The IBC's Commentary on the Draft Law Affecting Courier Services

IBC, March 13, 2026. The International Business Council (IBC) has prepared an expert opinion and recommendations on the draft Law of the Kyrgyz Republic "On Amendments to Certain Legislative Acts of the Kyrgyz Republic on Road Safety." On March 11, 2026, the Jogorku Kenesh of the Kyrgyz Republic adopted, in its second reading, the draft law "On Amendments to Certain Legislative Acts of the Kyrgyz Republic on Road Safety," which, among other things, proposes introducing mandatory state registration of mopeds and mandatory acquisition of the corresponding category of driver's license. The IBC has previously sent numerous appeals to deputies of the 7th and 8th convocations of the Jogorku Kenesh regarding this draft law, and hopes for continued support in its constructive review, which is important for both the business community and the citizens of the Kyrgyz Republic as a whole. The expert opinion was prepared to assess the potential socio-economic risks related to citizens' employment should the draft law be adopted without simultaneously introducing mechanisms to legalize previously imported and currently used mopeds, and without expanding the network of driving schools offering training for the relevant license category. IBC members support the bill's goals of improving road safety, regulating the use of motorized two-wheelers, and establishing uniform rules for road users. At the same time, analysis of the proposed provisions shows that implementing them as currently drafted could lead to significant socio-economic consequences for a large group of citizens and create a number of practical problems in enforcing the law.

1. The Socio-Economic Role of Mopeds and Motorized Two-Wheelers
According to data obtained from participants in the courier services market, more than 7,000 couriers in the Kyrgyz Republic currently use mopeds and low-power motorized two-wheelers to carry out their work. Delivery services form part of the urban logistics infrastructure for food service, retail, online marketplaces, and pharmacies. Importantly, for most of these users, mopeds are not a means of personal transportation but a tool for economic activity. The main users are: students; citizens with part-time employment; members of socially vulnerable groups; and individuals using delivery work as a side income. Mopeds allow these groups to earn income and maintain mobility amid heavy traffic congestion in major cities. For many young people and internal labor migrants, courier work is one of the few forms of employment available to them. Mopeds are also among the most economical and environmentally friendly forms of urban transport, reducing pressure on road infrastructure and traffic flow.

2. Socio-Economic Consequences
An abrupt change to the rules governing who may operate this type of vehicle directly affects the employment and income of a substantial number of citizens and could lead to the following consequences: loss of income for thousands of citizens; higher logistics costs for small and medium-sized businesses; rising prices for goods and services due to more expensive delivery; a reduction in jobs within the service economy; and lower tax revenues. The scale of the courier employment market directly affects the volume of the consumer economy, and adopting the law in its current form could trigger a domino effect impacting all related industries and the tax revenue generated by them.

3. Limited Training Infrastructure (Category A1)
Under the proposed amendments, operating a moped would require a Category A1 driver's license. However, the country currently has a limited number of driving schools offering Category A1 training, which creates an institutional barrier to quickly obtaining the required license. If the law takes effect in the near term, a significant portion of current moped users would be unable to promptly obtain the necessary license due to the shortage of driving schools. As a result, a large share of citizens who rely on mopeds for income would effectively be barred from working for an extended period, potentially costing thousands of households their source of income.

4. The Problem of Registering Existing Mopeds
Most mopeds were imported into the country during a period when registration was not required. As a result: owners lack technical passports; there is no documentation confirming the vehicle's origin; and there is no unified registration standard. If the law is introduced without a legalization mechanism, a large share of owners simply will not be able to register their vehicles, despite wanting to comply with the law. This could lead to: an increase in unregistered, shadow use of vehicles; a rise in fines without any real improvement in safety; and conflicts between drivers and regulatory authorities.

5. International Practice
To ensure an effective and socially acceptable transition to mandatory registration of mopeds and similar vehicles, it would be worthwhile to introduce simplified and transparent registration procedures. In this regard, it is proposed to draw on the experience of the Republic of Kazakhstan, where mandatory registration of such vehicles was introduced alongside a minimal set of requirements, including an identity document and vehicle documentation, or, in their absence, technical specifications confirmed from publicly available sources. This approach made it possible to legalize vehicles, preserve employment, and avoid negative social consequences.

Proposed Solutions
Improving road safety is an unconditional priority. However, effective regulation must take into account the real conditions of the labor market, infrastructure, and business environment. The growth of delivery services and urban logistics in recent years has become an important part of the modern service economy. This sector generates significant turnover in food service, e-commerce, and retail trade, while also contributing tax revenue through the activities of restaurants, shops, and service platforms. Restricting courier infrastructure could have an indirect impact on the turnover of small and medium-sized businesses, employment levels, and the volume of tax revenue collected by the budget. It is therefore important to ensure a smooth and well-considered transition to the new rules, one that can simultaneously: improve road safety; preserve jobs; and avoid placing excessive administrative burden on citizens and business. In this regard, IBC members consider it advisable to provide for the following measures to ensure a smooth transition to the new regulatory requirements:

1. Transition Period
Establish a transition period of at least 12 months from the date the law takes effect, during which the requirements for holding a Category A1 driver's license and registering mopeds with the state are applied without penalties.

2. Simplified Registration Procedure for Previously Imported Mopeds
For mopeds imported into the Kyrgyz Republic prior to the law's entry into force, provide for a simplified registration procedure that allows registration in the absence of a technical passport, based on: the vehicle identification number (VIN) or engine number; and a written statement from the owner confirming actual ownership of the vehicle.

3. Adaptation Period for Obtaining Category A1
During the transition period, allow for the continued operation of mopeds provided the driver is enrolled in a training program or is preparing to obtain a Category A1 driver's license. A phased approach to regulation will make it possible to improve road safety without dismantling the economic ecosystem that has developed around this sector. The International Business Council expresses its readiness for continued expert dialogue with government bodies on improving regulation in this area and remains open to participating in discussions on the practical implementation of the proposed measures.