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Changes in the legislation of Kazakhstan

We track new rules and explain who they affect and what has to be done.

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LANES client alerts in full: who is affected, what changes, effective dates and our recommendations.

Tax administration and bank secrecy

The procedure for banks to transfer data on incoming payments to bank accounts of individuals and individual entrepreneurs to the State Revenue Committee has been revised

Who is affected

Individual entrepreneurs under a special tax regime. Users of the special mobile application for entrepreneurial activity. Individuals to whose accounts payments from entrepreneurial activity are received. Second-tier banks and organizations engaged in certain types of banking operations. Employers and companies settling with self-employed individuals and individual entrepreneurs via transfers to personal accounts. Companies engaging contractors under contracts for the paid provision of services with payment to a bank card.

What changes

The rules and deadlines for second-tier banks and organizations engaged in certain types of banking operations to submit data to the state revenue authorities on the total amounts of payments received for a calendar month to the accounts of individuals, individual entrepreneurs under a special tax regime, and users of the special mobile application are set out in a revised edition. The transfer is carried out monthly, no later than the 5th day of the following month via an open API in XML format, and in the absence of integration, via a secure sftp server according to the list formed by the State Revenue Committee on the 1st day. The basis for the transfer is the payer's consent to the disclosure of bank secrecy, signed in the special mobile application with an electronic digital signature. Amounts for which data is already received in the special mobile application are excluded from the transfer. We separately note a related change: starting from November 10, 2026, the threshold for detecting entrepreneurial income on personal accounts has been increased - according to source reports, up to 1,557,000 tenge. This is a separate act, and its requisites require separate verification.

List of changes
  • The Rules and deadlines for the submission to the state revenue authority by second-tier banks and organizations engaged in certain types of banking operations of data on the total amounts of payments received for a calendar month to the accounts of individuals, individual entrepreneurs under a special tax regime, and users of the special mobile application have been revised
  • Amounts for which data is received in the special mobile application have been excluded from the transmitted data
  • The basis for the transfer is the payer's consent to the disclosure of bank secrecy given to the servicing bank
  • The consent is signed in the special mobile application with the mandatory use of an electronic digital signature
  • The special mobile application provides banks with an electronic document confirming the existence of consent
  • The State Revenue Committee generates an initial list of payers with a mark on the existence of consent and transfers it to the banks' central systems
  • The list of payers is updated online when data changes
  • In case of integrated central systems, data is transferred monthly no later than the 5th day of the month following the reporting month via an open API in XML format
  • In the absence of integration, on the 1st day the Committee generates a file with the list of payers as of 00:00 and places it on a secure sftp server
  • In the absence of integration, on the 5th day banks upload data according to this list and place them in the bank's folder on the same server
  • The Order does not mean the automatic classification of all receipts to individual accounts as income from entrepreneurial activity
Effective date

Effective from November 23, 2026.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Customs Law and Foreign Economic Activity

Cash at the EAEU customs border may be detained based on national security authorities information

Who is affected

Companies and their representatives moving cash and negotiable instruments across the customs border of the Eurasian Economic Union. Executives and employees traveling with company cash or accountable amounts. Foreign economic activity participants settling in cash. Companies using promissory notes, checks, and other bearer negotiable instruments. Carriers and courier services accompanying valuables.

What changes

The rules for detaining cash and negotiable instruments moved across the EAEU customs border have been supplemented with a new source of information: national security authorities have been added to law enforcement agencies and the authorized body for financial monitoring. State revenue authorities are now entitled to detain cash and negotiable instruments, including based on information from the National Security Committee regarding the possible involvement of funds in the legalization (laundering) of proceeds from crime, the financing of terrorism, or the financing of the proliferation of weapons of mass destruction. For cases where information is received from national security authorities, the procedure for transferring detained funds to the requesting agency also applies. No new limits on cash transport are introduced, customs declaration requirements are not cancelled, and automatic detention of cash for all border crossers is not provided.

