Kyrgyzstan
On 11 January 2025, the Krygyz Republic published its inaugural NAP.
Available NAPs
Kyrgyzstan: 1st NAP (2025-2027)
Status
The Kyrgyz Republic published its inaugural NAP on 11 January 2025.
Process
A report by the Kyrgyz Ombudsman titled “On the Observance of Human and Civil Rights and Freedoms in 2021”, included a recommendation that the Cabinet of Ministers if the Kyrgyz Republic develop and adopt a NAP on BHR to implement the UNGPs. On 16 June 2022, the Cabinet of Ministers of the Kyrgyz Republic subsequently committed to develop a NAP on BHR to implement the UN Guiding Principles.
On January 19 2023, the First Deputy Minister of Economy and Commerce issued an order establishing an interdepartemental working group to draft the NAP. The working group was authorised, where necessary, to involve ministries, administrative departments, other executive bodies, interdependent experts, and consultants in the drafting process. The Business Environment Policy Department was tasked with providing organisational and methodological support for the group’s activities.
The NAP was developed with support from UNDP, which provided technical assistance to the Ministry of Economy and Commerce and the Office of the Ombudsperson of the Kyrgyz Republic.
The NAP was published on 11 January 2025 and covers the period 2025-2027.
National Baseline Assessment (NBA)
- Published in 2023 and available here. Executive summary in English is available here.
- Developed to inform the development of Kyrgyzstan’s NAP on BHR. It includes an analysis of the BHR framework and key conclusions and recommendations to promote BHR.
- Conducted by “lawyers of the Public Foundation ‘Legal Clinic ‘Adilet” Kurmanbayeva A. M. and Sergeeva N. D., management consultants Sydykova Z. B. and Biyalieva Ch. S. This publication was developed under the UNDP project “Business and Human Rights” (B+HR) in the Kyrgyz Republic, with the support of the Government of Japan.”
- Utilised some DIHR/ICAR methodology. The assessment drew on policy and legislative analysis, alongside consultations and surveys with key stakeholders across five sectors, stakeholder mapping, and screening of company websites for integration of the UNGPs.
Follow-up, monitoring, reporting and review
The NAP identifies four priority areas for implementation, but there is no accountability or monitoring framework in the NAP.
Stakeholders views and analysis on the NAP
Agriculture sector
The Kyrgyzstan NAP does not make explicit reference to the agriculture sector.
Children’s rights
2.3 Access to Legal Remedies for Aggrieved Persons When Business Violates Their Rights All members of society, including indigenous peoples, migrants, women, and children, are entitled to file complaints and must be afforded the same legal protection as the general population. No legislative restrictions in this regard have been identified.
Conflict-affected areas
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 9 | Produce recommendations for legal entities aimed at the identification and prevention of negative impact on human rights | Q3 2026 | The recommendations have been published on the official website of the authorized body on entrepreneurship and disseminated among business associations. Businesses are aware of: – potential risks related to specific types of economic activity, taking into account the border conflict and internal displacement; – measures to prevent the negative impact of business activities on human rights. | MEC, business associations, NGOs (to be agreed) | National budget and budgets of donor organizations |
Construction sector
The Kyrgyz NAP does not an explicit reference to the construction sector.
Corporate law & corporate governance
Chapter 2: Analysis and Assessment of the Current Situation
The legislative framework of the Kyrgyz Republic does not currently establish a regulatory basis for fostering a coordinated approach to promoting responsible business conduct with respect to human rights.
