National Bank regulation, state digitalisation programmes and a compact banking market set the context for IT projects in the country for the coming years.
24 commercial banks supervised by the National Bank
As of February 2026 there are 24 banks and 307 branches. All of them must comply with the National Bank's information security regulation (resolution 2021-П-20/72-8 of 22.12.2021). The regulator does not suggest "best practices" — it requires a specific set of controls.
National Bank of the Kyrgyz Republic
Digital Transformation Concept 2024–2028
Presidential Decree No. УП-90 of 5 April 2024 approved the Digital Transformation Concept of Kyrgyzstan for 2024–2028. Ministries and agencies work to formal indicators and fund digitalisation through to the end of 2028.
Ministry of Justice of the KR · Decree No. УП-90
Personal data law No. 179 — no mandatory localisation
Law No. 179 of 31 July 2025 replaced the one in force since 2008. A feature unique in the region: there is no requirement to localise data inside Kyrgyzstan. That leaves a free choice between on-premises, a private cloud and a foreign provider.
State Agency for Personal Data Protection of the KR
CIO of a tier-two bank · Bishkek
One of the 24 commercial banks. An IT team of 40–70 people, 4–6 information security engineers. Supervised by the National Bank under resolution 2021-П-20/72-8.
Experienced security engineers leave for Dubai or for remote work in Russia at 2–3 times the salary. Round-the-clock security monitoring is covered manually and the team is burning out.
"I don't need another compliance report on the National Bank regulation. I need a partner who will cover the night shifts of the monitoring centre — I have already lost two security people to Dubai."
IT director of a government agency
Tax, customs, the social fund, the state registration service — an operator of the personal data of millions of citizens. Works within the 2024–2028 Concept and the integration with Tunduk.
Legacy infrastructure 10–15 years old. Institutional uncertainty after the reorganisation of the digital ministry in April 2026 — procurement and approval procedures are being rewritten.
"I have a 2014 server holding a registry covering half the country. In parallel there is an instruction to move to electronic services by the end of the year. I cannot stop the system for even an hour, and I cannot hire people who know how to migrate hardware like that."
CTO of a payments / fintech company
A payment organisation licensed by the National Bank, integrated into Elcart. A development and operations team of 30–50 people, many of them remote.
Growing at double-digit rates. Data localisation is not required by law, but partner banks ask for a data centre they can make sense of. The local team has no experience running large distributed systems.
"I am growing 60% a year and the cluster is already creaking. I need a team that has built this for a dozen customers, not for one — my people simply have not done it before."