List of changes
  • National security authorities have been added to the list of information sources serving as the basis for detaining cash and negotiable instruments
  • Previously, the basis was information from law enforcement agencies and the authorized body for financial monitoring
  • State revenue authorities detain cash and negotiable instruments at the EAEU customs border in cooperation with law enforcement agencies, national security authorities, and the authorized body for financial monitoring
  • The basis is information on the possible involvement of funds in the legalization (laundering) of proceeds from crime, the financing of terrorism, or the financing of the proliferation of weapons of mass destruction
  • The procedure for transferring detained funds to the agency that provided the information has been extended to cases where information is received from national security authorities
  • The transfer of detained funds is carried out upon the request of the agency, in the presence of the officer responsible for storage, and is formalized by an act in two copies in the established form
  • The detention procedure itself has not been significantly changed, no new amount limits for moving cash have been established, and customs declaration requirements have been preserved
Effective date

From November 20, 2026.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Transportation and Transitin force

A 20 MCI Guarantee Fee for Electronic Queue Booking is Introduced at the Border with Uzbekistan

Who is affected

International road freight carriers using the Kazygurt, B. Konysbayeva, and Atameken checkpoints on the Kazakhstan-Uzbekistan border. Freight forwarders and logistics operators booking electronic queue slots on behalf of carriers. Cargo owners exporting and importing goods via the Uzbek direction and in transit further south. Companies operating under strict delivery schedules.

What changes

To book a slot in the electronic queue system at three checkpoints, a guarantee fee in the amount of 20 monthly calculation indices is introduced, which is 86,500 tenge based on the 2026 index. The amount must be in the carrier's special electronic account at the time of booking. Upon timely arrival of the vehicle at the booked time, the fee is refunded in full automatically. If the carrier fails to arrive at the designated time twice in a row within 90 calendar days, the amount is withheld and credited to the state budget. A single failure to arrive does not entail withholding. The measure is aimed against booking slots without the intention to use them, which blocked the queue for bona fide carriers.

List of changes
  • A guarantee fee is introduced to book a slot in the electronic queue system for international transport
  • The amount of the fee is 20 monthly calculation indices, which amounts to 86,500 tenge with the 2026 index at 4,325 tenge
  • The measure is introduced at the Kazygurt, B. Konysbayeva, and Atameken checkpoints on the Kazakhstan-Uzbekistan border
  • To book a slot, the required amount must be in the carrier's special electronic account
  • Upon arrival of the vehicle at the checkpoint at the designated time, the guarantee amount is refunded in full automatically
  • A single failure to arrive at the booked time does not entail withholding of the fee
  • If the carrier fails to arrive at the designated time twice in a row within 90 calendar days, the guarantee amount is not refunded and is credited to the state budget
  • The measure is aimed at suppressing the booking of slots without the intention to use them
Effective date

From November 9, 2026.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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International Treaties

Ratified agreement with Uzbekistan on the opening of customs service representative offices

Who is affected

Exporters and importers operating with Uzbekistan. Carriers and freight forwarders along the Kazakhstan-Uzbekistan route, including transit to Afghanistan, Iran, and further south. Customs representatives and declarants. Companies that regularly encounter disputable situations during clearance on the Uzbek side. Participants of projects along the southern transport corridor.

What changes

The intergovernmental agreement with Uzbekistan on the opening of representative offices of the customs services of the two states has been ratified. The ratification law was signed by the Head of State on November 5, 2026, simultaneously with the law on the ratification of the customs agreement with Pakistan. A customs service representative office in another state is a permanent channel of direct interaction between the services, which is usually used for operational verification of information, resolution of disputable situations during clearance, and exchange of information without diplomatic correspondence. The alert is issued as a signal of the emergence of a new mechanism, and not as an analysis of its rules.

