Fintech & payments regulation in Mongolia (2026)
Fintech and digital payments in Mongolia: partial.
Mongolia established a formal payment-services licensing regime under the 2017 Law on National Payment System, enabling non-bank entities to obtain Bank of Mongolia licenses to provide payment services and issue e-money; at least nine non-bank e-money issuers are currently licensed. Core interbank infrastructure (RTGS, ACH+, QR-code standards) is operational. However, dedicated open banking mandates, BNPL-specific rules, and advanced fintech supervisory capacity remain underdeveloped, with the Asian Development Bank providing active technical assistance to close these gaps.
Legal framework
Law on National Payment System (enacted 31 May 2017, in force 1 January 2018); Bank of Mongolia (Mongolbank) Resolution No. A-45 on Electronic Money (2018); regulated by the Bank of Mongolia for payment services and e-money, and the Financial Regulatory Commission (FRC) for virtual asset service providers
Key points: digital payments & fintech in Mongolia
Payment Services Licensing
The Law on National Payment System (passed 31 May 2017, effective 1 January 2018) authorises the Bank of Mongolia to license both banks and non-bank entities as payment service providers and payment system operators, with formal application, capital, and compliance requirements set out by the central bank.
E-Money Regime
Bank of Mongolia Resolution No. A-45 (13 February 2018, effective 1 June 2018) created a standalone e-money licensing category. As of 2024-2025, at least nine non-bank e-money issuers hold licences, including Mobifinance NBFI, SuperUp Wallet, ArdCredit NBFI, Toki NBFI, Hipay, Data Bank, Send MN NBFI, Lifetech T Mongolia, and StorePay NBFI.
Payment Infrastructure
Mongolia operates a three-tier interbank infrastructure: an RTGS system for large-value payments, an ACH+ clearing house for low-value transfers (≤MNT 3 million per transaction), and an interbank card payment system. QR-code interbank payment standards were approved by the Bank of Mongolia and NETC in Q1 2022.
Open Banking
No formal open banking mandate or binding API standard has been legislated as of early 2026. The Bank of Mongolia has not issued open banking rules; industry sources indicate frameworks are anticipated but remain nascent.
BNPL Regulation
Buy Now Pay Later products are growing in Mongolia but no dedicated BNPL regulatory framework exists; offerings are primarily from licensed banks operating under general consumer credit rules rather than fintech-specific regulation.
Regulatory Capacity & ADB TA
ADB technical-assistance project 55234 is actively helping Mongolia assess its fintech legal frameworks, develop a fintech regulatory roadmap, and build supervisory capacity, explicitly acknowledging that existing measures (e-signature law, sandbox regulation, virtual asset law) have not fully kept pace with rapid market growth.
Sources
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Next topicOrientation, not legal advice: verify against the primary sources linked above. Last verified 24 May 2026. Methodology & how to cite · State of Technology Regulation 2026