It is the Central Bank of Uzbekistan (CBU) that writes the rules for the country's fintech market. The regulator also supervises the companies competing in it. And there’s more. The CBU has created an innovation hub to incubate some of these enterprises, while this year it established a $50mn venture fund intended to invest in the fintech sector.

It is a combination that would raise eyebrows in most jurisdictions. In Tashkent, however, it is the strategy.

In 2018, the only company processing card payments in Uzbekistan, a private firm called Uzcard, suffered a major software failure that shut down card transactions for about two days. In September that year, a presidential decree created a rival: a state processing centre called Humo, held on the balance sheet of the CBU’s Main Informatisation Center.

Created by presidential decree, Humo was sold to Paynet for $65mn.

Humo grew into one of the country's two national card schemes, with more than 23mn cards issued by early 2024. In November 2023, a further decree moved it off the central bank's books and into the State Assets Management Agency (UzSAMA), which gave a blunt reason for the transfer: keeping an interbank processing centre on the regulator's balance sheet created a conflict of interest. Fourteen months later the agency sold the company outright to payments operator Paynet for $65mn.

The central bank, meanwhile, is now doing something that rhymes with it. It has built a credit platform that scores borrowers using artificial intelligence and lets commercial banks bid against each other to fund the loan. Once the platform is running properly, says Bobur Khodjaev, head of the department of financial technologies, digitalisation and artificial intelligence at the Presidential Administration, "it will be privatised too."

"Essentially we are creating new platforms, new companies that will mobilise private financing," he told the Silk Road Finance & Technology Forum in Tashkent in late August.

Build it, prove it, sell it. Humo was not designed that way — it was an emergency fix for a monopoly failure, divested for a different reason again, and swept into a privatisation programme covering 247 state companies. The pattern is being described in retrospect. But it is now being applied more deliberately.

Singapore has generally favoured regulator-led shared infrastructure, while India built public digital rails for broad private-sector use. Uzbekistan is experimenting with something more interventionist: building market infrastructure and businesses itself, with at least some intended eventually for private ownership — while simultaneously writing the sector's strategy, regulating it, running its innovation hub and preparing to invest in startups through a $50mn venture fund.

The conflict at the centre

Nobody at the three-day forum, which drew around 8,500 participants from 77 countries, put a hard question to that model. The clearest account of its risks came instead from the official responsible for delivering it.

Ravshanbek Kadirov was hired last year to establish and build the central bank's fintech department (Credit: @AnewZ_TV, screenshot).

Ravshanbek Kadirov was hired last year to build the central bank's fintech department. He was, he notes drily, appointed before the department existed: "I was the one in charge of establishing the department I was hired to direct."

The obvious objection to all of this is that the central bank now occupies four roles that sit awkwardly together. It writes the strategy. It regulates the market. It runs the innovation hub intended to incubate entrants. And it has established a venture fund intended to invest in them.

It is not a hypothetical objection, and it is not a foreign one. The Uzbek state reached exactly this conclusion once already: the stated reason for moving Humo off the central bank's balance sheet in November 2023 was that holding a processing centre there created a conflict of interest. The judgement has been made, in writing, about this institution — before the venture fund existed.

Kadirov raises it himself, unprompted.

"If we're going to be the ones coming up with a fintech strategy, if we're going to be the regulator, and at the same time have the innovation hub and the venture fund, there will be a temptation to become the victim of a conflict of interest — although we have the best intentions at heart," he said. "That's why I believe that in this transition phase we're going to have to be extra careful with the team and the human capital we involve in this fintech project."

The leapfrog argument

That is not an argument against the model. Kadirov built it, and his route to the job explains why he thinks it is worth the risk. He started at Citibank in the United States, returned to a private Uzbek bank part-owned by the International Finance Corporation (IFC), and then moved to a state bank in the middle of the transformation and privatisation programme that has occupied Uzbekistan's banking sector since President Shavkat Mirziyoyev ordered the state banks to modernise.

