ESUTD: What Employers Will Be Fined For and How — Effective from 12 March 2026 05.03.2026
From 12 March 2026, Kazakhstan will bring into force provisions on administrative liability for violations connected with the use of the Unified System for Recording Employment Contracts (ESUTD).
ESUTD is a state information system in which employers are required to register information on the conclusion, amendment, and termination of employment contracts. Whereas previously oversight was predominantly formal, from March 2026 violations will result in actual fines.
What liability is provided for
Administrative liability will be applied to employers for the following ESUTD-related violations:
- failure to submit information on the conclusion, amendment, or termination of an employment contract;
- late entry of information into the ESUTD;
- entry of inaccurate or incomplete data;
- breach of the procedure for keeping records of employment contracts.
| Fines are set in MRP and vary depending on the business category (small, medium, large). For repeat violations, the sanctions increase. The amount of fines ranges from 30 MRP to 200 MRP. |
Why this matters for business
In practice, the ESUTD has become an instrument of digital oversight of employment relations. State authorities gain the ability to cross-check:
- information on employment contracts,
- data on pension and social contributions,
- tax reporting,
- employees’ migration status.
| This means that any discrepancies will be identified automatically. |
As a result, the risk of detecting violations increases significantly even without conducting an on-site inspection.
Particularly vulnerable are:
- companies with high staff turnover;
- employers using flexible forms of employment;
- businesses working with foreign employees;
- companies with a decentralised HR function.
Practical takeaways
- A formal approach to registering employment contracts is no longer safe.
- Late entry of amendments (for example, changes to salary, position, or working regime) also creates a risk of a fine.
- ESUTD violations may serve as grounds for a more in-depth inspection by the labour inspectorate.
- Discrepancies may create risks in relation to taxes and social contributions.
Recommendations for employers: what should be done before 12 March 2026
Before liability takes effect, employers should carry out a preventive review of their processes.
- Audit all current employment contracts;
- check the accuracy and completeness of the information entered in the ESUTD;
- check that terminated contracts have been registered in a timely manner;
- appoint a responsible person to administer the system;
- update internal HR policies and procedures;
- train HR personnel to work with the ESUTD.
How REVERA Kazakhstan can help
We can provide comprehensive support to employers:
- conduct a legal audit of HR documentation and the data in the ESUTD;
- identify administrative liability risks;
- develop internal procedures for maintaining employment contracts;
- support the remediation of violations and correction of information;
- represent the employer’s interests during labour inspectorate inspections;
- advise on labour law matters and interaction with state authorities.
In the context of intensified digital oversight, employment-related risks become transparent to the state. A proactive review and adjustment of processes will help avoid fines and reduce regulatory risks.
Author: Alisher Kissamenov.
If you would like to assess the risks for your company or conduct an express audit before 12 March 2026, contact us: kazakhstan@revera.legal
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