Kyrgyzstan is preparing to enter the global ship-registration market despite having no direct access to the sea, a move that could generate revenue but also expose the country to new regulatory and reputational risks.
Kyrgyz lawmakers have adopted legislation allowing merchant ships to register under the national flag, giving the landlocked Central Asian country a potential foothold in an industry normally associated with maritime powers.
Lawmakers approved the Merchant Shipping Code and related legislation in late June, including provisions for Kyrgyzstan’s accession to 14 international conventions developed under the International Maritime Organization (IMO).
The Ministry of Economy and Commerce says the code gives Kyrgyzstan the legal tools to regulate merchant shipping and formalizes its right, under international law, to access the seas and participate in maritime trade, despite having no coastline.
In practical terms, the legislation allows seagoing vessels to be registered under the Kyrgyz flag and lays the groundwork for an International Ship Register. It also sets out rules on maritime safety, seafarers’ rights, insurance, and shipowner liability.
The move follows Kyrgyzstan’s accession to the IMO in 2024, when it became the organization’s 176th member state. Officials have presented the legislation as a way to give Kyrgyz-registered ships international recognition, attract investment, and create opportunities for Kyrgyz companies in global shipping. The more immediate use case is simpler: a ship registry can generate fees by allowing foreign-owned vessels to sail under a national flag.
According to 24.kg, ministry officials told parliament that the registry could eventually bring Kyrgyzstan $10 million-$15 million a year, though they said exact calculations were not yet possible because the number and tonnage of future vessels were unknown.
That model is legal and not unusual. Mongolia, another landlocked Asian state, operates a ship registry and was cited by Deputy Economy Minister Sultan Akhmatov when he presented the draft code to lawmakers.
But several deputies were unconvinced. Dastanbek Dzhumabekov said the government needed to explain the proposal in clearer language, asking what the code would actually give the country and whether it would become another document that “gathers dust.”
Another concern is control. In May, Dzhumabekov warned that if a vessel sailing under the Kyrgyz flag carried sanctioned goods, the result could be a damaging international scandal. Another deputy, Bolot Sagynayev, later claimed that open shipping databases already showed more than 100 vessels sailing under the Kyrgyz flag. Akhmatov said Kyrgyzstan had issued no such permissions, because the maritime administration and ship register had not yet been created, and suggested the listings could be fraudulent.
The registry could prove attractive to foreign shipowners looking for a new flag jurisdiction. Open ship registries, often described as “flags of convenience,” are widely used in global shipping and are not illegal. But they have also come under scrutiny because vessels involved in sanctions evasion and shadow-fleet activity often change flags, obscure ownership, or rely on weak registry oversight.
There is no evidence that Kyrgyzstan’s new registry is intended for sanctions-busting. But if the country builds a fleet on paper rather than through domestically owned shipping companies, its credibility will depend on how strictly it vets vessel ownership, insurance, safety records, and links to sanctioned trade.