That last posting produced the insight the whole strategy rests on.

"Right now all the state banks are going through this transformation just so they can catch up to the private banks in terms of P&L, corporate governance, risk, treasury," Kadirov told IntelliNews. "If the state banks are using money, time, resources and effort to transform just to catch up to private banks that are already working quite well in Uzbekistan, what's the next milestone?"

Spend three to five years and considerable public money, he argues, and the state banks arrive where the private sector already is. "They're going to have a proper risk and corporate governance system just like the private banks. But in terms of P&L, in terms of value added, in terms of innovation, that's not going to help the country overall."

So skip it. "Wouldn't it make sense for Uzbekistan, from the eyes of the government, not to waste resources, time and all that effort catching up to the private banks, and to try to develop fintech at the same time? Because if we support fintech, fintech will require the private banks to also work and try to transform."

It is the leapfrog argument applied not to consumers but to institutions — and it is why a central bank in a lower-middle-income country has ended up preparing to enter the venture capital business.

The architecture

The legal instrument is Presidential Resolution No. PP-359, signed on November 27, 2025, which expanded the central bank's mandate beyond supervision into sector development. It required the CBU to prepare a National Strategy for the Development of Financial Technologies for 2026–2030, to establish an innovation hub and a dedicated fintech office, to launch the $50mn venture fund, and to build legislation out of the results of regulatory sandbox projects. It also made the central bank responsible for regulating the issuance and circulation of tokenised shares and bonds.

The published targets for 2030 are $1bn of foreign investment into the sector, more than 5,000 trained professionals, more than 200 licensed market participants and 100 incubated startups.

The infrastructure programme running underneath is substantial. A national payment switch and cloud infrastructure are in development. Uzbekistan rolled out its unified UzQR payment standard during 2026, with the new payment regime taking effect on July 1 and designed in part to support interoperability with neighbouring systems. Open APIs, under which commercial banks will be obliged to give fintechs access to customer data, had been slated for rollout by this month; CBU Governor Timur Ishmetov now puts them at the beginning of next year.

"At the beginning of next year we are prepared to launch the open APIs. All fintech companies will have access to the data, and commercial banks will be obliged to provide it," he told reporters in Tashkent.

Khusankhodja Abidov, the central bank's director for strategy, transformation and project management, describes three layers: rails, data and rules. On the last of these he sets out a sequencing principle that reads as a direct answer to the criticism the model invites. "We let innovation go first where possible, but regulate proportionately as risk and scale increase," he said. "Once an innovation becomes systemic, once it touches personal data or critical infrastructure, the regulatory expectation must increase too."

He is also explicit that the state should not be doing this alone. "The first mindset a central bank needs to adopt is that it shouldn't try to build the ecosystem on its own. Its role is to build the infrastructure, set the rules of the game, and create the conditions for the financial sector to innovate and compete."

One gap is conspicuous. Although Ishmetov unveiled the National FinTech Strategy at the August forum, the full strategy document has still not been published. The central bank's dedicated web page contains only a brief summary.

What the private sector has done with it

The market has moved faster than the paperwork.

Uzbekistan has two competing domestic card schemes, Uzcard and Humo — "usually countries have one, or zero," as Ishmetov puts it. Uzcard is pushing into AI for credit scoring, fraud detection and advisory services.

Uzbekistan's other card scheme is Humo's rival Uzcard.

Humo, since privatisation, has gone in an entirely different direction: its Humo Digital subsidiary issued a government-bond-backed token last year and, according to Khodjaev, is working towards the first stablecoin issued in Uzbekistan.

Uzum, founded in 2022, became the country's first fintech unicorn and secured a $2.3bn pre-money valuation in its latest funding round. Its bank uses marketplace turnover data to lend to merchants on a platform with more than 17,000 sellers, including businesses that lack the collateral or credit histories conventional banks typically require.