Chapter 3. Purpose and Tasks of the Implementation Program for the United Nations Guiding Principles on Business and Human Rights until 2027
In order to achieve this objective, the following tasks have been identified: 3) promote the exercise of due diligence with respect to human rights in the context of responsible corporate governance
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 15 | Develop a Corporate Governance Code | Q3 2026 | – The Corporate Governance Code has been approved; – Management bodies of OJSc with state participation have adopted corporate governance codes containing references to the UN Guiding Principles | FMRSS, SASPM | National budget | |
| 17 | Make amendments on the Regulation on Procedure for Reporting (Information Provision) and Disclosure by financial market entities approved by the Resolution of the Government of the Kyrgyz Republic No.417 dated September 4, 2018 | Q2 2027 | – Amendments have been made to the Resolution of the Government of the Kyrgyz Republic No.417 dated September 4, 2018; – Public companies include information on the availability of the human rights policy and other matters arising from the UN Guiding Principles into their brief description of corporate governance practices in relation to the regulated financial market entity as part of their reports | FMRSS, business associations (to be agreed) | National budgey | |
| 18 | Draft and adopt: – A guide on development of programmatic commitments (corporate policy) of companies on respect for human rights in business; – Methodology to assess the impact of entrepreneurial activity on human rights taken into account sectors of activity | 2005-2006 | The guide and methodology have been publishes on the official websites of the authorized state body on entrepreneurship and the authorized state body on state property management. The documents have been disseminated among state enterprises, business entities with state participation and business associations | MEC, SASPM, business associations, NGOs (to be agreed) | National budget |
Corruption
The Kyrgyz NAP does not an explicit reference to corruption.
Data protection & privacy
The Kyrgyz NAP does not an explicit reference to data protection and privacy.
Development finance institutions
The Kyrgyz NAP does not an explicit reference to development finance institutions.
Energy sector
The Kyrgyz NAP does not an explicit reference to the energy sector.
Environment & climate change
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 11 | Develop a guide on environment protection and realization of the human right to a favorable environment for specific business activities and publish the same of the websites of state authorities | 2005 – 2007 | Information on environment protection and realization of the human right to a favorable environment is available for specific business sectors | MNRETS | National budget |
Environment & climate change
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 11 | Develop a guide on environment protection and realization of the human right to a favorable environment for specific business activities and publish the same of the websites of state authorities | 2005 – 2007 | Information on environment protection and realization of the human right to a favorable environment is available for specific business sectors | MNRETS | National budget |
Equality & non-discrimination
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 8 | Build the capacity of the employees of state bodies and stakeholders in the UN Guiding Principles | Organize training workshops on non discrimination and inclusiveness, focusing on developing skills to identify vulnerable groups and implement measures to protect their rights (individuals with disabilities, migrant workers with family responsibilities, older adults, and others) | Q3 2025 | Four (4) activities have been conducted per year | MLSSM | National budget and budgets of donor organizations |
| 10 | Build the capacity of the employees of state bodies and stakeholders in the UN Guiding Principles | Conduct an analysis of components aimed at shaping the culture of zero-tolerance towards gender discrimination, as a socially significant norm of the subject educational standard | Q3 2026 | All educational programs at all levels integrate the components aimed at shaping the culture of zero-tolerance towards gender discrimination as a socially significant norm | MES, MCISYP, business associations, NGOs (to be agreed) | National budget |
Export credit
The Kyrgyz NAP does not an explicit reference to export credit.
Extractives sector
The Kyrgyz NAP does not an explicit reference to the extractive sector.
Extraterritorial jurisdiction
The Kyrgyz NAP does not an explicit reference to extraterritorial jurisdiction.
Finance & banking sector
The Kyrgyz NAP does not an explicit reference to the finance and banking sector.
Fisheries and aquaculture sectors
The Kyrgyz NAP does not an explicit reference to the fisheries and aquaculture sector.
Forced labour & modern slavery
The Kyrgyz NAP does not an explicit reference to forced labour and modern slavery.
Freedom of association
The Kyrgyz NAP does not an explicit reference to freedom of association.
Garment, Textile and Footwear Sector
The Kyrgyz NAP does not an explicit reference to the garment, textile and footwear sector.
Gender & women’s rights
2.3 Access to Legal Remedies for Aggrieved Persons When Business Violates Their Rights
All members of society, including indigenous peoples, migrants, women, and children, are entitled to file complaints and must be afforded the same legal protection as the general population. No legislative restrictions in this regard have been identified.
