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title: "Kazakhstan Crypto Regulation Monitor | cryptoassets.gi"
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source_html: /jurisdictions/kazakhstan/index.html
description: "Kazakhstan crypto asset regulation: 9 categories, 46 sourced findings, updated 2026-11-04. Licensing, token classification, stablecoins, tax treatment."
generated_at: 2026-11-07T14:19:44Z
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# Kazakhstan Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/kazakhstan/)

Last updated 2026-11-04 · 9 categories · 46 sourced
findings · 50 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-11-04 · Position last changed: 2026-11-04 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot ↗](/reports/?type=copilot&j=KAZAKHSTAN)[Build Report](/reports/?j=KAZAKHSTAN)[Compare](/compare/?j=KAZAKHSTAN)

Framework posture Regulated 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority The Block Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2026-Q4 AIFC sectoral digital-asset risk assessment due under Resolution 934

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

9 Categories

0 Moved this cycle 0 Key judgments 3 Open gaps 46 Findings

0 Tier-1 sources

Confidence mix 9 unpopulated
(sums to 9 rendered categories; click to filter)

No categories moved this cycle.

## Jurisdiction lead brief

###### Latest update · 4 November 2026

#### Lead Signal

Kazakhstan's crypto-licensing perimeter tightened visibly in the second half of October 2026. The AIFC Court issued injunctions on 15 September 2026 against six platforms operating without authorisation within the Astana International Financial Centre, Coinbase, HTX, BingX, Bitcoin.com, BitMart and WEEX, with enforcement reported on 20-21 October directing Apple and Google to restrict the relevant apps inside Kazakhstan. The Astana Financial Services Authority's chief executive described this as a continuation of a track that began in 2025 with written warnings sent to more than twenty platforms, rather than a new enforcement posture. Set against that, the regulator granted in-principle approval around 28 October 2026 to Kraken, through its local entity Payward Kazakhstan, to launch a trading platform and hold client digital assets inside the AIFC, though trading remains unavailable pending a final licence and the review sits at an early phase. The two developments together describe a regulator simultaneously closing the door on unlicensed offshore access and opening it, carefully, to exchanges willing to seek authorisation.

#### Other Developments

Outside the AIFC, Kazakhstan's National Bank licensing requirement for unsecured-digital-asset exchange operators, in force since 1 May 2026 under Law No. 193-VII as amended, remains unchanged and unaffected by the AIFC-specific enforcement activity. The underlying classification framework also continues as before: fiat-backed stablecoins are treated as a type of digital financial asset, distinct from unsecured digital assets such as Bitcoin, which are not recognised as a means of payment, financial instrument or financial asset. The National Bank's regulatory sandbox, which as of September 2026 reportedly hosted 34 projects across 14 areas including stablecoins and tokenization, continues under development, though the evidence base for this figure remains thin and is treated as provisional.

#### Cross-Monitor Connections

The AFSA enforcement action and its accompanying consumer guidance, that an international exchange's reputation does not by itself confirm Kazakhstan authorisation, and that customers should verify a platform's status in the AFSA register before using it, touches consumer-facing protections that sit adjacent to the licensing question but were not separately developed. No material connection to gambling-sector payment or AML developments was evidenced in this pass.

#### Outlook

The near-term signal to watch is whether Kraken's in-principle approval converts into a final AIFC trading licence, which would mark the first major international exchange to complete the authorisation Kazakhstan's regulator is visibly trying to channel unlicensed platforms toward. Equally relevant is whether the six platforms named in the AIFC Court injunctions comply with the app-store restriction order, or whether further enforcement escalation follows. Confirmation of either development from a primary AFSA or National Bank publication, rather than secondary press reporting, would materially strengthen the evidentiary basis for both threads.

5 earlier updates not shown here.

###### Standing brief · as of 25 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Kazakhstan's digital-asset regime has completed its transition from a registration-based system to a formal licensing model under Law No. 193-VII LRK, in force since 1 May 2026. Operators of unsecured digital-asset exchange platforms outside the Astana International Financial Centre must now obtain a licence from the National Bank of Kazakhstan, a high-confidence requirement drawn directly from a National Bank notice and corroborated by secondary legal-advisory reporting on the underlying legislative shift. This is the most structurally significant development in Kazakhstan's crypto framework this cycle: it converts what was previously a lighter-touch registration obligation into a full licensing gate, with the National Bank as supervisory authority for the onshore, non-AIFC market. This shift also formalises the AIFC's position as the jurisdiction's parallel, distinctly regulated channel: activity conducted through AIFC-licensed platforms sits outside the National Bank's direct onshore licensing perimeter, creating a two-track structure — a National-Bank-licensed onshore market and an AIFC-licensed financial-centre market — that recurs across several of this cycle's other findings.