"Many SMEs lack good collateral or credit history, so going to a traditional bank and asking for credit is simply impossible," said Rasulzhan Gulyamov, chairman of Uzum Bank's supervisory board.

Around them sit payment companies that grew rapidly during an earlier period of much lighter regulation — Click among them, Kadirov argues. That regulatory lag is what prompted the current effort. The central bank left them largely alone when they were moving money for a few thousand people. "But now it's millions. And the central bank is saying: wait a minute, if something happens this is going to be a systemic risk."

The adoption numbers explain the urgency. The share of people making or receiving at least one digital payment rose from 39% in 2021 to 71% in 2025, according to a central bank financial inclusion survey conducted with Asian Development Bank (ADB) support, and 57% of payments are now cashless. The number of fintech companies has gone from 24 in 2018 to 103 in 2025, according to a central bank presentation, with payment services accounting for just over half the market.

Money has followed. Foreign investment into Uzbek fintech exceeded $260mn in 2025, roughly four times the previous year's figure — against a cumulative target of $1bn by 2030 that looks increasingly attainable if recent investment levels persist. Uzbekistan's total venture capital in 2024 was $69.5mn, of which fintech took $58mn.

The macro backdrop has cooperated. GDP grew 8.5% in the first half of 2026. Net foreign direct investment inflows reached $702mn in the first quarter, according to the central bank. S&P upgraded the sovereign in 2025, and on June 25 this year Moody's raised Uzbekistan from Ba3 to Ba2 with a stable outlook, citing sustained improvements in the institutional and policy framework.

The mitigations, and what they miss

The mitigation Kadirov offers is structural. The venture fund will be run by an external general partner. "To help us manage that and to remove the conflict of interest," Kadirov said, "so that we can look at investment committee level and see how they're going to be managing state money with a private sector mindset."

No manager has yet been appointed. "We have established a dedicated venture fund. We are discussing with experienced international fund managers," Ishmetov told the forum on its opening day, adding that the aim was a pipeline running from the innovation hub to international scaling, with larger ticket sizes and co-investment. The hub itself takes its first cohort of resident startups in the fourth quarter of this year. For now, in other words, the safeguard against the conflict exists as an intention rather than an appointment.

He is equally clear that the arrangement is meant to be temporary. "It's not the aim of the central bank to be supporting the market through the central bank's venture funds all the time. This is just to bankroll the market and support the market." Within three to five years, he expects, "central bank involvement will be less required."

He also anticipates the market pushing back. "We understand that there will be some kind of market resistance, and we think that it's a healthy reaction. We would be surprised if there was no market resistance."

The international view offered at the forum was warmer. Sopnendu Mohanty, group chief executive of the Global Finance & Technology Network, which co-organised the event with the central bank, called the venture fund unprecedented and said the room should applaud it. "Why is it important? Because that's signalling money. It signals the central bank's intent to take skin in the game and risk on a startup with a new idea."

Private investors made a similar calculation. "Once private capital sees that the government and the central bank have skin in the game, they will be more willing to invest and take the risks," Khodjaev said.

What none of them addressed is the scenario the structure could eventually make possible: a company backed by the central bank's fund applying for a licence from the central bank's supervisors, or competing against a platform the central bank built and has yet to sell. If a processing centre on the balance sheet was enough to trouble the state in 2023, a future portfolio of startup investments raises a harder question, not an easier one.

Whether any of it reaches people

The sharpest challenge to the whole programme came from inside the central bank, on a stage in front of two of the companies it was describing.

Dilbar Abduganieva, the CBU's chief financial inclusion officer, told a panel that the word inclusion is being used loosely. "Inclusion means access, usage and quality — all three pillars have to be there," she said, adding that a minimum set of products should be in scope: credit, savings and payments. Measured that way, "embedded finance is not inclusion right now, because it covers only part of the concept."

