Regulation of Payment Organizations in the Republic of Uzbekistan

This article will address issues related to payment organizations in the Republic of Uzbekistan, the provision of payment services, the process of obtaining a license, as well as the requirements imposed on payment system operators.

It should be noted that as of the beginning of 2025, there are 2 registered payment system operators in Uzbekistan (Humo and Uzcard) and 49 payment organizations (including Payme, Click, Uzum, Oson, and others).

Humo is the payment system of the Republic of Uzbekistan, with transactions conducted in Uzbek sums. It was established in 2019 by the state-owned National Interbank Processing Center. In January 2025, it was privatized by Paynet, with the deal valued at $65 million.

Uzcard is the leading national payment operator in the Republic of Uzbekistan, which provides acquiring services, electronic payment processing, and functions as a provider, linking commercial banks, payment aggregators, and other market participants

A payment organization is a legal entity that is not a bank but is authorized to provide payment services.

Payme is a payment organization in Uzbekistan that allows users to conveniently and securely utilize the Payme service for payments of goods, services, and transfers.

Clik is a mobile banking service that provides users with the ability to remotely manage their accounts via system interfaces, as well as receive SMS notifications about transactions.

Uzum integrates e-commerce, fintech, and banking services for individuals and small to medium-sized entrepreneurs. It offers a marketplace, express delivery service, both traditional and digital banking services, a Buy Now, Pay Later (BNPL) service, a platform for purchasing vehicles, and an application for entrepreneurs. It creates a unique user experience for residents of the Republic.

Oson is the electronic payment system of the Republic of Uzbekistan, including an electronic wallet and electronic money (Oson sum). The operator of Oson electronic money is Brio Group, which became the first company in Uzbekistan to obtain the status of an electronic money operator. The issuer of electronic money is Turkistonbank.

Starting from July 1, 2024, payment system operators and payment organizations in Uzbekistan will be allowed to operate in the form of joint-stock companies. In addition, the minimum charter capital requirements for these entities will be increased:

- from July 1, 2025, the minimum charter capital will range from 10 billion to 50 billion UZS, for Payment organizations - 1 billion to 10 billion UZS.

-  from July 1, 2025, the minimum authorized capital for payment organizations must be 20 billion UZS.      

A payment service is provided by a provider to user.  

The payment services include:

- receiving and making payments using a bank account;

- receiving cash funds for crediting to bank accounts, including those of third parties;

- receiving cash funds for making payments without opening a bank account by the payer;

- issuance and redemption of electronic money;

- issuance of bank cards;

- receiving and processing payments made using electronic money;

- processing payments in electronic form and transmitting necessary information to the bank for making a payment or receiving funds for such payments;

- receiving and making money transfers through money transfer systems.

Payment services do not include services for:

- transferring cash funds by the payer to the person to whom the payer has obligations, made without the involvement of a payment service provider;

- cash-in transit services for banknotes, coins, and such valuables;

- performing currency exchange operations with cash foreign currency without opening a bank account;

- providing informational, communication, and technological interaction between the beneficiary – a legal entity, individual entrepreneur, and the payment service provider making money transfers in favor of the beneficiary based on accepted payments without third-party involvement.

Users of payment services are entitled to utilize the remote service systems of their bank account, or to avail themselves of another payment service provider, which has the necessary technical capabilities to support such use, in compliance with information security standards and ensuring equal access to all payment service providers.

The provision of payment services within the territory of the Republic of Uzbekistan is prohibited without the appropriate license issued by the Central Bank. This requirement does not apply to the activities of payment agents and sub-agents.

A payment organization is authorized to engage in payment services as an agent or sub-agent, based on an agency agreement.

When disclosing information about its operations, the payment organization is required to specify its license number.

The requirements for obtaining a payment organization license include  :

- the founders (participants or shareholders) of a payment system operator or organization may include both legal entities and individuals who are residents and non-residence of the Republic of Uzbekistan;

- the total share of non-resident legal entities and individuals, excluding international financial organizations, foreign banks, and foreign operators and organizations, in the charter fund (share capital) shall not exceed 50%.

Payment system operators and executives of payment organizations must:

- hold a higher education degree and have at least two years of experience in banking, finance, or the ICT sector;

- comply with the business reputation requirements established by the regulations;

- the license is issued by the Central Bank for an unlimited period;

- the right to operate as a payment operator and organization is granted from the moment the license is issued.

Regulating the activities of payment organizations in the Republic of Uzbekistan is significant  for ensuring the stability and security of financial operations, as well as for protecting consumer interests. Legislation in the field of payment systems and services is continuously evolving, creating conditions for the formation of a competitive and innovative payment infrastructure.

An important aspect is the regulation of licensing requirements for payment operators and organizations, which ensures the reliability and transparency of their operations. Established requirements, such as minimum charter capital, executive qualifications, and founder requirements, contribute to improving service quality and reducing risks in the market.

Moreover, considering the rapidly developing technologies and trends in digital payments, further refinement of legislation and regulatory mechanisms, as well as adaptation to international standards, will help create safer conditions for payment system participants and enhance user trust.

Thus, the regulation and licensing process for payment organizations in Uzbekistan is aimed at creating a stable and secure financial environment, which plays a crucial role in the country's economic development and in increasing financial inclusion.

Our company is ready to provide comprehensive support and legal assistance in obtaining the necessary permits and licenses for payment system operator activities.

    Sources:

1. The Law of the Republic of Uzbekistan on Payments and Payment Systems, dated September 19, 2019, on the Licensing Procedure;

2. Regulation on the Approval of the Licensing Procedure for Payment System Operators and Payment Organizations No. 3431, dated May 5, 2023;

3. Presidential Decree of the Republic of Uzbekistan on Measures to Strengthen Consumer Rights for Digital Products and Combat Digital Offenses, dated November 30, 2023, No. PP-381.