#### Other Developments

Token classification has been formalised alongside licensing: the same legislative package distinguishes digital financial assets, including money-backed stablecoins, from unsecured digital assets, while unsecured cryptoassets remain generally prohibited in circulation outside the AIFC's carve-out. The classification also matters for cross-border purposes, since digital financial assets and unsecured digital assets are treated differently under the AIFC-channelling quota that governs cross-border transfer.

Mining has been formalised as a licensed corporate activity. New legislation, administered by the Ministry of Artificial Intelligence and Digital Development, requires miners owning physical mining-centre infrastructure and miners using third-party hosted equipment to each obtain a distinct type of three-year digital mining licence. The three-year term signals a fixed-cycle renewal model rather than a perpetual licence, though renewal conditions were not detailed in the reporting reviewed this cycle. DeFi-lending and staking-specific rules remain comparatively thin, an under-researched vector flagged in the gaps register.

Stablecoin policy is in active build-out. A July 2026 presidential decree directs the National Bank and the Ministry of Artificial Intelligence and Digital Development to build cross-border stablecoin settlement mechanisms, though the primary decree text has not yet been retrieved. The Astana Financial Services Authority has separately piloted USD-pegged stablecoin acceptance for AIFC regulatory-fee payments, implying a de facto reserve or redemption expectation for accepted stablecoins under AIFC rules, though this remains an inference from a fee-payment pilot rather than a codified reserve rule.

Tax treatment is directionally favourable but not yet codified in detail. The same July 2026 decree introduces crypto income-tax exemptions as part of a broader digital-asset adoption package; the specific rate and base have not been retrieved this cycle.

Cross-border transfer remains gated through a binding AIFC-channelling quota. A rising mandated percentage of crypto sold via exchanges — 50 percent in 2024, 75 percent in 2025 — must route through AIFC-licensed platforms, a high-confidence, binding requirement under Law No. 193-VII LRK. The current post-2025 percentage has not been confirmed beyond the last-known 75 percent step. Separately, cross-border stablecoin settlement mechanisms with China, Russia and Turkey remain at a planning or decree stage and are not yet operative.

#### Cross-Monitor Connections

The AIFC-channelling quota and the National Bank's licensing perimeter both carry direct relevance for world-payments' coverage of Kazakhstan's digital-asset-linked payment products, including the cryptocard project and AFSA/Bybit stablecoin-fee pilot tracked on that monitor. The stablecoin-regime build-out and the mining-licence formalisation also carry AML/CFT-adjacent implications that are financial-integrity monitor territory (modules D7 and D5) and are not re-analysed here.

#### Outlook

The clearest verification priority for next cycle is the July 2026 presidential decree's primary Adilet.zan.kz text, which underlies both the stablecoin cross-border-settlement directive and the tax-exemption signal. Watch also for confirmation of the AIFC-channelling quota's current percentage beyond the last-known 75 percent step, and for whether a comprehensive DeFi-lending or staking rule set emerges to close this cycle's identified gap. More broadly, the two-track AIFC/onshore structure that recurs across licensing, classification, and cross-border transfer this cycle suggests Kazakhstan's digital-asset framework is maturing around a deliberate segmentation rather than a single unified regime.

Read full brief · 1138 words

Key regulatory facts for Kazakhstan Regulatory Dimension Kazakhstan Standing Position

Jurisdiction Kazakhstan (KZ)

Regulatory Scope Crypto & Digital Asset Regulation (9 modules, 46 sourced findings)

Crypto Licensing Kazakhstan operates a dual-track crypto licensing perimeter.

Token Classification Kazakh law draws a binary statutory distinction between 'secured' digital assets (backed by an underlying asset/issuer obligation) and 'unsecured' digital assets (e.g., typical cryptocurrencies such as BTC), the...

On-Chain Activity Regime Mining is by far the most heavily regulated on-chain activity in Kazakhstan given the country's historical role as a major Bitcoin hash-rate hub.

Stablecoin Regime National Bank rules approved under the Digital Assets Law set requirements for stablecoin (money-backed DFA) issuers, the stablecoin issuance decision, and stablecoin investors, including qualified-investor gating...

Primary Instruments Cited The Block, CoinDesk, CoinDesk, CoinDesk, AIFC Court / AFSA

Last Confirmed / Updated 2026-11-04 (50 sources in cumulative register)

9 of 9 categories

Signal
Moved
Judgment
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Selections OR within a group, AND across groups. Press / to search.

