05 · Comparison

EE · MN · KhUR

Estonia's 25-year-old X-tee, Gerege's new X-Road MN, and Mongolia's current KhUR, the state data-exchange system — side by side, row by row. X-Road MN is at an early stage, so we compare design and trust model, not volumes.

FeatureEstonia · X-teeMongolia · X-Road MNMongolia · KhUR
Launched2001-12-172026-07-22 (instance MN)2017 pilot, officially 2018-01
TechnologyX-Road (NIIS, MIT)X-Road 7.8.2 (NIIS, MIT)Open-source-based ESB, built in-house
ArchitectureDistributed, peer-to-peerDistributed, peer-to-peerCentralized hub
OperatorRIAGerege Systems (technical); the management server is owned by the Ministry of Digital DevelopmentNational Data Center
Instance / identifierEE/GOV/…MN/GOV|COM/…—
Member classesGOV · COM · NGOGOV · COM—
Members~1,000 directly connected (1,083 in logs)3 (NDC, Ministry, Gerege)~517 organizations unverified
Traffic~13 million requests a dayTest traffic; no providers registered yet2.67 billion transactions (cumulative, 2024) unverified
ConnectivitymTLS over the internetmTLS over the internetVPN or government network, static IP allowlist
Message signaturesYes, with the organization's keyYes, eID Mongolia organization CANo requirement found
TimestampsYes, RFC 3161Yes, tsa.timeserver.mnNo requirement found
Key exchangePKI, OCSPPKI, OCSP (RFC 6960)PGP, data center access certificate
Legal basisGovernment Regulation No. 105 (2016)None yet — needs a government resolutionOrder A/61 (2016), technical rules A/64 (2022)
FeesThe layer is freeUndecidedPaid (Government Resolution No. 259, 2022)
Data controlStays with the ownerStays with the ownerPasses through the center

KhUR figures come from a 2024 ministry / E-Mongolia Academy presentation slide — which system they describe has not been officially confirmed. Sources give different numbers, anywhere from 462 to 659 organizations. In 2026, preparations began to move KhUR to a "distributed architecture" under the Smart Government II project.

The core argument

Why X-Road, not an ESB

A study from Mato Grosso, Brazil, puts it plainly: earlier integration-bus attempts failed because they required centralizing data, and data owners refused to give up control. X-Road delivered the same result while keeping owners autonomous.

That is Mongolia's situation. Organizations not sharing data is a governance problem, not a technical one — and X-Road solves it through architecture.

ESB · KhUR
  • Data passes through the center
  • If the center goes down, everything stops
  • Evidence lives in the central log
  • Trust based on VPN and IP
X-Road · MN
  • Direct, between the two organizations
  • Exchange continues during a Central Server outage while the global configuration is valid
  • Signed logs on both sides
  • Trust based on certificates

Peer countries

The closest cases to Mongolia

Closest match

Kyrgyzstan · Tunduk

~7 million people, post-Soviet. €500k in total (USAID + Estonian Foreign Ministry), 260 specialists trained. 2018: 363 thousand → 2024: 3.5 billion transactions, 185 organizations. Stalled in 2016–2018 and moved only after the prime minister made it mandatory. The hardest organizations were not the outdated ones but those locked into proprietary contracts.

No vendor

Cambodia · CamDX

Launched 2020-06-15. Deployed in-house from open source. 87 members (32 public, 55 private), 269 services, 117 million transactions (2026-05). Proof that a local team can do it.

Started small

Turkmenistan

Went live 2025-07-28. Nortal, UNDP funding. 10 ministries, 12 services, 75 specialists trained, hosted in-country.

Structural twin

Faroe Islands · Heldin

Samleikin (eID) · Heldin (X-Road) · Vangin (portal). In Mongolia: DAN · KhUR/X-Road · e-Mongolia. All governance terminology was created in the native language.

Law comes first

Iceland · Straumurinn

~3 years from partner to full member. The blockers were not technical but legal: roles and responsibilities. Rule: member servers may not lag the center by more than 2 versions.

Multi-tenant

Ukraine · Trembita (UXP)

Many organizations on one Security Server. For Mongolia, with 1,392 government organizations, the key model for connecting small ones. 573 systems were audited before connecting.

Risks

What makes it fail

Recurring causes across the 13 rollouts studied.

1

Change of government

Amapá (Brazil) halted; Querétaro (Mexico) stalled at 50%. Mongolia's digital ministry has been renamed twice.

2

PKI mismatch

Colombia, Brazil and El Salvador had to change their CAs. For MN, this part is done.

3

Crisis-driven

Quintana Roo started because of COVID and shut down when the crisis ended.

4

Cost–benefit mismatch

Members bear the cost while the state gets the benefit (OECD OPSI). Needs central funding or a multi-tenant model.

Roadmap

Proposed phases

Based on the Turkmenistan model. Cost benchmark: €250k–500k, including PKI. The X-Road software itself is free.

Done

Phase 0 · Foundation

CA gaps (OCSP, TSA, organization profile) closed. KhUR audit and legal analysis remain.

Done

Phase 1 · PoC

Central Server + 2 Security Servers, production CA. Publishing two real services and Mongolian terminology remain.

Next

Phase 2 · Institutionalize

Government resolution, naming the operator (ministry owns, NDC runs), international funding.

Future

Phase 3 · Rollout

Start with 10 organizations and 10–12 services. No big-bang migration. Train specialists.