Why is this important
The new rules protect borrowers from bank manipulation and unscrupulous practices. The risk checklist will help citizens make informed decisions about loans. Prohibiting autofill and default checkpoints will prevent imposing unfavorable conditions. The mandatory restructuring procedure will give borrowers in difficult situations a chance to avoid default.
What happened
- The Central Bank approved new requirements for banks when lending to individuals;
- The Ministry of Justice registered the resolution on October 28, it comes into force on January 29, 2026;
- Risk checklists are being introduced when processing a loan;
- It is prohibited to automatically check consent and autofill parameters in online forms;
- Banks should develop a transparent restructuring procedure;
- “Unfair practices” are prohibited: imposing large sums, collecting social benefits, and making early demands.
Risk checklist
Banks are obligated to provide borrowers with a standard list of risks associated with financial obligations. The Central Bank expects this to allow clients to make informed decisions about borrowing.
Examples of risks:
- Risk of non-repayment: what happens if I can’t pay;
- Fines and penalties for late payment;
- Consequences for credit history;
- Possibility of loss of the pledged property;
- Impact on family budget.
Online lending restrictions
Prohibited:
- Place “default” checkmarks and switches indicating the client’s consent;
- Substitute the loan parameters (amount, interest, term) into the online form in advance.
The goal is to ensure freedom of decision-making, strengthen transparency of conditions, and prevent misunderstandings between banks and clients.
Restructuring
Banks should develop an internal procedure for reviewing (restructuring) loan agreements if the borrower cannot make payments on time due to financial difficulties. The procedure should be transparent for consumers.
Restructuring may include:
- Reduction of monthly payment;
- Increase in the loan term;
- Temporary deferral of payments (credit holidays);
- Reviewing the interest rate.
Prohibition of “dishonest practices”
Banks are prohibited:
- Encourage borrowers to obtain a loan for an amount exceeding the amount they indicate in the application;
- To impose a penalty on social benefits and financial assistance from the state;
- Submit claims for the recovery of payments before the calendar date specified in the contract or return schedule.
Guaranteeing deposits
Banks must inform clients about:
- System of deposit guarantees;
- Types of deposits subject to guarantee;
- Maximum guaranteed amount;
- The procedure and timeframe for paying compensation.
Context
The new rules are the Central Bank’s response to the growth of consumer lending (36% of the loan portfolio, +23% year-on-year) and complaints about unscrupulous banking practices. Individuals often take loans without understanding the risks, which leads to defaults and legal disputes.
The risk checklist is a common practice in developed countries. In the EU and the USA, banks are obligated to provide borrowers with complete information about the risks and consequences of loan default.
The “default” ban on autofill and checkmarks is directed against dark patterns — manipulative UX design techniques that encourage users to make unfavorable decisions. For example, an automatically placed consent checkmark for insurance or a pre-filled loan amount higher than the requested amount.
Mandatory restructuring gives borrowers in difficult situations the opportunity to avoid default and preserve their credit history. Previously, banks could refuse restructuring at their discretion, leading to mass non-returns and judicial penalties.
The ban on collecting social benefits protects the most vulnerable groups: pensioners, disabled people, and low-income families. Previously, banks could collect debts from any income, including pensions and child benefits, leaving people without means of subsistence.
The prohibition of early demands prevents banks from demanding the immediate return of the entire loan amount at the slightest delay without giving the borrower time to rectify the situation.
Information about deposit guarantee increases confidence in the banking system. Many clients are unaware that their deposits are insured by the Deposit Insurance Fund for up to 400 million soums (approximately $33 thousand).