List of changes
  • Ratified the agreement between the Governments of Kazakhstan and Uzbekistan on the opening of representative offices of the customs services of the two states
  • The ratification law was signed by王的 Head of State on November 5, 2026
  • The law was adopted simultaneously with the law on the ratification of the agreement with Pakistan on cooperation and mutual administrative assistance in customs matters
  • A legal basis is established for the permanent presence of representatives of the customs service of one state on the territory of another
Effective date

The agreement enters into force in the manner provided for by the agreement itself—as a rule, after the exchange of notifications on the fulfillment by the parties of internal state procedures. The ratification law has been signed by the Head of State, and the text of the law is published in the press. The actual opening of representative offices will require separate organizational decisions and may take a considerable amount of time.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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International Treaties

Agreement with Pakistan on Customs Cooperation and Exchange of Declaration Data Ratified

Who is affected

Exporters shipping goods to Pakistan or through its territory. Importers of Pakistani goods. Transport and logistics companies using or planning to use Pakistani sea ports to access foreign markets. Customs representatives and declarants. Companies processing transit declarations in the southern direction.

What changes

The Agreement between Kazakhstan and Pakistan on Cooperation and Mutual Administrative Assistance in Customs Matters has been ratified. One provision is crucial for business: the customs services of the two countries will exchange information on export and transit declarations. This means that data declared by a Kazakhstani exporter becomes available to the Pakistani side and vice versa, and discrepancies between the departure declaration and the destination declaration cease to go unnoticed. The Agreement establishes the legal framework for the joint prevention of customs legislation violations and the coordination of response measures. The context is the development of Kazakhstan's exports through Pakistani sea ports.

List of changes
  • Ratified the Agreement between the Governments of Kazakhstan and Pakistan on Cooperation and Mutual Administrative Assistance in Customs Matters
  • Established the legal and organizational frameworks for customs cooperation between the two states
  • Introduced the exchange of information on export and transit declarations between customs services
  • The Parties undertake to promptly exchange necessary information between customs services
  • The Parties promote the prevention and suppression of violations of customs legislation
  • The Parties coordinate measures for the prevention and suppression of violations
  • Obligations have been established to ensure the confidentiality of transferred information and information security
Effective date

The Agreement enters into force in the manner prescribed therein—as a rule, following the exchange of notifications on the fulfillment by the Parties of internal state procedures. The Law on Ratification was signed by the President of the Republic of Kazakhstan, and the text of the law is published in the press.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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International Treaties

Protocol with Russia on the Resumption of the Agreement on Oil and Petroleum Product Supplies Ratified

Who is affected

Importers of crude oil and petroleum products from the Russian Federation. Oil refineries and traders. Airlines and airport operators with respect to jet fuel. Transport and logistics companies purchasing diesel fuel and gasoline. Gas station networks. Participants in the coordination of indicative supply balances. Any companies for which fuel constitutes a significant share of their cost of production.

What changes

Kazakhstan has ratified the protocol to the intergovernmental agreement with Russia on trade and economic cooperation in the field of oil and petroleum product supplies. The baseline agreement was concluded in 2010, its validity period expired in early 2024, and the protocol resumes its effect with amendments. The practical implication for business is the preservation of the duty-free regime for supplies of petroleum products from Russia and the mechanism for annual coordination of indicative balances. According to the estimate provided during the consideration of the law, the savings from the duty-free regime in 2026 amount to approximately 30 billion tenge: about 5.59 billion for gasoline, 15.75 billion for diesel fuel, and 8.61 billion for jet fuel. Without ratification, the intergovernmental supply coordination mechanism would have ceased to be effective.

List of changes
  • Ratified the protocol resuming the effect of the intergovernmental agreement between Kazakhstan and Russia on trade and economic cooperation in the field of oil and petroleum product supplies
  • The baseline agreement was concluded in 2010, its validity period expired in early 2024, and the protocol brings the agreement back into force
  • The protocol introduces amendments to certain provisions of the baseline agreement
  • The duty-free regime for supplies of oil and petroleum products from the Russian Federation is preserved
  • The mechanism for annual coordination of indicative supply balances between the parties is preserved
  • An exchange of information between the competent authorities of the two states is provided for
  • The intergovernmental supply coordination mechanism is restored, allowing for a prompt response to risks of petroleum product shortages
  • According to the estimate provided during the consideration of the ratification law, the savings from the duty-free regime in 2026 amount to approximately 30 billion tenge, including about 5.59 billion for gasoline, 15.75 billion for diesel fuel, and 8.61 billion for jet fuel
Effective date

