There is a moment that captures everything you need to know about Banking as a Service in the CIS and Central Asia’s digital finance story. Kaspi.kz a company that started as a conventional Kazakhstani bank; now controls 65% of digital payments in Kazakhstan, 45% of the entire e-commerce market, and 32% of consumer lending. It has expanded into Azerbaijan and has Uzbekistan firmly in its sights. this is not a technology company that became a bank; but a bank that became a platform.
That transformation from direct lender to ecosystem engine is precisely what Banking as a Service (BaaS) enables. And across the Commonwealth of Independent States, from Almaty to Baku to Tashkent, the conditions for BaaS to reshape financial services have never been stronger.
Why the CIS Is a BaaS Market Worth Understanding
The CIS+ region; Armenia, Azerbaijan, Georgia, Kazakhstan, Ukraine, and Uzbekistan presents a banking landscape of striking contrasts. On one hand, Fitch Ratings maintains a neutral sector outlook through 2026, anchored by resilient operating environments, double-digit retail lending growth, and robust commodity-driven economies. On the other hand, credit penetration remains low across most markets, financial inclusion challenges persist, and legacy banking infrastructure is the norm rather than the exception.
These contrasts are precisely what make BaaS so compelling here. Low credit penetration means enormous addressable markets for embedded lending. High smartphone adoption in urban centers creates ready distribution channels. Young, digitally active populations; Uzbekistan alone has 36 million people, 56% of whom lacked a bank account as recently as 2021; represent underserved segments that traditional branch banking cannot efficiently reach.
| CIS+ Banking Outlook (Fitch 2026) | Neutral — stable with growth potential |
| Uzbekistan deposit growth forecast 2026 | +20–25% driven by digitalization |
| Kaspi.kz market share in KZ digital payments | 65% — model for regional BaaS |
| Azerbaijan cashless transactions (Jan–Apr 2025) | +67% YoY in volume |
| Kazakhstan GDP growth forecast 2026 | 4.5–5.0% (ING) |
| Global embedded finance CAGR 2025–2030 | ~24.4% (Mordor Intelligence) |
The Defining Shift: From Direct Lender to Platform Engine
Traditional banking in the CIS follows a familiar model: open branches, attract deposits, extend credit, repeat. It has worked. But it scales slowly, serves urban populations better than rural ones, and demands heavy infrastructure investment for each new market entry.
BaaS inverts this logic entirely. Instead of building every customer touchpoint directly, a bank becomes the licensed, regulated infrastructure beneath third-party platforms. An e-commerce marketplace in Tashkent wants to offer instalment financing? The bank provides the credit engine via API. A ride-hailing app in Tbilisi wants to give drivers instant earnings access? The bank provides the wallet infrastructure. A government service portal in Astana wants to embed tax payment capabilities? The bank provides the rails.
The bank catches many customers it would never have acquired directly through partners it never had to market to, via experiences it never had to build. This is the BaaS value proposition, and across the CIS, the conditions for it to flourish are rapidly assembling.
The Market Landscape: Country by Country
Kazakhstan: The BaaS Pioneer
Kazakhstan is the most advanced BaaS market in the CIS. Kaspi’s trajectory from bank to super-app is the regional template, but the infrastructure supporting it; the Astana International Financial Centre (AIFC), progressive fintech regulation, and growing API enablement across major banks; means Kaspi is not the only story.
The country’s Financial Sector Development Strategy has actively encouraged platform business models. The AIFC operates under English common law, making it attractive to international fintech players seeking CIS exposure. And with GDP growth expected at 4.5–5% in 2026 despite fiscal consolidation pressures, the macroeconomic backdrop supports continued digital investment.
For BaaS specifically, Kazakhstan’s challenge is that its regulatory framework still limits traditional banks from opening Islamic windows; a constraint that shapes product architecture but also creates opportunity for purpose-built BaaS providers to fill the gap with compliant solutions.
