Currently, the legislation of Kyrgyzstan does not cover specific norms regulating rights to electronic money after the owner's death, nor does it establish a procedure for their blocking and transfer to heirs.
In practice, there is no unified approach to the issues of inheriting electronic funds.
Financial institutions and payment system operators act based on internal instructions, leading to discrepancies in the application of norms and complicating the process for heirs to obtain their funds, which, in turn, may lead to legal disputes.
According to data from the National Bank as of June 30, 2025, there are over 6.6 million electronic wallets registered in Kyrgyzstan, with the number of unique users exceeding 3.4 million. The total amount of funds in these wallets is 1.38 billion soms.
These figures highlight the importance of electronic money in the country's economy. The lack of regulatory framework for the inheritance of such assets leads to legal uncertainty and increases the risk of unauthorized disposal by third parties.
The proposed law aims to address these gaps by including claims to electronic money in inheritance and defining the procedure for their transfer to heirs. This should lead to the unification of law enforcement practices, protection of citizens' property rights, and increased transparency in electronic money transactions, as noted by the Ministry of Justice.
As part of the project, it is planned to amend Article 1120 of the Civil Code to include rights to electronic money and digital assets as part of the inheritance, as well as to supplement Article 6 of the Law "On Payment Systems" with norms regulating the actions of electronic money issuers upon receiving notification from a notary about the death of the owner.
Additionally, the project makes changes to the Law "On Banks and Banking Activities," concerning the provision of information by banks about the presence of electronic money in the wallets of deceased clients, which constitutes banking secrecy.
