Payment app in Uzbekistan: the licence comes before the launch

Many fintech teams arrive with a finished product: the app works, the partners are lined up, the marketing is ready. In Uzbekistan the question that decides the launch date is a different one: is the activity licensed, and by whom?

Why the product is not the starting point

Accepting, transferring or holding clients' money is regulated activity. Payment organisations and payment system operators work under the supervision of the Central Bank, and the type of service you offer determines which permission you need. Building first and asking later often means rebuilding the product or the business model.

What to check before launch

• Which of your services count as payment services and which licence or registration they require

• Whether you need your own licence or can work through a licensed partner

• Capital, IT security and internal control requirements set by the regulator

• AML/KYC procedures: client identification, monitoring and reporting

• Where customer data is stored and how it is protected

The gap we often see

The contract with a licensed partner is signed, but it does not say clearly who is responsible to the regulator, who holds client funds and what happens if the partner loses its licence. On paper the launch looks safe; in practice the risk stays with the fintech.

Our view

Map your services against the regulatory requirements before the technical launch. A short legal review at the design stage is usually faster than adapting a working product to the regulator later.

Legal World, advocates (Tashkent) advises fintech and payment projects on licensing, partner agreements and compliance in Uzbekistan. More: legalworld.uz