations without prior notice. This provision is set out in the new Instructions on the Supervision of Payment System Operators and Payment Organisations, adopted by the National Bank of the Kyrgyz Republic on 6 July 2026.

According to the document, inspections may be carried out with or without prior notice. The decision to conduct an unannounced inspection may be taken by the head of an authorised department of the National Bank or by the head of a regional office or representative office of the regulator.

Unscheduled inspections will be carried out in cases where risks to the stability of payment services or breaches of legal requirements are identified.

In particular, grounds for an unannounced inspection may include:

• disruptions to the continuity of the payment system or the electronic money settlement system;
• indications of fraud, abuse or other breaches of the law;
• complaints from individuals and legal entities, as well as information from other sources;
• the identification of negative trends during the analysis of financial statements, which may lead to a deterioration in the organisation’s stability;
• doubts regarding the completeness and accuracy of the financial statements submitted to the National Bank;
• failure to comply with the regulator’s requirements, directives or decisions;
• the need to verify compliance with previously issued directives;
• conflicts between founders, members, shareholders or officers that may affect the smooth operation of payment services;
• information from law enforcement and other state bodies regarding possible illegal activities.

When conducting an inspection, the inspection team must present the inspection order to the head of the organisation or an authorised representative immediately upon arrival.

The new guidance also establishes two types of inspections: comprehensive and targeted. Comprehensive inspections will focus on assessing the organisation’s financial position, risk management system and compliance with legal requirements. Targeted inspections may be carried out in specific areas of activity and may be either scheduled or unscheduled.

Scheduled inspections of payment organisations will, as a rule, be carried out no more than once a year.