Azerbaijan: The Open Finance Frontier
Azerbaijan may be the most exciting BaaS story in the CIS right now, and it is largely under-reported. At the Fintex Summit 2025 in Baku; attended by 1,500 delegates from 300 international organisations—the Central Bank of Azerbaijan revealed it had received numerous requests from banks and payment institutions specifically about implementing BaaS, FinTech-as-a-Service, and SaaS solutions.
This is not speculative interest. From January to April 2025, the volume of domestic cashless transactions in Azerbaijan grew by 67%, with the number of such transactions rising over 91%. Monthly cashless payment volumes have approached 10 billion manats ($5.9 billion). The country processed 126 billion manats ($74.1 billion) in card transactions during 2024; a 27% increase year-on-year.
Perhaps most significantly, Azerbaijan’s Central Bank has mapped out a deliberate path towards an open finance model: a unified API ecosystem connecting the entire financial sector, enabling innovative service models. BaaS is not emerging organically here. It is being architected by the regulator.
Uzbekistan: The Sleeping Giant Awakening
Uzbekistan’s fintech scene is transforming faster than most outside observers realise. With 36 million people and a historically underbanked population, the country is experiencing double-digit banking sector growth. Fitch forecasts deposit volumes growing 20–25% in 2026 alone, driven by rising household incomes, a shrinking shadow economy, and accelerating digitalization.
The FinTech & Banking forum in Tashkent has become a serious regional event, attracting leading companies globally and spawning fintech startups like Azma Finance; a platform automating accounting and tax management for small businesses; that demonstrate the appetite for embedded financial services.
BaaS in Uzbekistan is not yet mature, but the foundations are forming quickly. E-commerce growth, combined with high mobile penetration in urban areas and regulatory reform driven by International Monetary Fund and World Bank engagement, is creating the conditions for rapid BaaS adoption once licensing frameworks clarify.
Georgia and Armenia: The Integration Hubs
Georgia’s banking sector is dominated by TBC Bank and Bank of Georgia, both London Stock Exchange-listed, which gives them a sophistication and API readiness unusual for the region. Around 50 fintechs now operate in Georgia, with Ranko; a Georgian startup; winning recognition at international competitions. Georgia’s ambitions to become a regional fintech hub make it a natural BaaS gateway for companies seeking broader CIS exposure.
Armenia is following a similar trajectory, with the National Bank exploring CBDC capabilities and actively digitizing payment infrastructure. The Financial Sector Development Strategy 2024–2026 prioritizes insurance, capital markets, and payment systems; all areas where embedded finance through BaaS creates significant opportunity.
The Architecture Behind BaaS in the CIS
Understanding what makes BaaS work in this region requires understanding the technical and regulatory foundations it depends on.
API Connectivity: The Non-Negotiable Foundation
BaaS is fundamentally an API business. A bank cannot power third-party platforms if its core banking system cannot expose functions through reliable, well-documented APIs. This sounds obvious, but across the CIS, most legacy core banking systems were not built with external API consumption in mind. They were built for internal operations.
This is where the choice of core banking platform becomes strategically critical. A BaaS-ready bank needs comprehensive API coverage; not just for payments and balances, but for account creation, KYC orchestration, lending decisions, transaction categorization, and compliance reporting. Modern platforms like Fimple expose over 9,000 APIs precisely because the platform business model demands this breadth.
The Side-Core Approach: De-Risking BaaS Entry
For established CIS banks with legacy core systems, a full core replacement carries unacceptable risk. Migrating millions of accounts in markets where public trust in banks is still being built is not a sensible gamble. The side-core approach offers a pragmatic alternative.
A modern, API-first core sits alongside the legacy system. New BaaS products; digital wallets, embedded lending, white-label accounts launch on the modern core. Existing customer accounts and traditional products stay on the legacy core. Over time, the bank can migrate products selectively, at its own pace, with each phase de-risked by the previous one. The critical challenge is maintaining a single version of truth across both systems; a solved problem for experienced implementation partners.