The protocol enters into force in the manner prescribed by it—as a rule, from the date of the last written notification on the fulfillment by the parties of internal state procedures. The Law of the Republic of Kazakhstan on ratification was signed by the President and published in October 2026.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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FMCG · retailin force

Rules for labeling light industry goods approved: Data Matrix for clothing from December 1

Who is affected

Manufacturers of clothing, knitwear, leather and fur products, bed linen, table linen, toilet linen, and kitchen linen. Importers of light industry goods. Wholesale and retail sellers, marketplaces. Logistics companies and customs representatives servicing the import of these goods. Owners of inventory balances.

What changes

The Rules for Labeling and Traceability of Light Industry Goods have been approved. The main provisions enter into force on November 14, 2026, and mandatory labeling with the Data Matrix code begins on December 1, 2026, being introduced in four stages with an expansion of the list of goods. Key for foreign economic activity: the importer is obliged to ensure labeling BEFORE the import of goods into Kazakhstan or before placement under the customs procedure of release for domestic consumption or re-import, meaning the application of codes is transferred to a foreign supplier or to a warehouse outside the country. Retailers are required to sell such goods through a cash register machine with a scanner that reads the Data Matrix.

List of changes
  • The Rules for Labeling and Traceability of Light Industry Goods have been approved
  • The main provisions of the Rules enter into force on November 14, 2026
  • Mandatory labeling of goods of the first stage begins on December 1, 2026
  • The first stage covers clothing and clothing accessories made of natural or composite leather, artificial fur and products made from it, certain types of men's, women's, and children's clothing, ski suits, bed linen, table linen, toilet linen, and kitchen linen
  • Starting March 1, 2027, the list is expanded to include certain types of outerwear, blouses, sweaters, pullovers, cardigans, vests, men's shirts, women's blouses, shawls, scarves, ties, and other categories
  • Starting October 1, 2027, the list is expanded to include additional categories of men's, women's, and children's clothing, including suits, jackets, blazers, dresses, skirts, trousers, overalls, tracksuits, and knitted shirts
  • Starting October 1, 2027, mandatory transfer of information on the movement of goods between turnover participants is introduced
  • The deadline for labeling inventory balances is established until January 1, 2028
  • Manufacturers are obliged to apply a unique Data Matrix code to each unit of goods before transferring it to the next turnover participant
  • Importers are obliged to ensure labeling before the import of goods into Kazakhstan or before placing goods under the customs procedure of release for domestic consumption or re-import
  • Retail sellers are obliged to sell labeled products through a cash register machine with a scanner capable of reading the Data Matrix code
  • Buyers are provided with the opportunity to check goods through the free Naqty Onim application
Effective date

From November 14, 2026 – main provisions of the Rules. From December 1, 2026 – mandatory labeling of goods of the first stage. From March 1, 2027 and from October 1, 2027 – expansion of the list. From October 1, 2027 – mandatory transfer of information on the movement of goods. Until January 1, 2028 – labeling of inventory balances.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Customs Law and Foreign Economic Activityin force

The list of goods subject to mandatory accompanying waybills and electronic invoices via the Virtual Warehouse has been expanded

Who is affected

Importers, manufacturers, and sellers of goods from the updated list. Companies operating with petroleum products, liquefied petroleum gas, biofuels, ethyl alcohol, and alcoholic beverages. Participants in the turnover of goods subject to traceability within the EAEU. From December 1, 2026, importers of goods subject to the minimum import price level and suppliers of certain types of agricultural products. Logistics companies and freight forwarders issuing accompanying waybills for goods.

What changes

The Ministry of Finance has updated the list of goods for which electronic invoices are issued through the Virtual Warehouse module of the electronic invoice information system and accompanying waybills for goods are executed. The list includes nine categories. The main part of the order comes into effect on November 1, 2026, and provisions regarding goods with a minimum import price level and certain types of agricultural products come into effect on December 1, 2026. Practical implications for business: if the HS codes of your nomenclature are included in the list, executing sales without accompanying waybills for goods and without electronic invoices via the Virtual Warehouse constitutes a violation, and inventory balances require registration in the module.