### Kazakhstan: C1 Crypto LicensingAmberEnacted in forceModule confidence: Probable▾

Kazakhstan operates a dual-track crypto licensing perimeter. Outside the AIFC, the National Bank licenses unsecured-digital-asset exchange operators and registers DFA/trading-platform operators under the Law 'On Digital Assets', in force nationally from 1 May 2026. Within the AIFC's separate common-law jurisdiction, AFSA licenses crypto-asset service providers under the AIFC Financial Services Framework Regulations.

Open gap — crypto-int-1 No Tier-1 (AFSA/National Bank primary) source directly retrieved this pass for crypto_licensing, token_classification or consumer_protection findings. no under-indexing note recorded

Open gap — crypto-int-2 AFSA's own primary-source list of nine voluntarily-exited and seven licence-seeking platforms not retrieved this cycle. tax_treatment is a structurally thin-evidence module across the crypto estate.

Horizon · 2026-Q4 (± six months) AIFC sectoral digital-asset risk assessment due under Resolution 934 Adopted, not yet in force

Horizon · 2026-Q4 (± a quarter) National Bank/ARDFM draft DFA-issuance resolution consultation Consultation · Tier 3 source

#### Crypto Licensing

Kazakhstan has moved decisively from a registration-based to a formal licensing model for digital assets. Operators of unsecured digital-asset exchange platforms outside the Astana International Financial Centre must obtain a licence from the National Bank of Kazakhstan, a high-confidence, Tier-1-sourced requirement in force since 1 May 2026. The prior registration-based system for crypto exchanges has been replaced by this formal licensing model, per Tier-4 secondary legal-advisory reporting corroborating the National Bank's own announcement. The result is a comprehensive, in-force licensing framework supervised by the National Bank, with the AIFC continuing to operate as a parallel, distinctly licensed channel outside the National Bank's direct onshore licensing perimeter.

#### Outlook

Watch for licence-application volumes under the new regime and for any clarification of how the AIFC and onshore National Bank licensing perimeters interact for platforms seeking to operate across both channels.

Read full sub-brief · 140 words Periodic update · new data 2026-10-25

#### Crypto Licensing

Kazakhstan operates two parallel crypto-licensing perimeters. Within the Astana International Financial Centre, a digital-asset business must obtain an authorisation from the Astana Financial Services Authority before offering exchange, brokerage or custody services. Outside the AIFC, the applicable requirement is licensing or registration with the National Bank of Kazakhstan under the Law on Digital Assets. This dual-track structure means that a platform's compliance posture depends materially on which perimeter it operates in, and a licence or authorisation valid in one perimeter does not extend automatically to the other.

The AIFC Court issued injunctions dated 15 September 2026, disclosed 20 October 2026, against six global exchanges, Coinbase, HTX, BingX, Bitcoin.com, BitMart and WEEX, barring them from providing unlicensed digital-asset services within the AIFC's legal perimeter. The Astana Financial Services Authority obtained these orders, and critically, the restraint applies only within the AIFC's own legal perimeter and does not extend to the rest of Kazakhstan, underscoring the practical reality that the two licensing tracks are legally distinct rather than a single national system. The episode is reported through multiple trade-press sources rather than a located AFSA primary release, and whether the injunctions have produced a published court judgment or any further penalty beyond the injunction itself has not been verified.

#### Outlook

The principal matter to watch is whether AFSA or the AIFC Court publishes primary documentation of the injunctions, which would move the finding from probable to confirmed and would clarify whether any penalty beyond the injunction itself has been or will be imposed. More broadly, the dual-perimeter structure itself is a standing feature of the regime rather than a transitional one, so any platform assessing Kazakhstan exposure needs to separately evaluate its AIFC-facing and non-AIFC-facing activity against the two distinct licensing tracks.

3 earlier distinct update(s) Periodic update · new data 2026-10-18

#### 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.

Periodic update · new data 2026-09-28

#### Crypto Licensing

Kazakhstan's crypto-licensing landscape is now defined by two parallel, non-overlapping regulatory perimeters. Outside the Astana International Financial Centre, the National Bank of Kazakhstan's licensing regime entered force on 1 May 2026 under the Law of the Republic of Kazakhstan 'On Digital Assets in the Republic of Kazakhstan' (No. 193-VII LRK). Under this regime, crypto exchange operators must obtain an NBK licence, while digital-asset trading platforms and DFA (digital financial asset) platform operators must complete NBK registration — a lighter-touch pathway than full licensure, reserved for platform-type activity rather than exchange operation. This is a confirmed, primary-sourced development directly from the National Bank's own press release, and it represents the most significant single change to Kazakhstan's crypto-licensing posture in this cycle.