Regulatory Readiness: Evolving Frameworks
CIS regulators are at different stages of BaaS enablement. Azerbaijan is moving fastest with a deliberate open finance roadmap. Kazakhstan has the most sophisticated framework but some constraints around Islamic windows and cross-border operations. Uzbekistan is reforming rapidly but the framework is still maturing.
For banks and fintechs planning BaaS strategies, this means building configurable compliance architectures that can adapt to local regulatory evolution without requiring platform changes. A core banking platform operating across multiple CIS jurisdictions needs parameterized compliance rules, not hardcoded ones.
Why Fimple is Built for the CIS BaaS Opportunity
The CIS market has specific requirements that distinguish it from Western European or GCC BaaS deployments. Understanding these requirements explains why platform choice matters enormously.
Multi-Jurisdiction Configuration
Operating across Kazakhstan, Azerbaijan, Uzbekistan, Georgia, and Armenia means navigating five different regulatory frameworks, multiple currencies, varying KYC requirements, and different tax reporting obligations. Fimple’s configurable compliance engine handles this through parameterization rather than custom development; enabling banks to adapt to local requirements without the cost and delay of bespoke engineering.
Rapid Deployment for a Fast-Moving Market
The CIS digital banking market is moving at speed. Kaspi’s Azerbaijan expansion, Azerbaijan’s open finance roadmap, Uzbekistan’s banking sector growth; these are not slow-moving trends. A bank or fintech that takes 18 months to launch a BaaS proposition will find the market has moved. Fimple’s low-code configuration approach enables launch of new BaaS products in weeks, not quarters.
SDK Sharing and Ecosystem Development
BaaS is not just about the bank’s capabilities; it is about the ecosystem of developers, fintechs, and non-financial platforms that build on top of those capabilities. Fimple shares solution development kits with customers and partners, enabling them to create their own BaaS use cases without requiring deep banking expertise. This is how ecosystems actually form: by lowering the barrier to participation.
What BaaS Enables in Practice: CIS Use Cases
The theoretical case for BaaS is clear. The practical opportunity becomes vivid when you consider specific CIS use cases.
Embedded agricultural finance is one of the most significant. Across Central Asia, smallholder farmers represent a substantial segment that traditional banks cannot profitably serve through branches. An agricultural supply chain platform; already connecting farmers to inputs and markets can embed lending and insurance through BaaS APIs, reaching farmers at the point of commercial activity rather than requiring branch visits.
Remittance-linked banking is another. CIS countries are major remittance recipients. Millions of workers send money home from Russia, the Gulf, and Europe. A remittance platform that adds embedded saving and lending capabilities powered by a licensed CIS bank through BaaS APIs; transforms a transaction service into a full financial relationship.
SME embedded finance represents perhaps the largest opportunity. Small and medium enterprises across the CIS are chronically underserved by traditional corporate banking. Accounting software, e-commerce platforms, and logistics systems used daily by SME owners are natural distribution channels for embedded lending, payments, and insurance; all deliverable through BaaS.
Conclusion: The Platform Future is Being Built Now
Banking as a Service in the CIS is not a distant possibility. It is being assembled right now through regulatory reform in Azerbaijan, platform expansion by Kaspi across the region, digitalization-driven deposit growth in Uzbekistan, and fintech ecosystem development in Georgia and Armenia.
The banks and fintechs that establish BaaS capabilities in this market today will define its structure for a decade. The infrastructure; API-first core banking platforms, open finance regulatory frameworks, high mobile penetration, and underserved populations hungry for accessible financial services; is in place.
Catching one fish at a time made sense when banking required branches. In 2026, the CIS is building the nets. The question for every financial institution in the region is simple: will you be the infrastructure that powers the ecosystem, or will you be left outside it?
