Corporate Law
Requirements for the State Registration of Commercial Legal Entities Strengthened
As of 1 April 2026, the procedure for the state registration of commercial legal entities, as well as the registration of their branches and representative offices, has changed.
In cases provided for by the registering authority’s internal control rules, state registration is carried out in the personal presence of the founder. A notification requiring personal attendance is sent to the applicant’s personal account on the e-government web portal.
In addition, when an electronic application is submitted for the state registration of a legal entity classified as a private entrepreneurship entity, the entity’s registered address must be confirmed by the consent of the owner or owners of the relevant immovable property.
The accuracy of the stated address is verified automatically through the integration of information systems. The verification includes checking whether the address is recorded in the Address Register information system and determining the category of the relevant property.
Accordingly, as of 1 April, the registration procedure for commercial legal entities includes additional mechanisms for verifying the founder’s identity and the accuracy of the legal entity’s registered address.
Employment Law
Use of Civil Law Contracts Instead of Employment Contracts Restricted
On 7 April 2026, Law of the Republic of Kazakhstan No. 277-VIII “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Improving Safe Working Conditions, Protecting Employees’ Labour Rights and Social Security” was signed.
One of the key changes is a restriction on entering into civil law contracts with individuals where there are indicators of an employment relationship.
Such indicators include, in particular:
- performing work in a specific profession or position;
- personally performing work while being subject to the employer’s internal employment rules;
- receiving remuneration for the work process rather than for a specific end result.
Where such indicators are present, the relationship must be formalised by an employment contract rather than a civil law contract.
The change is aimed at preventing employment relationships from being disguised as civil law arrangements and strengthening safeguards for employees’ labour rights. The law is particularly relevant to sectors where individuals are widely engaged under civil law contracts.
Construction
New Rules for Turnkey Construction Projects Approved
On 15 May 2026, Order No. 235 of the Minister of Industry and Construction of the Republic of Kazakhstan approved the Rules for the Implementation of Turnkey Construction Projects. The Rules entered into force on 1 July 2026.
“Turnkey” construction is defined as a set of construction works covering virtually the entire scope of works performed by the contractor.
The Rules apply to construction projects involving facilities classified as responsibility levels I and II. Where a project involves surveys or the preparation of urban planning documentation, the contractor carries out such work independently or with the involvement of third parties.
One of the key provisions of the Rules is the establishment of an estimated cost for turnkey construction. This is determined at the pre-design stage and used for tender procedures and the execution of contracts. The calculation is based on aggregated construction cost indicators, taking into account the capacity of the facility, the length of linear structures and other technical characteristics and, where necessary, the cost of structural elements and types of work, including on the basis of design and cost estimates for comparable projects.
The cost of works is determined on the basis of the estimated turnkey construction cost, and an increase in the construction cost determined on this basis is not permitted.
The Rules also establish the principal terms of the contract between the customer and the contractor. These include, in particular, the parties’ obligations, the timing and cost of the works, the allocation of risks and liability, quality and safety requirements, procedures for amendments, documentation and reporting, acceptance of the facility, dispute resolution, force majeure and warranties.
The customer is also required to engage a person to provide technical supervision under a contractual arrangement. The engagement of a project manager or technical customer is governed by the Construction Code of the Republic of Kazakhstan.
Accordingly, the new Rules establish a unified procedure for implementing turnkey construction projects and define the scope of works, the procedure for determining costs and the principal terms governing the relationship between the customer and the contractor.
Personal Data
Personal Data Protection Rules Updated
On 22 June 2026, a new version of the Rules for the Implementation by the Owner and/or Operator, as well as a Third Party, of Measures for the Protection of Personal Data was approved. The amendments entered into force on 12 July 2026.
The Rules establish procedures for organising personal data protection, including requirements applicable to owners and operators of information systems that process personal data.
In particular, the Rules distinguish between publicly available personal data and data subject to restricted access. Owners and operators must identify the business processes involving the collection and processing of personal data, determine which individuals have access to such data and approve the relevant internal documents.
For legal entities, the Rules also provide for the appointment of a person responsible for organising the processing of personal data. Their functions include, in particular, internal monitoring of compliance with legal requirements, informing employees about data processing and protection rules, and overseeing the handling of requests from personal data subjects.
Specific requirements apply to personal data subject to restricted access. Among other things, owners and operators must maintain logs of events and user actions, use data integrity controls, secure data transmission channels and cryptographic information protection measures.
