Bank, payment organization, payment system operator, microfinance and insurance — obtaining the license, meeting the requirements and defending you when the regulator moves.
Who issues financial licenses in Uzbekistan and what are the capital requirements?
There are two regulators, and that is the first fork in the road. The Central Bank of the Republic of Uzbekistan licenses banks, payment system operators, payment organizations and non-bank credit organizations. Insurance activity, the capital market, circulation of crypto-assets, e-commerce and lotteries are licensed by the National Agency for Prospective Projects. On capital: the minimum charter capital of a bank in Uzbekistan is five hundred billion soums from 1 January 2025, while for a payment organization it is 10 billion soums from 1 July 2024 and 20 billion soums from 1 July 2025. From 1 July 2024 payment system operators and payment organizations are established solely in the form of a joint-stock company.
These are not abstract risks but the scenarios that break deals and turn government decisions against you.
Undercapitalization is a direct ground for supervisory measures, up to restriction of operations. The capital then has to be topped up in a hurry and on the worst possible terms.
Typical mistake: Relying on 2023 reviews. Presidential Resolution No. PP-381 of 30 November 2023 set the figure for a payment organization at 10 billion soums from 1 July 2024 and 20 billion soums from 1 July 2025.
A mismatch in the legal form blocks both obtaining the license and keeping it. Reorganization into a joint-stock company means a share issue, registration of the issue, a new charter and re-signing of contracts.
Typical mistake: Missing the requirement of PP-381: from 1 July 2024 payment system operators and payment organizations are established and operate solely in the form of a joint-stock company.
A refusal based on the composition of founders wipes out the deal: the money is already inside the structure, due diligence has been paid for, and entering the capital is impossible.
Typical mistake: Overlooking the express restriction in the banking law as amended by Law No. ZRU-831: legal entities registered in, and individuals residing in, a state or territory with a preferential tax regime may not be founders or shareholders of a bank.
The client pays for a service that does not exist, loses months, and walks into the regulator with the wrong package.
Typical mistake: Using terminology that has been repealed. Under Law No. ZRU-765 of 20 April 2022 the operative concept is the microfinance organization, and its market-entry regime differs from bank licensing.
Months lost corresponding with a regulator that has no say, and in the worst case operating without a valid license.
Typical mistake: Assuming the whole financial market belongs to the Central Bank. Insurance, the capital market, crypto-assets, e-commerce and lotteries are licensed by the National Agency for Prospective Projects.
Anti-money-laundering claims hit the license rather than the wallet, and they are handled within the law-enforcement track.
Typical mistake: The template was written for Russian law, which does not apply in Uzbekistan. The applicable act is Law No. 660-II of 26 August 2004.
For a network of outlets this means recurring sanctions; for a payment service, losing its place in the payment acceptance chain.
Typical mistake: Reading Presidential Decree No. UP-246 of 10 December 2025 as a recommendation. From 1 July 2026 acceptance of payments through the single QR code payment system is mandatory for legal entities in trade and services.
Central Bank or NAPP, a license or registration on the register — decided for your specific model, not for your industry in general.
We check the founders for an offshore trail and for limits on non-resident shareholding before filing, not after a refusal.
Calculating the charter capital requirement as of the filing date and bringing the legal form into line with it.
Application, business plan, internal policies, candidates for management positions — tailored to the requirements of the specific regulator.
Rules based on the applicable Uzbek law, customer identification and the procedure for dealing with the authorized body.
Handling orders, restriction of operations and the threat of license withdrawal.
We establish exactly which activity you carry out and which regulator admits it to the market.
Legal form, capital, composition of participants, management and premises — before the application is filed.
The document package, answers to the regulator's queries, clearing objections before the decision.
Reporting, maintaining capital, AML/CFT and changes in the shareholder structure.
Every point carries a link to the primary source so that you can check it yourself.
The minimum charter capital of a payment organization in Uzbekistan is 10 billion soums from 1 July 2024 and 20 billion soums from 1 July 2025 (Resolution No. PP-381 of 30 November 2023).
lex.uz — PP-381From 1 July 2024 payment system operators and payment organizations are established and operate solely in the form of a joint-stock company (Resolution No. PP-381 of 30 November 2023).
lex.uz — PP-381The minimum charter capital of a bank in Uzbekistan is five hundred billion soums from 1 January 2025 (Law No. ZRU-831 of 19 April 2023).
lex.uz — ZRU-831Legal entities registered in, and individuals residing in, a state or territory with a preferential tax regime may not be founders or shareholders of a bank (banking law as amended by ZRU-831).
lex.uz — ZRU-831On 22 January 2025 the Central Bank of Uzbekistan restricted the active operations of two banks for failing to meet the minimum charter capital requirement.
Gazeta.uz, 22.01.2025The types of non-bank credit organizations, including the microfinance organization and the pawnshop, are set out in Law No. ZRU-765 of 20 April 2022 “On non-bank credit organizations and microfinance activity”.
lex.uz — ZRU-765The licensing procedure for payment system operators and payment organizations is set out in the Regulation registered on 5 May 2023 under No. 3431.
lex.uz — Regulation No. 3431The licensing procedure for credit organizations, including the stages of reviewing an application and the state duties, is published by the Central Bank of the Republic of Uzbekistan.
cbu.uz — licensingLicensing and regulation of insurance activity, the capital market, circulation of crypto-assets, e-commerce and lotteries in Uzbekistan is carried out by the National Agency for Prospective Projects.
NAPP — areas of regulationBetween 12 October and 3 November 2023 NAPP revoked the licenses of four insurance companies in Uzbekistan.
Gazeta.uz, 06.11.2023The core act on combating the legalization of criminal proceeds and the financing of terrorism is Law No. 660-II of 26 August 2004.
lex.uz — Law No. 660-IIPresidential Decree No. UP-246 of 10 December 2025 made acceptance of payments through the single QR code payment system mandatory from 1 July 2026 for legal entities in trade and services.
lex.uz — UP-246Law No. ZRU-1026 of 11 February 2025 introduced a new type of credit organization — the microfinance bank — into the legislation on microfinance activity.
lex.uz — ZRU-1026| Activity | Regulator | Key requirement |
|---|---|---|
| Bank | Central Bank | Charter capital of 500 billion soums from 1 January 2025; restrictions on offshore founders |
| Payment organization, payment system operator | Central Bank | Joint-stock company only from 1 July 2024; capital of 20 billion soums from 1 July 2025 |
| Microfinance organization, pawnshop | Central Bank | Regime under Law ZRU-765 — different from bank licensing |
| Insurance, capital market, crypto-assets, lotteries | NAPP | A separate regulator: approaching the Central Bank is time lost |
The first fork is not the paperwork but the regulator. A mistake here costs months, because it only comes to light after the wrong package has been filed with the wrong authority.
We will go through your situation, tell you what can realistically be done and in what timeframe, and name the fee once we understand the scope. Without that, any figure would be invented.
Консультация по задаче — бесплатно. Стоимость работы называем после того, как поймём объём.
No testimonials and no case studies here: they cannot be verified. Only what you can confirm yourself.
This material is for reference only and is not legal advice on your specific situation. Rules and tariffs change — check the current wording via the links to the primary sources above. To have your case assessed, send us a request.