Within the AIFC, a separate and pre-existing regime continues to apply. The Astana Financial Services Authority introduced amendments to its capital-market, digital-asset and crowdfunding frameworks effective 1 January 2026, updating the unified DASP (Digital Asset Service Provider) licensing framework under the AFSA Rules on Digital Asset Activities. This AIFC-based regime has operated independently of the national framework and continues to be Kazakhstan's more mature, internationally-oriented digital-asset supervisory track, built around the AIFC's separate common-law jurisdiction carved out from the rest of Kazakhstan's civil-law system.

A third and lower-confidence element concerns crypto mining. Secondary industry-body commentary reports that cryptocurrency mining operators must register as corporate entities with the Ministry of Digital Development and Innovation. This requirement has not been independently corroborated against a primary regulator page this cycle, and should be treated as a probable, standing feature of the regime rather than a confirmed one.

Taken together, these three strands describe a regime that has moved from largely AIFC-centric to genuinely national in scope as of May 2026, while leaving the AIFC's own regulatory track intact and running in parallel. The practical effect for a market entrant is that the choice of where to locate — mainland Kazakhstan under NBK supervision, or within the AIFC under AFSA supervision — now carries materially different licensing pathways, obligations and, potentially, different degrees of regulatory maturity, since the national regime has only just entered force and lacks any operational track record, while the AIFC regime has been operating and iterating since at least January 2024.

#### Outlook

A sectoral digital-asset risk assessment mandated under Government Resolution 934 is expected around Q4 2026 (half-year uncertainty band), and is likely to be the next significant data point on how the national NBK regime and the AIFC/AFSA regime are meant to interact, and on how AML/CFT countermeasures for crypto-related laundering typologies will be layered across both perimeters. Given the national regime's newness, expect continued clarification of registration versus licensing thresholds for platform operators, and possible primary-source confirmation or correction of the mining-registration requirement, which currently rests on a single secondary source.

Periodic update · new data 2026-09-14

#### Crypto Licensing

Kazakhstan's crypto-licensing framework transitioned to a comprehensive, in-force national regime on 1 May 2026. Outside the AIFC, unsecured-digital-asset exchange operators must obtain a National Bank of Kazakhstan licence, confirmed by primary NBK communication. Separately, DFA trading-platform operators must complete an NBK registration procedure under the same Digital Assets Law implementation, corroborated by both a T1 and a T3 source. This dual licensing/registration structure distinguishes exchange operators (licensed) from DFA trading platforms (registered), a meaningful distinction for any firm assessing its own regulatory obligations depending on which category its activity falls into.

Within the AIFC's separate legal jurisdiction, crypto-asset service providers continue to be licensed by AFSA under the AIFC Financial Services Framework Regulations, a parallel channel to the national NBK regime. This claim is model-asserted and has not been independently re-verified against AFSA's own site this cycle, a gap explicitly flagged in the underlying research; the existence of AFSA's separate licensing authority within the AIFC is a long-standing structural feature, but the current operational detail of that regime carries lower confidence than the national NBK action.

The overall effect of this cycle's development is that Kazakhstan's prior regulatory gap for exchange-type crypto-asset activity conducted outside the AIFC has now closed. A firm previously operating in a grey zone outside the AIFC is now required to either obtain an NBK licence (if operating as an exchange) or complete NBK registration (if operating as a DFA trading platform).

