Kazakhstan

Crypto Licensing

Kazakhstan now operates two parallel licensing channels for digital-asset activity under a single statutory framework. The foundational requirement, set out in Article 11(5) of the Law On Digital Assets, is that organising digital-asset circulation requires a licence or authorisation, obtainable either within the Astana International Financial Centre under the Astana Financial Services Authority, or outside the AIFC under national legislation. Until Law No. 259-VIII of 16 January 2026, the national-legislation route outside the AIFC was not meaningfully operationalised for unsecured digital assets; that law changed this by opening a national licensing channel for exchange operators licensed by the National Bank of Kazakhstan and registered trading-platform operators, with a 20-business-day licence-review process, and with circulation permitted nationally from 1 May 2026.

The AIFC channel continues to function as an active, supervised regime. AFSA's 2026 enforcement record includes a USD 7,000 financial penalty against KBI Partners Limited under Section 118(1)(a) of the Financial Services Framework Regulations, and licence suspensions against Kantai Securities Ltd, effective 28 May 2026, and EA Group Finance LTD, effective 19 March 2026. This enforcement activity confirms the AIFC licensing regime is not merely a nominal framework but an operating supervisory channel capable of imposing penalties and withdrawing authorisation from licensed entities. Commercial commentary describes AIFC Digital Asset Trading Facility licensing as requiring a minimum capital of USD 200,000 and a licensing process spanning six to seven months, though this figure comes from an industry-body secondary source rather than a directly retrieved AFSA capital schedule.

The national channel opened by Law No. 259-VIII presents a different picture: its existence and basic operating parameters, National Bank licensing of exchange operators, registration of trading-platform operators, the 20-business-day review period, and the 1 May 2026 effective date, are documented, but a correspondingly detailed primary-source account of the capital requirements, supervisory reporting obligations, or enforcement mechanisms for this specific national channel has not been retrieved this cycle. This is a gap in available evidence rather than a finding that no such requirements exist; the National Bank may have issued implementing rules that have not yet surfaced in the material reviewed.

Outlook

The key development to watch is publication of, or commercial reporting on, the National Bank's detailed licensing conditions for the national (non-AIFC) exchange and trading-platform channel, since the current record establishes the channel's existence and headline parameters without establishing its full operating requirements. Continued AFSA enforcement activity within the AIFC channel, and any first reported licence grants under the new national channel following its 1 May 2026 effective date, would both be informative markers of how the two parallel regimes are developing relative to one another.

Token Classification

The Law On Digital Assets No.193-VII establishes a clear statutory taxonomy now in force. 'Unsecured digital assets', a category that includes assets such as Bitcoin, are statutorily defined as digital assets that are not digital financial assets, a direct definition drawn from the primary statute text. Digital financial assets (DFAs) are defined by the same law, corroborated by primary NBK communication, to include money-backed stablecoins, tokenized real assets, and digital forms of traditional financial instruments.

This binary classification is the foundation for the differentiated licensing treatment described under crypto_licensing: unsecured digital assets are traded through NBK-licensed exchange operators, while DFAs are traded through NBK-registered trading platforms. The taxonomy therefore carries direct regulatory consequence rather than functioning as a purely definitional exercise, and both defining claims carry Confirmed confidence on the strength of direct primary-source citation.

Outlook

Watch for whether further NBK guidance or implementing rules refine the boundary between the two categories, particularly for hybrid instruments that combine features of both unsecured digital assets and digital financial assets, an area where the current statutory definitions leave interpretive room.

On-Chain Activity Regime

Kazakhstan's on-chain activity regime, which has historically centred on its licensed cryptocurrency-mining sector, was liberalised this cycle through the repeal of a mandatory asset-sale requirement. Previously, Kazakhstan-based miners were required to sell 75% of mined digital assets through AIFC-licensed exchanges, directing the proceeds of domestic mining activity through the AIFC's supervised exchange infrastructure. That requirement was repealed effective 18 January 2026, two days after the signature of Law No. 259-VIII, the same instrument that opened the new national digital-asset exchange licensing channel described under Crypto Licensing above.

The repeal of the 75% mandatory-sale rule does not extend to removing the underlying mining-licensing requirement itself: mining in Kazakhstan continues to operate under a licensed regime, with licences issued for three-year terms. The combined effect is that miners retain a licensing obligation to conduct mining activity at all, but are no longer required to route a fixed majority of their output through AIFC-licensed exchange infrastructure specifically. This is a liberalisation of asset-disposal flexibility for an already-licensed activity, rather than a liberalisation of the licensing requirement for mining itself.

Beyond the mining-specific mandatory-sale repeal, no validator-level, staking-specific, or decentralised-finance-specific regulatory provisions for Kazakhstan have been located this cycle. The available record speaks specifically to mining licensing and the asset-disposal rule change; it does not establish whether or how Kazakhstan's regulatory framework addresses other categories of on-chain activity such as proof-of-stake validation or DeFi protocol participation.

Outlook

The repeal of the mandatory-sale requirement is likely to be read by domestic miners as a significant easing of operational constraints, since it removes a specific requirement to route output through a particular licensed exchange channel while leaving the underlying mining-licensing framework intact. Whether Kazakhstan subsequently issues guidance addressing other on-chain activities, such as staking or DeFi participation, not currently covered in the available record, is the development most likely to extend this module's scope in a future cycle.