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 10 | Build the capacity of the employees of state bodies and stakeholders in the UN Guiding Principles | Conduct an analysis of components aimed at shaping the culture of zero-tolerance towards gender discrimination, as a socially significant norm of the subject educational standard | Q3 2026 | All educational programs at all levels integrate the components aimed at shaping the culture of zero-tolerance towards gender discrimination as a socially significant norm | MES, MCISYP, business associations, NGOs (to be agreed) | National budget |
Guidance to business
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 5 | Raise the awareness of business entities about the UN Guiding Principles | Conduct an awareness raising campaign on the UN Guiding Principles and the application of business and human rights standards through state media and Internet sites | Ongoing | Public awareness raising and outreach campaigns have been held, UNGP texts and explaining materials has been published in the media | Ombudsman (Akyikatchy), business associations, NGOs (to be agreed) | National budget and budgets of donor organizations |
| 6 | Raise the awareness of business entities about the UN Guiding Principles | Disseminate among businesses the respective guidelines, methodological documents and recommendations of international organizations on business and human rights, including through the translation thereof into the state language | Q3 2026 | Guidelines, methodological documents and recommendations of international organizations on business and human rights have been translated into the state and official languages | MEC, Ombudsman (Akyikatchy) (to be agreed) | National budget and budgets of donor organizations |
| 9 | Build the capacity of the employees of state bodies and stakeholders in the UN Guiding Principles | Produce recommendations for legal entities aimed at the identification and prevention of negative impact on human rights | Q3 2026 | The recommendations have been published on the official website of the authorized body on entrepreneurship and disseminated among business associations. Businesses are aware of: – potential risks related to specific types of economic activity, taking into account the border conflict and internal displacement; – measures to prevent the negative impact of business activities on human rights. | MEC, business associations, NGOs (to be agreed) | National budget and budgets of donor organizations |
| 11 | Develop a guide on environment protection and realization of the human right to a favorable environment for specific business activities and publish the same of the websites of state authorities | 2005 – 2007 | Information on environment protection and realization of the human right to a favorable environment is available for specific business sectors | MNRETS | National budget | |
| 12 | Organize training on legal requirements to respect the human right to a favorable environment in businesses | Q3 2025 | Training sessions have been organized for business associations, civil society representative and other stakeholders | MNRETS, business associations NGOs (to be agreed) | National budget |
Health and social care
The Kyrgyz NAP does not an explicit reference to health and social care.
Human rights defenders & Civic space
The Kyrgyz NAP does not an explicit reference to human rights defenders and civic space.
Human rights impact assessments
The Kyrgyz NAP does not an explicit reference to human rights impact assessments.
Indigenous Peoples
2.3 Access to Legal Remedies for Aggrieved Persons When Business Violates Their Rights All members of society, including indigenous peoples, migrants, women, and children, are entitled to file complaints and must be afforded the same legal protection as the general population. No legislative restrictions in this regard have been identified.
Information and communications technology (ICT) and electronics sector
The Kyrgyz NAP does not an explicit reference to the information and communications technology and electronics sector.
Read more about Information and communications technology (ICT) and electronics sector
Investment treaties & investor-state dispute settlements (ISDS)
The Kyrgyz NAP does not an explicit reference to investment treaties and investor-state dispute settlement.
Read more about Investment treaties & investor-state dispute settlements (ISDS)
Judicial remedy
2.3 Access to Legal Remedies for Aggrieved Persons When Business Violates Their Rights
An analysis of the legislation of the Kyrgyz Republic for compliance with Pillar III of the UN Guiding Principles has revealed the existence of laws establishing liability for businesses causing harm to individuals’ health, property, the environment, and for violations of labor rights. These laws obligate businesses to compensate for damages and restore violated rights. However, the current legal norms do not incentivize enterprises to prevent human rights violations, adopt preventive protection measures, or engage in responsible behavior. Furthermore, adverse human rights impacts resulting from business activities do not limit businesses’ access to state funding. […]
In this regard, the State should take additional measures to ensure access to justice for vulnerable populations. These measures may include conducting public awareness campaigns, providing free legal assistance, equipping court buildings with appropriate infrastructure, training judges, lawyers, and prosecutors on the specificities of protecting the rights of vulnerable groups, and offering concessions on judicial costs/state fees.