#### Outlook

Watch for AFSA guidance responding to the national Digital Assets Law's implementation, and for independent re-verification of the AIFC parallel-channel claim against AFSA's own publications. The dual-track licensing structure itself is a stable, durable feature expected to persist absent a coordination or harmonisation initiative between the NBK and AFSA.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (15)
- T4[The Block](https://www.theblock.co/post/261967/kazakhstan-government-blocks-coinbase) — The issuance, circulation, and offering/trading of unsecured digital assets via crypto exchanges is prohibited in Kazakhstan outside the territory of the Astana International Financial Centre (AIFC).
- T3[CoinDesk](https://www.coindesk.com/policy/2022/10/06/crypto-exchange-binance-receives-license-to-operate-in-kazakhstan) — Crypto exchanges and custody providers operating within the AIFC (e.g. Binance, Upbit, Bybit) must obtain a license/work permit from the Astana Financial Services Authority (AFSA) to operate as a regulated digital asset trading platform and custody provider.
- T3[CoinDesk](https://www.coindesk.com/policy/2022/12/19/kazakhstan-tightens-regulation-for-miners-looks-to-develop-broader-crypto-industry) — Crypto miners must be licensed/registered, with two distinct licensing categories depending on whether they own and operate their own mining infrastructure or host mining equipment in a third-party facility.
- T3[CoinDesk](https://www.coindesk.com/policy/2021/11/05/kazakhstan-passes-law-to-monitor-crypto-services-for-money-laundering-terrorism-financing) — Companies issuing digital assets or providing fiat on-ramp/crypto trading services must notify Kazakhstan's Ministry of Digital Development, Innovation and Aerospace Industry (MDDIAI) upon launching or shutting down such services, as part of the 2021 financial-monitoring law.
- T2 · Cryptonomist[AIFC Court / AFSA](https://en.cryptonomist.ch/2026/10/20/kazakhstan-crypto-injunction/) — Injunctions (15 Sep 2026, enforcement reported 20-21 Oct 2026) restricting six crypto platforms (Coinbase, HTX, BingX, Bitcoin.com, BitMart, WEEX) from unlicensed digital-asset services within the AIFC; Apple/Google directed to restrict apps inside Kazakhstan.
- T2[Astana Financial Services Authority (AFSA)](https://timesca.com/kazakhstan-kraken-cryptocurrency-approval/) — Kraken, via Payward Kazakhstan, received AFSA in-principle approval around 28 October 2026 to launch a trading platform and hold client digital assets in the AIFC; trading not yet available pending final licence.
- T3[AIFC Court / AFSA](https://en.cryptonomist.ch/2026/10/20/kazakhstan-crypto-injunction/) — AIFC Court injunctions dated 15 September 2026, obtained by AFSA, bar Coinbase, HTX, BingX, Bitcoin.com, BitMart and WEEX from providing unlicensed digital-asset services within the AIFC's legal perimeter; the restraints do not extend to the rest of Kazakhstan.
- T3 · Uppersetup[National Bank of Kazakhstan](https://uppersetup.com/en/blog/digital-assets-and-mining-in-kazakhstan-2026-national-bank) — Outside the AIFC, operating as an unsecured-digital-asset exchange operator without a National Bank licence has been prohibited since 1 May 2026; trading-platform and digital-financial-asset-platform operators must register with the National Bank.
- T3 · Cryptonomist[Astana Financial Services Authority / National Bank of Kazakhstan](https://gofaizen-sherle.com/crypto-license/kazakhstan) — Within the AIFC, a digital-asset business authorisation from AFSA is required before offering exchange, brokerage or custody services; outside the AIFC, licensing/registration with the National Bank is required under the Law on Digital Assets.
- T2 · Cryptonomist[AIFC Court](https://en.cryptonomist.ch/2026/10/20/kazakhstan-crypto-injunction/) — in_force
- T2[Kraken (Payward Kazakhstan)](https://timesca.com/kazakhstan-kraken-cryptocurrency-approval/) — proposed
- T3 · Uppersetup[National Bank of Kazakhstan](https://uppersetup.com/en/blog/digital-assets-and-mining-in-kazakhstan-2026-national-bank) — in_force
- T3[Law No. 259-VIII of 16 January 2026](https://uppersetup.com/en/blog/digital-assets-and-mining-in-kazakhstan-2026-national-bank) — National (non-AIFC) unsecured digital-asset circulation via National Bank-licensed exchange operators and registered trading-platform operators, 20-business-day review, effective for circulation from 1 May 2026
- T1[AFSA / Law 'On Digital Assets'](https://aifc.kz/news/afsa-warning-on-unlicensed-digital-asset-platforms/) — A licence or authorisation to organise digital-asset circulation, within the AIFC under AFSA or outside it under national legislation
- T1[AFSA](https://afsa.aifc.kz/supervision/enforcement/regulatory-actions/) — Multiple enforcement actions against AIFC-registered entities in 2026, including a USD 7,000 fine on KBI Partners Limited under FSFR Section 118(1)(a), and licence suspensions (Kantai Securities Ltd, 28 May 2026; EA Group Finance LTD, 19 March 2026)

### Kazakhstan: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable▾

Kazakh law draws a binary statutory distinction between 'secured' digital assets (backed by an underlying asset/issuer obligation) and 'unsecured' digital assets (e.g., typical cryptocurrencies such as BTC), the latter being subject to the AIFC-only circulation restriction. Within the AIFC, AFSA additionally operates a criteria-based token approval ('green list') process determining which digital assets may be traded on licensed exchanges. No formal MiCA-style multi-category taxonomy (security/e-money/asset-referenced/utility token) has been identified in available reporting.

Periodic update · new data 2026-09-14

#### 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.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-11-04

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### Kazakhstan: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾

Mining is by far the most heavily regulated on-chain activity in Kazakhstan given the country's historical role as a major Bitcoin hash-rate hub. Miners are licensed, taxed on a sliding per-kWh electricity-consumption scale, restricted to drawing grid power only during surplus periods via the state operator KOREM, and (per 2023 amendments) obliged to sell an increasing share of mined coins through AIFC-licensed exchanges. Staking, DeFi lending, DEX, node operation, validator, and tokenization activities have no dedicated statutory regime identified in current reporting.