List of changes
  • The list of goods for which electronic invoices are issued through the Virtual Warehouse module of the electronic invoice information system has been updated
  • Biofuels have been included in the list
  • Ethyl alcohol and alcoholic beverages have been included in the list
  • Certain types of petroleum products have been included in the list
  • Gasohol, benzanol, nefras, and other types of fuel have been included in the list
  • Liquefied petroleum gas has been included in the list
  • Narcotic drugs, psychotropic substances, and precursors have been included in the list
  • Goods subject to traceability within the framework of the Eurasian Economic Union have been included in the list
  • From December 1, 2026, goods to which the minimum import price level is applied are included in the list
  • From December 1, 2026, certain types of agricultural products are included in the list
  • For goods from the list, the execution of accompanying waybills for goods and the issuance of electronic invoices via the Virtual Warehouse module are mandatory
Effective date

From November 1, 2026. Provisions regarding goods with a minimum import price level and certain types of agricultural products are effective from December 1, 2026.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Migration and Foreign Personnelin force

Introduction of the QazETA Electronic Entry Permit for Visa-Free Foreigners and Transit

Who is affected

Companies inviting foreign specialists, consultants, auditors, and head office representatives from visa-free countries. Branches and representative offices of foreign legal entities. Employers engaging foreign personnel from EAEU member states and visa-free countries. Carriers and logistics companies regarding international transport drivers. Organizers of business trips, conferences, and negotiations. Transit passengers.

What changes

A mandatory QazETA electronic permit is being introduced for foreigners entering Kazakhstan without a visa, including transit travel. Implementation is phased: starting November 1, 2026, checks will begin at Aktau Airport and four automobile border checkpoints, while the absence of a permit is not yet grounds for entry refusal, and the traveler is only informed. Starting January 1, 2027, the check will extend to the airports of Astana and Almaty, starting March 1, 2027, to all other checkpoints, and starting July 1, 2027, the permit becomes fully mandatory and entry will be refused in its absence. The application is submitted via a digital platform no later than 72 hours before entry. Issuance is free of charge, and the permit is valid for 180 calendar days. There are 29 categories of persons exempted from the requirement.

List of changes
  • A mandatory QazETA electronic permit is introduced for visa-free entry, including transit travel through the territory of Kazakhstan
  • Starting November 1, 2026, checks begin at Aktau Airport and the 'Urlytobe', 'Aukhatty', 'Atameken', and 'Nurly Zhol' checkpoints; at this stage, the absence of a permit does not entail entry refusal, and the traveler is informed of the need to obtain it
  • Starting January 1, 2027, the requirement extends to the airports of Astana and Almaty
  • Starting March 1, 2027, checks are introduced at all other checkpoints
  • Starting July 1, 2027, the permit becomes fully mandatory, and entry is refused in its absence
  • The application is submitted via a digital platform no later than 72 hours before the intended entry, with mandatory identification of the applicant
  • Permits are issued by internal affairs bodies in coordination with national security bodies
  • Issuance is free of charge, the permit is valid for 180 calendar days, and stay is permitted within established limits
  • Upon border crossing, the same passport used to apply for the permit must be presented, and verification is conducted via the 'Berkut' unified digital system
  • Refusal of issuance is possible on the grounds provided by the legislation on population migration
  • The permit may be revoked upon reduction of the period of stay, administrative expulsion, or if issued with violations, and notifications are sent via the platform
  • 29 categories of persons are established who do not require a permit provided they have supporting documents, including children under 16, persons over 65, holders of a valid Kazakhstan visa or residence permit, refugees, transit passengers in the airport zone, ship and train crews, international transport and bus drivers, heads of state, and diplomats
Effective date

Starting November 1, 2026 — first phase. Starting January 1, 2027 — Astana and Almaty airports. Starting March 1, 2027 — all other checkpoints. Starting July 1, 2027 — full mandatory requirement with entry refusal. Separate sources indicate October 24, 2026, as the effective date of the act, however, practical consequences arise from November 1.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Migration and Foreign Personnelin force

The procedure for issuing permits to attract foreign labor has been tightened

Who is affected

All employers engaging foreign employees, including branches and representative offices of foreign legal entities. Companies utilizing intra-corporate transfer. Employers whose permits are valid in multiple regions. Kandases, resettlers, and employers participating in resettlement programs. Labor immigrants.

