HUMO Pay launches free card-to-card transfers in Uzbekistan, with a 100 million som monthly limit through 31 December 2026

HUMO has launched the HUMO Pay app, and until 31 December 2026 transfers between HUMO cards are free up to 100 million som per month, or about $8,250. For PSPs and high-risk operators, the interesting part is not the consumer app itself, but the rail it normalises: cheap card-to-card movement is exactly the kind of infrastructure P2P flows tend to sit on.

1. HUMO Pay makes card-to-card transfers free through 31 December 2026, with a monthly cap of 100 million som. On paper that is a consumer feature. In practice it lowers the cost of the “player → trader card” model that P2P flows often use, at least while the zero-fee window is open.
2. Uzbekistan is tightening controls on card transfers at the same time. Under internal control rules signed by the Central Bank and the Department for Combating Economic Crimes, which came into force on 9 August 2026, the measures are explicitly aimed first and foremost at the card-to-card transfer market.
3. The monitoring thresholds are concrete. Transfers via mobile apps to one or several cards or wallets reaching 500 BRV over 30 days require special bank attention; with BRV at 412,000 som, that is about 206 million som, or roughly $17,000. Incoming transfers to a single card from 1,000 BRV over 30 days are treated similarly, which is about 412 million som, or roughly $34,000.
4. Internal electronic transfers above 25 BRV must carry sender and recipient data in the same way as international transfers. Banks also pass along full name, address, date of birth, passport details, card number and transaction identifiers, so the chain can be traced from sender to recipient.
5. The blocking side is already live. According to the Ministry of Internal Affairs, in the first half of 2026 authorities prevented the illegal withdrawal of 29 trillion som, or about $2.4 billion, and blocked more than 18,800 suspicious bank cards. The statement does not say which schemes were behind those figures, and it does not name gambling, P2P or mule accounts.

For traders collecting payments through wallets, the point is simple: wallets do not sit outside the perimeter. The 500 BRV rule covers cards and electronic wallets, so moving money through wallets is still part of the monitored flow. HUMO Pay’s 100 million som fee-free cap is also below the 500 BRV threshold, but the bank looks at aggregate patterns over time, not just at the product limit.

The thing is, the economics change again after 31 December 2026. If the zero-fee window ends, the flow that came in because transfers were free will have to reprice itself, and that is usually when volume starts asking awkward questions of the payment stack.