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 21 | Create mechanisms to encourage apologies for unfavorable impact on human rights due to business activities | Conduct an analysis of the legislative framework to identify provisions obliging business entities who violated human rights not only to compensate for the harm but also take public responsibility and tender apologies | Q2 2026 | A report and a respective document have been drafted encouraging business entities to tender public apologies for violating human rights in addition to compensation for the harm | MEC, business associations, NGOs (to be agreed) | National budget |
| 22 | Enhance the quality of SGLA | Develop a training module on human rights in business for providing legal consultations to individuals in the event business violate their rights | Q3 2026 | A training module for an online platform has been developed for coordinators and lawyers of the SGLA system and employees of the 114 hotline | Legal Aid Service under the MJ | National budget |
| 23 | Organize activities to enhance the knowledge of coordinators and lawyers of the SGLA system and the employees of the 114 hotline on human rights in business | Ongoing | Four (4) training seminars have been organized per year on human rights and business | |||
| 24 | Build the capacity of judges, lawyers, prosecutors, law enforcement officials, mediators and arbitrators on matters related to business and human rights | Ongoing | Two (2) activities have been organized per year to raise the awareness and improve the knowledge of mediators and arbitrators on human rights and business | CCI ( to be agreed) | Enterprise’s own funds | |
| 25 | Develop training plans and programs related to business and human rights. Incorporate topics on business and human rights into the curricula of the Higher School of Justice of the Kyrgyz Republic, the training center of the Bar of the Kyrgyz Republic, as well as into the training programs for law enforcement officers | Ongoing | – Training plans and programs have been developed; – Judges, lawyers, prosecutors and law enforcement officers have been trained on matters related to business and human rights | HS, PGO (to be agreed), MIA, the Bar of the Kyrgyz Republic (to be agreed) | National budget Enterprise’s own funds |
Land and natural resources
The Kyrgyz NAP does not an explicit reference to land and natural resources.
Mandatory human rights due diligence
The Kyrgyz NAP does not an explicit reference to mandatory human rights due diligence.
Migrant workers
2.3 Access to Legal Remedies for Aggrieved Persons When Business Violates Their Rights
All members of society, including indigenous peoples, migrants, women, and children, are entitled to file complaints and must be afforded the same legal protection as the general population. No legislative restrictions in this regard have been identified.
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 8 | Organize training workshops on non-discrimination and inclusiveness, focusing on developing skills to identify vulnerable groups and implement measures to protect their rights (individuals with disabilities, migrant workers with family responsibilities, older adults, and others) | Q3 2025 | Four (4) activities have been conducted per year | MLSSM | National budget and budgets of donor organizations |
National Human Rights Institutions (NHRIs)/ Ombudspersons
The Kyrgyz NAP does not an explicit reference to National Human Rights Institutions/Ombudspersons.
Read more about National Human Rights Institutions (NHRIs)/ Ombudspersons
Non-judicial grievance mechanisms
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 13 | Promote the UN Guiding Principles, including the commitments to respect human rights, take due diligence measures and create a grievance mechanism, in the Kyrgyz Republic | Develop a respective order of MEC, encouraging business entities to apply UNGPs in their activities, incorporate commitments to take programmatic measures to respect human rights into their strategic development plans, take due diligence measures, create a grievance mechanism, implement measures to manage the supply chain in the context of respect for human rights | Q3 2026 | – A MEC order has been adopted; – state-owned business entities, business entities with state participation have adopted strategic development plans, corporate policies and commitments to respect human rights, created grievance mechanisms | MEC, SASPM, FMRSS, business associations, NGOs (to be agreed) | National budget |
OECD National Contact Points (NCPs)
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 2 | Examine the feasibility of acceding to the OECD Declaration on International Investment and Multinational Enterprises | Q2 2026 | – A situational, financial and economic, and legal analysis have been conducted; – A report on the preparedness of the Kyrgyz Republic to accede to the OECD Declaration has been drafted. | NIA, MEC, SASPM, business associations, NGOs (to be agreed) | National budget | |
| 3 | Analyze international best practices in the operation of OECD National Contact Points (OECD NCPs). | Q2 2026 | A report on the feasibility/unfeasibility of OECD NCP establishment containing risk and benefit analysis has been prepared and submitted to MEC | NIA, MEC, business associations, NGOs (to be agreed) | National budget |
Persons with disabilities
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 8 | Organize training workshops on non-discrimination and inclusiveness, focusing on developing skills to identify vulnerable groups and implement measures to protect their rights (individuals with disabilities, migrant workers with family responsibilities, older adults, and others) | Q3 2025 | Four (4) activities have been conducted per year | MLSSM | National budget and budgets of donor organizations |
Privatisation
The Kyrgyz NAP does not an explicit reference to privatisation.