Periodic update · new data 2026-10-18

#### 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.

Periodic update · new data 2026-09-14

#### On-Chain Activity Regime

Kazakhstan's on-chain activity regime, particularly as it concerns mining, moved in a liberalising direction this cycle, a notable divergence from the broader tightening trend elsewhere in the country's crypto framework. Earlier rules had required miners to sell coins only through AIFC-registered platforms, restricting miners' disposal options to a single regulated channel. A November 2025 law eased several mining and trading limits, including this platform restriction, according to a single lower-tier source.

This development carries Probable confidence and has not been independently re-confirmed against a primary NBK mining circular this cycle, a gap explicitly noted in the underlying research. The direction of the change, however, is consistent with Kazakhstan's status as a significant Bitcoin-mining jurisdiction with an interest in supporting rather than constraining domestic mining activity, even as it simultaneously tightens exchange-level licensing and DFA-platform registration elsewhere in the same statutory framework.

#### Outlook

Watch for primary-source confirmation of the November 2025 mining-liberalisation measures via an NBK circular or equivalent instrument, since the current evidentiary basis rests on a single T4 source. Watch also for whether further mining-specific rules are introduced as a complement to the broader Digital Assets Law implementation that took effect in May 2026.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-11-04

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### Kazakhstan: C4 Stablecoin RegimeRedEnacted in forceModule confidence: Probable▾

National Bank rules approved under the Digital Assets Law set requirements for stablecoin (money-backed DFA) issuers, the stablecoin issuance decision, and stablecoin investors, including qualified-investor gating for certain DFA classes.

Horizon · 2026-Q4 (± six months) July 2026 decree stablecoin/tokenization mechanisms build-out Adopted · Tier 3 source

Periodic update · new data 2026-10-25

#### Stablecoin Regime

Kazakhstan's stablecoin framework rests on digital-financial-asset rules issued by the National Bank, effective 1 May 2026, which recognise money-backed stablecoins, tokenised real assets, and digital forms of traditional financial instruments as a distinct category of "digital financial asset," separate from unsecured digital assets such as most cryptocurrencies. This classification test gives the regime a statutory basis for distinguishing asset-backed instruments from the broader unsecured digital-asset category, though the precise legal test has not been independently verified against primary statutory text.

Against that backdrop, Tether, the National Bank of Kazakhstan, and the Alatau City Authority signed an exploratory memorandum of understanding on 7 October 2026 to study the development of a tenge-pegged stablecoin and an asset-tokenisation pilot. The memorandum is explicitly non-binding and preliminary: it sets no launch date, no identified issuer, no blockchain platform and no reserve structure. A National Bank deputy governor characterised the exercise as studying international best practice in stablecoin issuance and real-world-asset tokenisation, language consistent with an exploratory rather than committed undertaking. The arrangement should therefore be read as an early-stage signal of interest in a sovereign-adjacent stablecoin structure rather than a confirmed regulatory or commercial commitment.

#### Outlook

The stablecoin track in Kazakhstan currently has an active legal classification framework in place since 1 May 2026, but no committed pilot structure: the Tether-NBK-Alatau MoU is the only concrete signal of forward movement, and it remains confined to a study phase. The next material development to watch is any announcement that moves the arrangement beyond exploration toward a defined issuer, reserve model or launch timetable, which would for the first time test how the existing digital-financial-asset classification rules apply in practice to a named pilot.

Periodic update · new data 2026-10-18

#### 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.

Periodic update · new data 2026-10-11

#### Stablecoin Regime

Kazakhstan's stablecoin regime rests on a confirmed statutory and supervisory foundation that was supplemented, not altered, this cycle. The National Bank of the Republic of Kazakhstan regulates stablecoin circulation directly, while the Agency for Regulation and Development of the Financial Market regulates other digital financial assets; this supervisory split remains unchanged. This cycle's material development is a non-binding memorandum of understanding, signed 7 October 2026, between Tether, the National Bank of the Republic of Kazakhstan and the Alatau City Authority, to study a tenge-pegged stablecoin pilot and a tokenisation framework. The agreement does not authorise issuance of any stablecoin and sets no launch date or reserve design; it is a study-phase commitment only. Separately, the National Bank and ARDFM published a draft joint resolution, opened for consultation on 9 October 2026, setting requirements for domestic financial organisations, residents and AIFC participants seeking to issue digital financial assets through a platform operator; this draft has not been adopted. Reserve-asset and redemption-right requirements specifically applicable to KZ-regulated stablecoin issuers were not located in primary National Bank text this cycle, which remains a standing research gap rather than an indication that no such rules exist.