The central bank's own numbers bear her out. In August it published the first pilot calculation of a national financial inclusion index, built on precisely the three components she describes — access, usage and quality — across credit, deposits and payments. It scored 59 out of 100 for individuals and 49 for small businesses. Access to payments was the strongest result anywhere in the report at 69 points: 83% of adults hold a bank card and 86.3% can pay by mobile internet. Actual usage of those payment tools scored 34, the lowest figure of any category measured. Adults hold an average of 3.2 cards and actively use 53% of them, and 69% of all cashless transactions are person-to-person transfers rather than payments for goods and services. For small businesses, payment service availability scored 19 out of 100 — the worst result in the report, against 50 for access to credit.

Access has improved and usage is following, she said, but on quality "there are a lot of questions, because from the regulator's perspective we have to think about transparency, and in most cases embedded finance lacks that transparency."

Todd Schweitzer, chief executive of the open finance infrastructure firm Brankas, conceded the point from the same panel, citing embedded lending in parts of Southeast Asia running at 100% interest or more with administrative fees on top — "not a high-quality product and arguably predatory."

Abduganieva's second warning is more specific, and more awkward for a strategy built on credit-led digital growth. The most recent financial inclusion survey put formal savings in Uzbekistan below the benchmark for both the Central Asian region and the world. "That's very surprising to me, because our nation has deep roots in saving behaviour. We are really good savers," she said. "But the formal savings level is not enough." Her request to the market was for savings products rather than more lending — and the first priority the central bank listed on publishing its inclusion index was expanding simple savings products.

She also notes that the fintech companies she deals with read the fintech strategy but not the separate national financial inclusion strategy — and that firms chasing margin go where the infrastructure already is. Uzbekistan's fintech market, she said, is "a blue ocean", and in a blue ocean nobody swims to the hard parts voluntarily.

The constraint, and the export

Every projection here rests on demographics. "More than half of our population is young," as Ishmetov puts it, in a country of over 37mn. The target is 5,000 trained fintech professionals by 2030; the governor told reporters the first cohort of 1,000 would start in September on government grants, in partnership with the National University of Singapore, though from the stage the programme was described more loosely as beginning by year-end with Singaporean universities.

The people actually hiring describe a subtler constraint. Marius Dan, who built Franklin Templeton's Tashkent office to more than 20 staff, found that the hardest people to persuade to move to Uzbekistan were Uzbeks living abroad; foreigners came from London and the Gulf readily. That reversed only after the successful listing of the national investment fund UzNIF in May, since when he has been "flooded" with returning expatriates.

Stefan Klestil of Speedinvest put the same thought as a test of the whole project: "The leading indicator of success in tech for a country is the best Uzbeks in the world coming back to start a business here rather than in Silicon Valley."

Ishmetov's own illustration was more direct. Unable to staff the central bank's IT department last year, it ran a hackathon: 40 teams, 160 participants, 80% of whom submitted job applications afterwards, and six to eight hires. The winning team was one banker and three students. "I understand that we will not have problems with young, talented people."

Framing the strategy in his opening address, titled The Silk Road Initiative: Turning a Socio-Economic Heritage into Central Asia's Financial Innovation Corridor, the governor reached for the region's intellectual heritage. Five building blocks: al-jabr, restoring what is missing; al-muqabala, balancing the elements of a sustainable financial ecosystem; zarkaynar, a marketplace where innovation meets opportunity; saroy, shared financial infrastructure; and madrassa, developing talent.

The problem Uzbekistan is trying to solve is not unique to the country. Dozens of developing markets face similar arithmetic: private capital too thin to build financial infrastructure alone, incumbent banks with little incentive to compete themselves out of comfortable positions, and a young population already living on its phones.

Many have concentrated on regulation and public digital infrastructure. Uzbekistan has chosen a more interventionist route: building parts of the market itself and planning eventually to hand some of them to private capital.

It is an unusually interventionist experiment, being conducted openly on a five-year timetable in a financial system still young enough to rebuild rather than retrofit.

Whether it produces a template or a cautionary tale, the answer will travel far beyond Tashkent.