What changes

The Ministry of Labor and Social Protection of the Population has introduced amendments and additions to thirteen orders on migration and employment issues. The main takeaway for business is that the preliminary decision and hearing of the applicant have been excluded from the permit refusal procedure: previously, the employer had two working days to submit objections, whereas now the local executive body makes a final decision without prior notice and discussion. A one-year ban on obtaining permits for illegal employment has been introduced. When a permit is valid in several regions, the fee is paid to the budget of each of them. The timeframe for reviewing complaints by the akim's office has been reduced to five working days. Grounds for suspending public services have been introduced. The block on the cancellation of the inclusion of kandases and resettlers in the regional quota is introduced starting from January 1, 2027.

List of changes
  • The preliminary decision and hearing of the applicant have been excluded from the procedure for refusing to issue a permit to attract foreign labor; previously, two working days were allocated for objections
  • Employers who have allowed illegal employment of foreign employees are deprived of the right to obtain permits to attract foreign labor for one year
  • If a permit is valid in several regions, the fee for attracting foreign labor is transferred to the budget of each of these regions
  • The timeframe for the akim's office to review complaints against decisions of local bodies in the field of migration and employment has been reduced to five working days
  • The possibility of suspending a public service upon the application of the employer or upon the initiative of the local executive body has been introduced
  • Ground for suspension: introduction of a state of emergency, threat or occurrence of a natural or man-made emergency
  • Ground for suspension: business trip of the employer, if it lasts longer than the service provision period and a legal representative is absent
  • Ground for suspension: inpatient treatment of the employer under the same conditions
  • Similar grounds for suspension have been introduced into the rules for assigning and extending the status of a kandas and inclusion in the regional quota for receiving resettlers
  • For labor immigrants, the service may be suspended under force majeure circumstances or if the applicant is undergoing inpatient treatment
  • The regulations for the provision of public services by local executive bodies in the field of migration and employment have been changed
  • Starting from January 1, 2027, the cancellation of the decision on the inclusion of a kandas or resettler in the regional quota is introduced on the following grounds: voluntary refusal of resettlement by application, failure to arrive in the chosen region within three months from the date of the decision, loss of compliance with legislative requirements after inclusion, two or more violations of the rules of permanent residence and registration within five years
  • Upon cancellation, the right to state support measures for the person themselves and members of their family is terminated, the social contract is terminated, the decision is made by the local executive body that included them in the quota with notification of the applicant
Effective date

Effective October 17, 2026. Provisions regarding the cancellation of the inclusion of kandases and resettlers in the regional quota shall take effect on January 1, 2027.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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FMCG · retailin force

Internal Trade Rules amended: 30 percent shelf space for domestic goods, eye level, price tags and trade markup

Who is affected

Retail chains and stores classified as trade facilities of categories 1, 2, 3, and 4. Marketplaces and other electronic trading platforms. Information and advertising platforms and classifieds services, including platforms for the sale and rental of housing. Importers, distributors, and suppliers of imported goods - regarding the reduction of available shelf space. Manufacturers, wholesale suppliers, and retailers of socially significant food products - regarding the maximum trade markup. Domestic goods manufacturers - as beneficiaries under the placement regulations.

What changes

Internal Trade Rules have been brought into compliance with the policy of supporting domestic production. The quota of 30 percent of trading area and/or shelf space for goods bearing the "Made in Kazakhstan" sign has been extended from food products to non-food products, while compliance with the share is verified not only for the store as a whole, but also for each category and subcategory of goods. Requirements for placement locations have been introduced - the central zone and the buyer's eye level, as well as mandatory designation of such locations. For electronic platforms, a priority for domestic goods in search results has been introduced, and for classifieds services - two-factor identification of advertisers, disclosure of housing dilapidation, and integration with the National Bank's anti-fraud center. A separate section regulates the maximum trade markup on socially significant food products and the composition of expenses for which its increase is permitted.