#### Outlook

The draft DFA-issuance resolution's path through consultation, expected to develop further within the fourth quarter of 2026, is the clearest near-term marker for Kazakhstan's stablecoin regime. Whether the Tether exploration MoU progresses from its current study phase toward a concrete tenge-pegged stablecoin product, and whether reserve-asset and redemption-right rules are published alongside any such product, remain the two open questions most relevant to assessing regime maturity.

Periodic update · new data 2026-09-14

#### Stablecoin Regime

Kazakhstan now has a dedicated, in-force implementing-rules instrument for stablecoin activity. National Bank rules, effective 31 July 2026, set requirements for stablecoin issuers, govern the stablecoin issuance decision process, and impose requirements on stablecoin investors, confirmed by direct citation of the primary implementing-rules instrument. This sits within the broader statutory frame established by the Law On Digital Assets, under which money-backed stablecoins are classified as a category of digital financial asset, distinct from unsecured digital assets such as Bitcoin.

The existence of a dedicated issuer, issuance-decision, and investor-requirement framework indicates that Kazakhstan has moved beyond a purely definitional treatment of stablecoins toward an operative regulatory regime governing their lifecycle from issuance through investor protection. This is a Confirmed-confidence, in-force development sourced directly to the primary implementing instrument.

#### Outlook

Watch for the first stablecoin issuances conducted under this new rules framework, which would provide a practical test of how the issuer and investor requirements operate in practice, and for any NBK guidance clarifying how the stablecoin regime interacts with the broader DFA trading-platform registration requirement.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-11-04

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### Kazakhstan: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable▾

AFSA has progressively proposed consumer-protection measures for AIFC-licensed digital asset exchanges in the wake of the FTX collapse, including customer-asset segregation, liquidity-risk checks, disclosure, and arbitrage-risk controls, alongside separate consultation on operational resilience. Outside the AIFC carve-out, retail consumer protection is limited in practice because unsecured digital-asset circulation itself is prohibited nationally.

Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded in this cycle

Sources and findings (3)
- T3[CoinDesk](https://www.coindesk.com/policy/2023/01/31/kazakhstan-looks-to-tighten-rules-for-crypto-exchanges-after-ftx-collapse/) — AFSA proposed new measures targeting the safekeeping and segregation of customers' digital assets by AIFC-licensed exchanges following the collapse of FTX, alongside checks on liquidity risk and arbitrage exposure.
- T3[CoinDesk](https://www.coindesk.com/policy/2023/01/31/kazakhstan-looks-to-tighten-rules-for-crypto-exchanges-after-ftx-collapse/) — AFSA's DATF framework requires proper disclosure practices by licensed digital-asset exchange operators as part of its post-FTX regulatory proposals, alongside checks on liquidity risk.
- T2[Astana Financial Services Authority (AFSA)](https://timesca.com/kazakhstan-kraken-cryptocurrency-approval/) — AFSA advises that an international exchange's reputation does not by itself confirm Kazakhstan authorisation, and recommends customers check a platform's status in AFSA's official register before using it, since unlicensed-platform customers may not receive the legal protections available to customers of AFSA-regulated exchanges.

### Kazakhstan: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾

Kazakhstan's confirmed crypto-tax exposure centers on mining: a sliding electricity-consumption levy (1–25 tenge/kWh depending on the price miners pay for power) plus mandatory corporate tax on mining income, with prior special-economic-zone tax preferences withdrawn by 2022–2023 amendments. Comprehensive individual capital-gains/income-tax and VAT treatment of ordinary crypto trading by retail investors has not been clearly confirmed in available reporting and requires primary-source verification (e.g. Kazakhstan Tax Code / Adilet legal database).

Periodic update · new data 2026-10-18

#### 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.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-11-04

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### Kazakhstan: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable▾

The clearest cross-border-adjacent control identified is the Travel Rule obligation imposed on AIFC-licensed VASPs as part of AFSA's regulatory-sandbox exit checklist, which must be embedded within a VASP's AML/CFT policies and systems before a full license is granted. National-level outbound restrictions, sanctions-nexus rules, and cross-border reporting thresholds specific to digital assets have not been separately confirmed in available sourcing beyond the general mainland prohibition on unsecured digital-asset circulation (captured under crypto_licensing).

