11.1. Legal Framework
The Kyrgyz Republic is one of the first countries in Central Asia to implement special regulation of virtual assets. The legislation regulates relations arising from the creation, issuance, storage, and circulation of virtual assets, as well as the activities of participants in the virtual asset market.
| Key Law | Law of the Kyrgyz Republic "On Virtual Assets" dated January 21, 2022 No. 12 (hereinafter – the Law on Virtual Assets) |
|---|---|
| Authorized Body | National Agency for Virtual Assets and Blockchain Technologies under the President of the Kyrgyz Republic (NAVA) |
A virtual asset is a set of data in electronic-digital form that has value and constitutes a digital representation of value and/or a means of certifying property and/or non-property rights. Virtual assets are created, stored, and circulated using distributed ledger technology or similar technologies.
In accordance with the legislation:
• a virtual asset may serve as an independent object of civil rights;
• a virtual asset may certify property and non-property rights, including claims to other objects of civil rights;
• virtual assets are not a means of payment;
• virtual assets are not a monetary unit (currency);
• virtual assets are not securities.
The legislation also provides for specific types of virtual assets, including:
• stablecoins;
• digital tokens;
• tokens backed by real assets (Real World Asset Token - RWA Token).
11.2. State Regulation
In 2025-2026, a reform of the state regulation system for the virtual assets and blockchain technology market was carried out in Kyrgyzstan.
In 2026, a specialized authorized body for policy implementation and regulation in the field of virtual assets was established – the National Agency for Virtual Assets and Blockchain Technologies under the President of the Kyrgyz Republic (NAVA). NAVA carries out the development and implementation of state policy, regulation and licensing, issuance of permits, state registration of virtual asset issuances, and maintenance of state registers,
as well as the application of enforcement measures to regulated virtual asset market participants.
The National Council for the Development of the Virtual Assets and Blockchain Technology Sector also operates under the President of the Kyrgyz Republic, coordinating state policy and preparing proposals for industry development.
Legislation provides for the possibility of creating special regulatory regimes (regulatory sandboxes) for testing innovative products and technologies in the field of virtual assets in a controlled environment under special conditions.
11.3. Regulated Types of Activities
The following types of activities are recognized as regulated activities in the field of virtual assets:
• mining;
• issuance (release) and initial placement of virtual assets, including stablecoins and RWA Tokens in national or foreign currency;
• activities of virtual asset service providers.
11.4. Virtual Asset Service Providers
A virtual asset service provider can only be a legal entity registered in the territory of the Kyrgyz Republic and carrying out the relevant activity on the basis of a license.
The main types of services related to virtual assets include:
• purchase and sale (exchange) of virtual assets;
• exchange between virtual assets;
• transfer of virtual assets;
• storage, management, and control of virtual assets;
• provision of financial services related to the initial placement and/or sale of the issuer's virtual assets.
A virtual asset trading operator (cryptocurrency exchange) and a virtual asset exchange operator are virtual asset service providers and operate on the basis of a license.
In this regard:
the cryptocurrency exchange organizes transactions with virtual assets through an electronic trading platform;
the virtual asset exchange operator conducts purchase, sale, and exchange of virtual assets on its own behalf.
| BUSINESS COMPASS | Legal Guide on Kyrgyzstan A crypto exchange must be established in the organizational and legal form of a joint-stock company. For virtual asset service providers, the legislation sets requirements for the minimum size of the authorized capital. The minimum capital size depends on the type of activity carried out and is determined by the President of the Kyrgyz Republic.53 11.5. Issuance and Initial Placement of Virtual Assets Issuance and public placement of virtual assets may be carried out by business entities of the Kyrgyz Republic for the purposes of: • attracting investments and borrowed funds; • accounting, exchange, and certification of ownership rights to property. Only secured virtual assets are allowed to be issued on the territory of the Kyrgyz Republic. The issuance of virtual assets is subject to mandatory state registration by the authorized body. The procedure for issuance, initial placement, and circulation of virtual assets is determined by the Law on Virtual Assets and the relevant subordinate acts. Information on virtual asset issuances is included in the Unified State Register of Virtual Asset Issuances both in national and foreign currency.54 53 From July 1, 2026, the minimum authorized capital of a virtual asset trading operator (crypto exchange) is set by the President of the Kyrgyz Republic at 300 million soms (approx. 3.43 million USD) (Presidential Decree of the Kyrgyz Republic "On Establishing the Minimum Authorized Capital Size of a Virtual Asset Trading Operator" dated March 13, 2026, No. 112). For virtual asset exchange operators, the minimum authorized capital was previously set by the Cabinet of Ministers at 40 million soms (approx. 460 thousand USD). It should be noted that according to amendments adopted in 2026 to the Law on Virtual Assets, the size of the authorized capital of virtual asset exchange operators is subject to determination by the President of the Kyrgyz Republic, so it is not excluded that the minimum authorized capital size for virtual asset exchange operators will be set by the President of the Kyrgyz Republic at a different amount. 54 Part 3, Article 5 of the Law on Virtual Assets. | |||
|---|---|---|---|---|
| BUSINESS COMPASS | Legal Guide on Kyrgyzstan A crypto exchange must be established in the organizational and legal form | |||
| of a joint-stock company. For virtual asset service providers, the legislation sets requirements for the minimum size of the authorized capital. The minimum capital size depends on the type of activity carried out and is determined by the President of the Kyrgyz Republic.53 11.5. Issuance and Initial Placement of Virtual Assets Issuance and public placement of virtual assets may be carried out by business entities of the Kyrgyz Republic for the purposes of: • attracting investments and borrowed funds; • accounting, exchange, and certification of ownership rights to property. Only secured virtual assets are allowed to be issued on the territory of the Kyrgyz Republic. The issuance of virtual assets is subject to mandatory state registration by the authorized body. The procedure for issuance, initial placement, and circulation of virtual assets is determined by the Law on Virtual Assets and the relevant subordinate acts. Information on virtual asset issuances is included in the Unified State Register of Virtual Asset Issuances both in national and foreign currency.54 53 From July 1, 2026, the minimum authorized capital of a virtual asset trading operator (crypto exchange) is set by the President of the Kyrgyz Republic at 300 million soms (approx. 3.43 million USD) (Presidential Decree of the Kyrgyz Republic "On Establishing the Minimum Authorized Capital Size of a Virtual Asset Trading Operator" dated March 13, 2026, No. 112). For virtual asset exchange operators, the minimum authorized capital was previously set by the Cabinet of Ministers at 40 million soms (approx. 460 thousand USD). It should be noted that according to amendments adopted in 2026 to the Law on Virtual Assets, the size of the authorized capital of virtual asset exchange operators is subject to determination by the President of the Kyrgyz Republic, so it is not excluded that the minimum authorized capital size for virtual asset exchange operators will be set by the President of the Kyrgyz Republic at a different amount. 54 Part 3, Article 5 of the Law on Virtual Assets. |
11.6. Mining
Mining is a regulated type of activity ensuring the functioning of the blockchain and confirming transactions in the distributed ledger.
Legislation provides:
Mining requires registration in the Digital Register of Miners and obtaining the corresponding certificate. The certificate is issued for an unlimited term.
The main requirements for registration are:
• ownership of mining equipment;
• availability of an active virtual asset wallet;
• compliance with power supply and safety requirements;
• absence of hidden mining
private mining conducted by individual entrepreneurs;
industrial mining conducted by legal entities.
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These materials were prepared by the National Investment Agency together with Baker Tilly, are informational only and do not constitute legal advice. Data is current as of June 2026. Verify against applicable laws and consult the NIA before making decisions.