Regulation of Digital Assets in Kazakhstan: Criteria and List of Unsecured Assets Approved

By Order of the Deputy Prime Minister – Minister of Artificial Intelligence and Digital Development of the Republic of Kazakhstan, criteria for classifying a digital asset as a fixed-value unsecured digital asset have been approved, along with a list of such assets. The document comes into force on 13 December 2025.

The approved criteria include

  • The existence of public information on the value of the digital asset relative to one or more national currencies, ensuring the stability of its value;
  • An average daily deviation of the asset's market price not exceeding ±1% over the last 30 calendar days (based on data from coinmarketcap.com or a digital exchange);
  • Disclosure of information about the digital asset, including details on its backing, issuer, and the mechanism for maintaining value stability;
  • Availability of data on the asset's market capitalisation and trading volumes on the coinmarketcap.com website;
  • Absence of court decisions or orders from authorised bodies of the Republic of Kazakhstan against the asset or its issuer concerning the remediation of legislative violations.

Conclusions based on the approved criteria:

  • A formal and verifiable mechanism for classifying fixed-value unsecured digital assets is being introduced, which strengthens market regulation and increases transparency for consumers and investors.
  • The criteria effectively establish standards for market stability, information disclosure, and the issuer's legal compliance, raising the requirements for digital asset market participants.
  • The new norms create clearer legal frameworks for the activities of digital exchanges, issuers, and platform operators, including mandatory monitoring of volatility and market indicators.
  • The approval of a list of unsecured digital assets signifies the emergence of an officially recognised list of assets meeting the established requirements, which may affect their circulation in Kazakhstan.

Recommendations for market participants:

  • Digital asset issuers should conduct an internal audit to assess compliance with the new criteria, particularly regarding value volatility and information disclosure.
  • Digital asset trading platforms are advised to update their compliance procedures, including monitoring market capitalisation, trading activity, and the legal status of issuers.
  • Investors are advised to refer to the new list of assets recognised by the regulator and consider the heightened requirements when dealing with assets not included in the list.
  • Participants in digital asset circulation must ensure the availability of complete and current information about the assets, including the mechanisms for maintaining their value stability.
  • Legal and corporate structures involved in digital asset activities should proactively adapt their internal procedures ahead of the Order's entry into force (13 December 2025).

The REVERA Kazakhstan team is ready to:

  • Analyse digital assets for compliance with the criteria established by the Order and prepare a legal opinion;
  • Assist issuers and platform operators in the process of information disclosure and adjusting mechanisms for maintaining asset value stability;
  • Develop compliance procedures for digital exchanges and operators, including monitoring volatility, market indicators, and legal risks;
  • Advise investors on selecting digital assets included or not included in the official list;
  • Prepare roadmaps for aligning activities with the new regulation entering into force on 13 December 2025;
  • Support interaction with authorised bodies regarding regulatory requirements in the digital asset sphere.

Author: Kissamenov Alisher

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