The Rules also establish that the collection and processing of restricted-access personal data must be carried out through digital facilities located in Kazakhstan, while such data must be stored in a database located in a server room or data centre in the Republic of Kazakhstan.
In addition, where a personal data security breach occurs, the owner, operator or third party must notify the authorised body within one business day of detecting the breach. For databases containing more than 100,000 records of restricted-access personal data, user identification or authentication measures must be used, including biometric authentication.
Accordingly, the new version of the Rules provides greater detail on organisational and technical measures for personal data protection and introduces additional requirements for companies collecting, processing and storing such data.
Pharmaceuticals
Kazakhstan Plans to Accelerate the Registration of Medicines and Medical Devices
On 25 May 2026, the Ministry of Healthcare of the Republic of Kazakhstan presented draft amendments to the pilot project for the state registration of medicines and medical devices under a “one-stop shop” model. The draft provides for shorter market access timelines for certain categories of products in Kazakhstan.
The proposed changes include accelerated registration mechanisms based on international regulatory practices, including:
- a joint registration procedure for medicines with the World Health Organization under its prequalification programme;
- recognition of decisions by regulatory authorities in countries with stringent regulatory systems, including the United States, the United Kingdom, EU countries, Switzerland, South Korea, Canada, Japan, Australia and others;
- accelerated assessment of medical devices holding internationally recognised quality and safety certificates, including CE marking and documents issued by IMDRF member countries.
For certain medical devices, the assessment period is proposed to be reduced to 15 business days.
The proposed acceleration would not remove mandatory quality, safety and efficacy requirements applicable to medicines and medical devices.
The proposed changes are aimed at reducing administrative barriers and accelerating the introduction of modern medicines and medical technologies to the Kazakhstan market.
Migration
Kazakhstan Plans to Simplify the Recruitment of Highly Qualified Foreign Specialists
Kazakhstan is planning a comprehensive update of its migration legislation aimed at attracting highly qualified foreign specialists, investors and entrepreneurs. The relevant measures are being implemented under a Decree of the President of the Republic of Kazakhstan and initiatives of the Ministry of Labour and Social Protection of the Population.
The draft law provides for new labour migration mechanisms that take into account actual labour market needs. A key innovation will be the establishment of a list of priority occupations approved by the Government and in demand in Kazakhstan’s economy. The list is expected to include specialists in information technology, healthcare, education, culture, energy, the nuclear industry, biotechnology, genomic medicine, water resources and other areas experiencing staff shortages.
At the same time, the Ministry of Labour is working to expand the list of occupations in demand from 51 to 174. The updated list is expected to be approved by a resolution of the Government of the Republic of Kazakhstan.
The draft law is also intended to create more transparent and straightforward conditions for the recruitment of foreign specialists at the invitation of employers. In particular, it provides for further development of the “Altyn Visa” programme. Foreign specialists will be able to apply for long-term resident status (Resident ID) after completing a specified period of employment in Kazakhstan.
The long-term resident status is expected to provide foreign specialists with a number of benefits, including access to tax incentives, financial services, healthcare and education systems, as well as the opportunity to work without quota restrictions.
According to the developers of the draft law, the proposed measures are intended not only to address labour shortages but also to facilitate the transfer of knowledge and expertise to Kazakhstani specialists, increase labour productivity and accelerate technological development. In the long term, Kazakhstan aims to strengthen its position as a regional hub for skilled professionals and high-tech projects.
E-commerce
Kazakhstan Plans to Establish a Legal Framework for E-commerce Operators
On 4 June 2026, the Mazhilis approved at first reading a draft law introducing amendments and additions to the Code of the Republic of Kazakhstan “On Customs Regulation”. The draft is aimed at developing the regulation of e-commerce and aligning Kazakhstan’s legislation with amendments to the Customs Code of the EAEU.
The draft law provides for e-commerce goods to be classified as a separate category and establishes a legal framework for the activities of e-commerce operators.
The proposed framework would require operators to provide logistics for individuals purchasing goods through online marketplaces, as well as to interact with marketplaces and customs authorities on the customs declaration and storage of e-commerce goods.
Accordingly, the proposed amendments establish a separate legal framework for participants in the e-commerce infrastructure and provide for the further development of specific rules governing the movement of e-commerce goods across the EAEU customs border.