Stablecoin Regime

Kazakhstan's stablecoin regime this cycle is best described as a clear policy direction without a correspondingly developed prudential framework. A July 2026 presidential decree authorised the use of stablecoins, alongside other digital assets, in cross-border import and export settlement, operating as a mechanism in parallel with Kazakhstan's conventional banking channels rather than replacing them. This authorisation establishes that stablecoins may lawfully be used for a specific settlement purpose, cross-border trade settlement, but it does not, on the evidence retrieved this cycle, establish a statutory reserve requirement, a redemption-right framework, or an issuance-authorisation regime specific to stablecoin issuers operating in or from Kazakhstan.

This is a genuine regime gap rather than an evidentiary gap alone: the policy-level commencement of stablecoin use via the July 2026 decree is clearly documented, but no binding stablecoin-specific prudential rule, addressing questions such as what backs a stablecoin in circulation, what redemption rights a holder has, or what capital or reserve-reporting obligations a stablecoin issuer faces, has been located. The decree authorises use of stablecoins for a settlement purpose; it does not appear to regulate the stablecoins themselves as a category of financial instrument with issuer-level prudential requirements.

Responsibility for this space appears to sit jointly between the National Bank of Kazakhstan and AFSA, reflecting the same dual-track structure seen in crypto licensing more broadly, a national-level policy authorisation alongside an AIFC-based regulator with its own rulebook. No AIFC-specific stablecoin issuance or reserve rule has been located this cycle either, so the gap applies across both the national and the AIFC tracks of Kazakhstan's regulatory architecture.

Outlook

The central question for this module going forward is whether Kazakhstan follows the July 2026 decree's settlement-use authorisation with a dedicated stablecoin prudential regime addressing reserve backing, redemption rights, and issuer authorisation, or whether stablecoin use continues to operate purely as an authorised settlement mechanism without issuer-level regulation. Until such a regime is located, Kazakhstan's stablecoin framework should be read as permissive at the use-case level but undeveloped at the issuer-regulation level.

Tax Treatment

Kazakhstan introduced a clear and specifically conditioned tax benefit for digital-asset trading income this cycle. The July 2026 presidential decree that authorised stablecoin cross-border settlement was paired with a provision exempting income from personal income tax, provided the trading activity occurs on licensed, domestically regulated platforms. The conditionality is explicit: the exemption attaches to the venue of trading, not to digital-asset trading income generically, meaning income earned through unlicensed or offshore platforms does not appear to benefit from the same tax treatment.

This tax measure is reported in connection with a broader 2026-2028 window intended to encourage holders of previously offshore-held digital assets to migrate those holdings to domestic, licensed providers. Read together, the tax exemption and the migration window describe a coordinated incentive structure: Kazakhstan is using tax policy specifically to channel digital-asset trading activity toward the domestically licensed platforms that fall under either the AIFC regime or the new national licensing channel opened by Law No. 259-VIII, rather than applying a blanket tax exemption regardless of platform.

The practical effect, if the incentive functions as intended, is to make Kazakhstan's licensed domestic trading venues more attractive relative to offshore alternatives for Kazakhstan-resident traders, by removing a tax cost for trading conducted through the domestic licensed route specifically. This is consistent with the broader pattern this cycle of Kazakhstan building out licensed domestic infrastructure, the new national exchange channel, the repealed mandatory-sale rule for miners, and this platform-specific tax exemption, all pointing toward a policy preference for routing digital-asset activity through licensed domestic channels.

Outlook

The indicator to watch is uptake of the tax exemption and the associated 2026-2028 migration window: specifically, whether reporting emerges on the volume of previously offshore-held digital assets actually migrated to domestic licensed providers in response to the tax incentive. The durability of the exemption itself, whether it is treated as a standing feature of Kazakhstan's tax treatment of digital assets or as a time-limited incentive tied to the 2026-2028 window, is also worth monitoring as the window progresses.

Cross-Border Transfer

Kazakhstan's cross-border digital-asset transfer regime was liberalised this cycle through a July 2026 presidential decree authorising digital assets and stablecoins for use in cross-border import and export settlement. This authorisation operates alongside Kazakhstan's conventional banking channels for cross-border payment, meaning the decree adds a new lawful settlement mechanism rather than displacing the existing correspondent-banking-based system for cross-border trade payment.

The decree is reported in connection with a 2026-2028 tax amnesty window applicable to previously offshore-held digital assets that migrate to domestic, licensed providers, discussed in more detail under Tax Treatment above. The cross-border and tax dimensions of this policy package are closely linked: the cross-border settlement authorisation gives licensed domestic platforms a lawful use case for handling cross-border digital-asset flows, while the tax exemption and amnesty window provide the incentive for holders to route those flows through domestic platforms rather than offshore ones.

What is not established in the material retrieved this cycle is the detail of how this cross-border settlement mechanism interacts with conventional cross-border payment controls: no specific reporting threshold, no travel-rule-equivalent requirement for cross-border digital-asset transfers, and no explicit customs or trade-documentation integration point has been located. The decree establishes that the mechanism is lawful; it does not, on the current record, establish the detailed compliance architecture a licensed platform would need to follow when processing a cross-border settlement through this channel.

Outlook

The central open question is whether the National Bank or another competent authority issues implementing rules addressing reporting thresholds, travel-rule-equivalent obligations, or customs-integration requirements for cross-border digital-asset settlement under the July 2026 decree. Evidence of actual cross-border trade transactions settled through this mechanism, as distinct from the existence of the legal authorisation, would be the clearest indicator of whether this channel is being used in practice.