Periodic update · new data 2026-10-18

#### 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.

Periodic update · new data 2026-09-14

#### Cross-Border Transfer

The Law On Digital Assets No.193-VII imposes a Travel-Rule-style requirement on cross-border and domestic transfers of unsecured digital assets: operators handling such transactions must apply customer identification and, for certain transfers, collect and store sender and recipient information. This obligation carries Probable confidence, sourced to a secondary trade-press analysis of the statute rather than direct primary-source citation of the specific threshold language, and the exact thresholds triggering the sender/recipient information-collection requirement were not independently verified this cycle.

This framework-level requirement is a material tightening of Kazakhstan's cross-border digital-asset compliance posture relative to the pre-May-2026 baseline, in which no comparable national-level CDD or Travel-Rule-style obligation existed for unsecured digital-asset transfers outside the AIFC. The requirement applies to operators handling unsecured-digital-asset transactions specifically, consistent with the token-classification taxonomy described above; DFA-specific cross-border transfer requirements were not separately detailed in the evidence located this cycle.

#### Outlook

Watch for NBK implementing guidance specifying the precise CDD and sender/recipient information thresholds, since the current framework-level obligation leaves significant interpretive scope. This is the domain's principal open question, and it directly affects how internationally active crypto-asset firms should scope their compliance obligations toward Kazakhstani counterparties.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 3 traced claims · Re-verified 2026-11-04

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### Kazakhstan: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable▾

AML/CFT obligations applicable to Kazakhstan digital-asset activity are governed under the fleet's shared Financial Integrity Module (FIM) aml_ctf baseline; this crypto consumer baseline does not duplicate AML/CFT claims. For disambiguation only: AIFC-licensed VASPs undergo AFSA regulatory-sandbox review of AML/CFT programs (including Travel Rule implementation) before receiving a full license, while mainland digital-asset platforms notify the Ministry of Digital Development and are subject to financial monitoring by Kazakhstan's Agency for Financial Monitoring under the 2021 AML law.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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### Kazakhstan: C9 Commercial Activity unpopulated ▾

## Commercial Activity

Commercial activity in Kazakhstan's crypto sector this cycle centred on exploratory partnership and state-investment disclosures rather than closed regulatory transactions. Tether signed a non-binding memorandum of understanding with the National Bank of the Republic of Kazakhstan and the Alatau City Authority on 7 October 2026 to study a tenge-pegged stablecoin pilot and tokenisation framework; the agreement discloses no transaction amount, reflecting its exploratory, non-binding nature. Separately, the National Investment Corporation disclosed that Kazakhstan's National Strategic Crypto Reserve reached 700 million dollars as of 15 September 2026, with approximately 200 million dollars already invested, up from 350 million dollars in March 2026 — a disclosed capital-commitment event. The National Bank and ARDFM's draft DFA-issuance resolution, opened for consultation on 9 October 2026, is a regulatory rather than commercial development but is closely connected to the same perimeter-expansion theme evident in the Tether MoU and the reserve growth. — Outlook: The pace of deployment of the remaining roughly 500 million dollars of the National Strategic Crypto Reserve not yet invested, and any progression of the Tether exploration MoU toward a concrete product, are the two commercial-activity threads most likely to produce further material developments for Kazakhstan's digital-asset sector.

Periodic update · new data 2026-10-25

#### Commercial Activity

Two commercial developments surfaced in Kazakhstan's digital-asset sector. The first is the exploratory memorandum of understanding signed 7 October 2026 by Tether, the National Bank of Kazakhstan, and the Alatau City Authority to study a tenge-pegged stablecoin and asset-tokenisation pilot; no consideration, equity stake, or financial terms were disclosed, consistent with its framing as a non-binding study exercise rather than a transaction. The second is a memorandum concerning Bybit's Kazakhstan operations and AIFC tax residency, which also surfaced, though its specific terms were not independently detailed in the material available.

Both developments share a common character: each is an announced partnership or memorandum of understanding rather than a completed transaction with disclosed consideration. This pattern is itself a useful signal about the current state of Kazakhstan's digital-asset commercial environment, which this cycle is characterised by exploratory positioning among international players and domestic authorities rather than closed, value-disclosed deals.

#### Outlook

The commercial-activity picture to watch is whether either the Tether-linked stablecoin exploration or the Bybit-AIFC tax-residency arrangement progresses from a memorandum to a disclosed transaction with defined terms. Until either arrangement moves past the exploratory or memorandum stage, the commercial signal remains one of positioning rather than concluded commercial activity.

Sources and findings (1)
- T3[National Investment Corporation](https://www.coincu.com/tether-kazakhstan-stablecoins-asset-tokenization/) — National Strategic Crypto Reserve reached $700 million as of 15 September 2026 (~$200m invested), up from $350m in March 2026