A New Anti-Corruption Law Adopted in Kyrgyzstan

This regulatory act replaces the previous anti-corruption law of 2012, significantly improving and systematizing the approach to anti-corruption regulation.

Terms and Definitions

While the previous version of the law contained only two defined concepts – “corruption” and “combating corruption” – the 2026 law introduces definitions for a broader range of terms, including:

a new definition of “corruption” and the related concept of “undue benefit”;
the concepts of a “corruption-prone factor” and a “corruption risk”;
the definition of “anti-corruption expertise”;
the concept of “anti-corruption standards” and related terms such as “close relatives”, “relatives by marriage”, and “affiliated persons”.

At the same time, the anti-corruption law still does not contain all terms related to combating corruption. For example, the concept of “conflict of interest” remains regulated by a separate law. In addition, it is not entirely clear how the definitions established in the new law correlate with the same terms defined in other laws. In particular, the Law “On Conflict of Interest” contains concepts such as “affiliated person” and “close person”.

Anti-Corruption Bodies

For the first time, the new law explicitly establishes the existence of a specially authorized body for corruption prevention, which:

participates in the development and implementation of state anti-corruption policy and prepares proposals for improving legislation;
coordinates, analyzes, and evaluates the effectiveness of anti-corruption activities in public authorities and provides methodological and advisory support;
develops a corruption measurement system, analyzes corruption risks and causes, and prepares and publishes a consolidated report on the state of corruption and implementation of anti-corruption policy;
maintains the Unified Register of Corruption-Related Crimes;
takes measures to prevent corruption;
carries out international legal cooperation in combating corruption.

However, it remains unclear which specific body will be assigned these functions.

The law also provides for the creation of an interagency Coordination Council on Combating Corruption under the General Prosecutor’s Office, as well as similar councils under lower-level prosecutor’s offices.

Anti-Corruption Measures in Public Organizations

The law introduces obligations for commercial and other organizations financed from the state budget to:

implement compliance programs and corruption risk mitigation measures based on their likelihood and significance;
conduct internal investigations and implement preventive measures;
publish information on their activities and results.

Anti-Corruption Monitoring

For the first time, the law establishes anti-corruption monitoring as an independent and mandatory instrument of state policy. Its purpose is to develop objective indicators of corruption levels and evaluate the effectiveness of anti-corruption measures.

State authorities and local self-government bodies must conduct internal monitoring and submit results to the authorized body, which prepares a consolidated national report.
The monitoring procedure will be determined by the Cabinet of Ministers.

Corruption Risk Assessment

The law requires state authorities and local self-government bodies to conduct internal corruption risk assessments, implement risk mitigation measures, and submit the results to the authorized body.

Anti-Corruption Standards

The law introduces a broader system of restrictions for public officials, including prohibitions on:

assisting relatives and affiliated persons in business using official position;
acting as a representative of third parties in public authorities;
establishing political parties, public associations, or other organizations in connection with official duties, or participating in or supporting their activities during working hours;
using official information or property for personal purposes;
accepting illegal remuneration or gifts;
concluding transactions on behalf of public organizations with companies linked to a spouse or close relatives;
being directly subordinate to relatives;
using official advantages during elections and referendums;
traveling abroad at the expense of individuals or legal entities (except where permitted by law or international treaties);
opening or holding accounts and storing valuables in foreign banks (except for certain categories of officials serving abroad).

Officials are also required to transfer shares, securities, and ownership interests into trust management for the duration of their public service, report any attempts to induce them to commit corruption offenses, and take measures to prevent conflicts of interest.

Failure to comply with these restrictions, if it does not constitute a criminal offense, may result in disciplinary liability, including dismissal.

Anti-Corruption Asset Declarations

Previously, the anti-corruption law required officials primarily to notify tax authorities about opening bank accounts, including foreign accounts.

The new law introduces mandatory declarations of:

income, expenses, liabilities, and assets, including those abroad, for the official, their spouse, and close relatives;
foreign bank accounts, foreign companies, and trusts, if the official or their spouse is a beneficial owner of such entities held in trust.

Tax authorities, with the assistance of financial intelligence units, analyze submitted data for completeness, accuracy, and consistency between declared income and expenditures. If signs of asset concealment or illicit enrichment are identified, materials are forwarded to prosecutors or other law enforcement bodies.

Reporting Corruption and Whistleblower Protection

State bodies and organizations must establish dedicated corruption reporting channels, including official websites, public information systems, and secure electronic or mobile hotlines.

The law also introduces state protection guarantees for whistleblowers, as well as their spouses and close relatives. In particular, retaliation against whistleblowers is prohibited, and in disputes, the employer bears the burden of proving that adverse measures were unrelated to the corruption report.

Registers and Legal Statistics

The new law establishes:

a Unified Register of Corruption-Related Crimes, maintained by the authorized anti-corruption body;
a Register of persons dismissed for conflict-of-interest-related violations, maintained by the public and municipal service authority.

Tax authorities are also required to maintain statistics on unified asset declarations.

Training and Public Awareness

The law places special emphasis on building an anti-corruption culture. State authorities must:

provide ongoing anti-corruption training and professional development for employees;
inform citizens about anti-corruption measures through official websites and other communication channels;
conduct awareness campaigns, media outreach, conferences, and publish methodological materials.

Anti-corruption education must also be incorporated into national education standards.
The civil service authority must organize training and professional development programs based on state orders.

Digitalization and Transparency of Governance

The law establishes requirements to ensure transparency of public authorities, reduce administrative barriers, expand electronic public services, and ensure transparency in public procurement, including the use of objective criteria and public monitoring mechanisms.

Civil Society Participation

The law grants citizens and civil society organizations the right to participate in anti-corruption efforts, including:

participating in drafting and discussing legal acts;
conducting independent monitoring and anti-corruption expertise;
requesting information from public authorities;
implementing educational and awareness initiatives.

Anti-Corruption Expertise

The 2026 law clarifies the objectives and procedures for anti-corruption expertise of legal acts and draft laws. This process is aimed at identifying corruption-prone provisions, assessing risks associated with their application, and developing recommendations to eliminate deficiencies.

Entities authorized to conduct such expertise include the prosecution authorities, the authorized executive body responsible for law-making, and the Office of the Jogorku Kenesh (Parliament) for draft laws. Independent expertise by accredited experts is also permitted.

The procedure and unified methodology will be established by the Cabinet of Ministers.

The law enters into force 10 days after its official publication.