Currency Regulation
Controls over Currency Transactions Strengthened
On 31 March 2026, the National Bank of the Republic of Kazakhstan approved new Rules for Currency Transactions. The Rules entered into force on 19 April 2026 and establish an updated procedure for conducting currency transactions, purchasing and selling foreign currency, as well as carrying out currency control and reporting.
Under the new Rules, requirements applicable to banks and professional participants in the financial market acting as currency control agents have been strengthened. They are required to verify client documents, monitor transactions indicating potential violations and notify the National Bank of identified violations.
For legal entities, a currency control threshold of USD 50,000 has been established. Transactions falling within the applicable criteria are included in bank reporting.
Certain currency transactions also require a currency contract registration number. When processing a transaction, a bank may request documents confirming its economic substance and compliance with the information provided.
Specific requirements apply to the purchase of foreign currency by legal entities. In particular, the purpose of the purchase must be stated and, where required, supported by relevant documents. In cases specified by the Rules, unused foreign currency must be sold back within three days.
Additional controls apply to transactions that may involve capital outflows, including certain cross-border transfers exceeding USD 50,000, loans providing for funds not to be returned to Kazakhstan, transactions with no apparent economic substance and certain long-term foreign trade contracts.
Accordingly, the new Rules strengthen documentary requirements for currency transactions and expand the tools available to banks for currency control when companies make cross-border payments.
Judicial System and Enforcement Proceedings
Controls over Enforcement Proceedings and Private Bailiffs Strengthened
On 24 June 2026, the Head of State signed the Law of the Republic of Kazakhstan “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Improving Enforcement Proceedings”.
The Law is aimed at improving the effectiveness of enforcement of court and other enforceable documents, strengthening the protection of the rights of participants in enforcement proceedings and increasing the accountability of private bailiffs.
One of the key changes is an increase in the threshold for applying simplified enforcement proceedings from 20 to 40 monthly calculation indices (MCI). This expands the range of claims that may be enforced under the simplified procedure.
The Law also introduces the automatic cancellation of enforcement measures under enforcement documents where the period for their presentation has expired. Such measures will be cancelled without the involvement of a private bailiff.
The Law strengthens oversight of private bailiffs. In particular:
- mandatory certification of serving private bailiffs is introduced, including verification of their knowledge of legislation and professional ethics;
- the authorised body is granted powers to revoke a private bailiff’s licence in cases provided for by law;
- territorial justice authorities will be able to issue notices to private bailiffs requiring identified violations to be remedied;
- a mandatory pre-trial procedure for challenging the actions and decisions of bailiffs is introduced, changing the procedure for protecting the rights of participants in enforcement proceedings.
Accordingly, the amendments both simplify certain debt enforcement procedures and strengthen state oversight of bailiffs, which is relevant to both creditors and debtors involved in enforcement proceedings.
Online Platforms and Digital Law
Rules for Digital Data Exchange Platforms Established
On 30 April 2026, the Rules for the Operation of Platforms for the Exchange and Circulation of Digital Data Products were approved. The Rules entered into force on 12 July 2026 and establish requirements for the operation of such platforms, as well as the rights and obligations of their participants.
A platform is defined as a digital system through which users can access and exchange digital data products. It must contain a list of the products made available, their terms of use and exchange, metadata for each product, mechanisms for concluding and recording transactions, an operations log and different levels of access, including the ability to use APIs.
Digital data products placed on a platform must be processed and structured and must not contain personal data that enables an individual to be identified. The placement of unprocessed (“raw”) data and the transfer of products to third parties without the rights holder’s consent are not permitted.
Platform owners must protect data against unauthorised access and leaks, comply with personal data and cybersecurity legislation, and take into account applicable restrictions on the cross-border transfer and storage of data.
The Rules identify three categories of platform participants: platform owners, suppliers and consumers of digital data products. Suppliers are responsible for the accuracy, completeness and currency of the data and metadata they provide, while consumers must use the data lawfully and comply with the applicable terms of use.
Platform owners are responsible for monitoring compliance of the data placed on the platform with the applicable requirements, ensuring transparency of access procedures, publishing the rules and pricing of products, recording and retaining transaction information and, where necessary, suspending or removing inaccurate data.
Access to the platform is granted following identification using an electronic digital signature (EDS) or two-factor authentication. The authorised body maintains a register of platforms and monitors their activities. Platform owners are also required to notify the authorities when a platform is launched or ceases operations.
Accordingly, the Rules establish a separate regulatory framework for the exchange and circulation of digital data products, setting requirements for their content, quality, security, access and transaction records.
