Law note · Kyrgyzstan

Digital Code, sectoral regulator for personal data

cite Digital Code, Law No. 178, Art. 90 (State Agency for Protection of Personal Data) stage RECENT in force 7 months effective 2026-02-06 kind Enforcement supervision binds public and private bodies reviewed 2026-08-29

What it requires

  • An app processing Kyrgyzstani personal data answers to the State Agency for Protection of Personal Data, which maintains a register of record-holders and can inspect and issue orders under the Digital Code. No fine schedule or private right of action was confirmed for this research; both should be checked directly against Digital Code Art. 90 before relying on their absence.

When LexLint raises it

  • crawls_web
  • trains_models
  • generates_content
  • deploys_chatbot
  • automated_outreach
  • high_risk_decisions
  • processes_voice
  • processes_biometrics

What we found

Art. 90, read in a reviewer pass at the official source (the research pass had not read it), requires the sectoral personal-data regulator to be created under Art. 9 of the Code and to be independent of the persons it oversees, with a head who must hold qualifications and experience in personal-data protection.

Art. 90(3) gives it real powers: applying and overseeing the Code; raising subject and controller awareness; advising state bodies; accrediting inspection bodies under Cabinet of Ministers procedure; hearing complaints and conducting inspections, including on its own initiative; taking preventive, corrective, and enforcement measures for violations; and publishing guidance. Art. 90(4) has it maintain a registry of record-owners recording incidents, inspection results, and binding decisions.

No fine schedule or private-right-of-action provision was found within Art. 90 or elsewhere read in either pass.

The Code's own text never names the regulator (it uses only "отраслевой регулятор в сфере персональных данных," sectoral regulator in the field of personal data, throughout, confirmed by a reviewer-pass search finding zero occurrences of "Агентство" anywhere in the Code); its identity as the State Agency for Protection of Personal Data (DPA) rests on the DPA's own official site, read directly, which describes itself in exactly these Digital-Code terms and institutionally predates the Code, having been established by a 2021 amendment to the now-repealed Law No. 58.

Primary source

official government portal
Centralized Bank of Legal Information of the Kyrgyz Republic (cbd.minjust.gov.kg), for Art. 90, which serves this page's text only to a rendering tier: a plain HTTP fetch of this same URL returns a 1,961-character JavaScript shell with zero hits for any Chapter 11 term, while the crawler's STEALTH_PLUS rendering tier returns the full 657,172-character document State Agency for Protection of Personal Data official site (dpa.gov.kg) for the regulator's identity

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