Public procurement
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 7 | Build the capacity of the employees of state bodies and stakeholders in the UN Guiding Principles | Train the employees of the state and municipal bodies in the UN Guiding Principles | Q3 2025 | Four (4) activities have been conducted per year for the employees of executive bodies | MH, SACSLSG, MEC, international organizations (to be agreed) | National budget and budgets of donor organizations |
Security & Defence sector
The Kyrgyz NAP does not an explicit reference to the security and defence sector.
Small & medium-sized enterprises (SMEs)
The Kyrgyz NAP does not an explicit reference to small and medium enterprises.
Special Economic Zones (SEZs)
The Kyrgyzstan NAP does not make explicit reference to SEZs.
State Owned Enterprises/ Public Private Partnerships
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 7 | Build the capacity of the employees of state bodies and stakeholders in the UN Guiding Principles | Train the employees of the state and municipal bodies in the UN Guiding Principles | Q3 2025 | Four (4) activities have been conducted per year for the employees of executive bodies | MH, SACSLSG, MEC, international organizations (to be agreed) | National budget and budgets of donor organizations |
Read more about State Owned Enterprises/ Public Private Partnerships
Supply chains
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 13 | Promote the UN Guiding Principles, including the commitments to respect human rights, take due diligence measures and create a grievance mechanism, in the Kyrgyz Republic | Develop a respective order of MEC, encouraging business entities to apply UNGPs in their activities, incorporate commitments to take programmatic measures to respect human rights into their strategic development plans, take due diligence measures, create a grievance mechanism, implement measures to manage the supply chain in the context of respect for human rights | Q3 2026 | – A MEC order has been adopted; – state-owned business entities, business entities with state participation have adopted strategic development plans, corporate policies and commitments to respect human rights, created grievance mechanisms | MEC, SASPM, FMRSS, business associations, NGOs (to be agreed) | National budget |
Sustainability Reporting
The Kyrgyz NAP does not an explicit reference to sustainability reporting.
Sustainable Development
Chapter 3. Purpose and Tasks of the Implementation Program for the United Nations Guiding Principles on Business and Human Rights until 2027
In order to achieve this objective, the following tasks have been identified: 5) support the implementation of the 2030 Agenda for Sustainable Development.
Tax
The Kyrgyz NAP does not an explicit reference to tax.
Tourism sector
The Kyrgyz NAP does not an explicit reference to the tourism sector.
Trade and investment
The Kyrgyz NAP does not an explicit reference to trade.
Workers’ rights
| No. | Tasks | Measures/ Activities | Timeframe | Expected results (deliverables) | Parties responsible | Source of funding |
| 1 | Integrate the business and human rights policy into the legislation of the Kyrgyz Republic in accordance with the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights until 2011 (UN Guiding Principles) and the UN Global Compact | Analyze the possibility of ratification by the Kyrgyz Republic of the following: – ILO Occupational Safety and Health Convention No.155; – ILO Promotional Framework for Occupational Safety and Health Convention No.187; – ILO Migrant Workers (Supplementary Provisions) Convention No.143 dated 1975 and Migrant Workers Recommendation No.151, intended to protect the rights of all migrant workers regardless of their status | Q3 2026 | A report and financial estimates have been prepared on the preparedness of the Kyrgyz Republic to ratify the ILO conventions based on the analyses (situational, legal, financial and economic) on the preparedness/unpreparedness of the Kyrgyz Republic to ratify the ILO Conventions | MLSSM, MH, MFA, NGOs (to be agreed) | Budgets of the state bodies involved |
| 4 | Draft and adopt an order of the Cabinet of Ministers of the Kyrgyz Republic ‘On Approval of the Occupational Health and Safety Program’ | Q3 2025 | – Occupational health and safety have improved | MLSSM | National budget |