List of changes
  • The requirement for a share of at least 30 percent of the trading area and/or shelf space for goods bearing the "Made in Kazakhstan" sign has been extended to non-food products; previously it applied only to food products
  • The share of domestic goods is calculated separately by subcategory, by category, and for the trade facility as a whole as the ratio of the number of facings of domestic goods to the total number of facings
  • For trade facilities of categories 1, 2, 3, and 4, the placement locations of domestic goods are designated by a sign or inscription "Made in Kazakhstan"
  • Domestic goods are placed in the central placement zone of each category and subcategory at the buyer's eye level and next to high-demand goods
  • In case of an insufficient quantity of domestic goods, vacant placement locations may be occupied by other goods
  • The maximum trade markup on socially significant food products is no more than 15 percent of the manufacturer's release price or the wholesale supplier's purchase price under the supply agreement; with multiple suppliers, the markup is calculated from the lowest recorded price
  • The markup may be increased by documented expenses for transportation and/or import, for delivery in electronic commerce, and for natural loss within the limits of standards; other operating expenses are taken into account within 15 percent and do not constitute grounds for its increase
  • Electronic trading platforms are required to ensure the priority display of goods bearing the "Made in Kazakhstan" sign in search results, with the exception of results generated taking into account personalized user parameters
  • Agreements between electronic trading platforms and sellers must include a condition on compliance with requirements for domestic goods
  • Information and advertising platforms are required to register and identify persons who posted advertisements through two-factor authentication using a number registered with a telecommunications operator of the Republic of Kazakhstan
  • Advertisements for the sale, lease, or other alienation of housing must indicate information on the recognition of the premises as emergency and/or dilapidated
  • The software of information and advertising platforms must be integrated with the anti-fraud center of the National Bank of the Republic of Kazakhstan
  • Price tags of sold goods must indicate the name of the good, grade, and price per unit or per weight
  • The procurement and/or sale of food products for subsequent sale must comply with national standards, and the list of standards has been supplemented
  • The concepts of category and subcategory of goods, control (identification) sign, and means of identification have been introduced, and the product identification code is contained in the National Product Catalog
Effective date

Effective October 19, 2026. Attention: certain sources indicate the effective date as October 20, 2026, and the alert adopts the earlier of the two dates.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Personal Data Protectionin force

Localization of digital objects and data subject's right to demand data deletion have been introduced

Who is affected

All owners and operators of databases and digital objects containing personal data, as well as third parties carrying out processing. Primarily online stores, services and mobile applications, financial organizations, platform operators, medical organizations, retail chains and any employer maintaining personnel records. Separately, companies using access control systems with fingerprints, facial or voice recognition.

What changes

Rules for the collection and processing of personal data have been amended by the Order of the Acting Minister of Artificial Intelligence and Digital Development dated September 17, 2026. The amendments are substantive in nature: biometric data is directly classified as personal data, the localization requirement has been extended from databases to any digital objects, and the data subject has acquired the right to demand the destruction of data collected in violation of the law.

List of changes
  • Biometric data is directly classified as personal data
  • Storage of personal data shall be carried out by the owner, operator or third party in a database or digital object located on the territory of the Republic of Kazakhstan
  • The localization requirement has been extended not only to databases, but also to any digital objects
  • Personal data, the collection and processing of which were carried out in violation of legislation, shall be destroyed or deleted upon the demand of the subject
  • The subject has the right to demand blocking or anonymization of data collected or processed in violation of established requirements
  • When posting personal data in publicly available sources, they must be masked
Effective date

Effective since October 1, 2026.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Non-residents Taxationin force

Tax rates and taxation procedure for non-residents' income at the source of payment have been amended

Who is affected

Kazakhstan companies paying income to foreign legal entities and individuals, acting as tax agents. Branches and representative offices of foreign legal entities, permanent establishments of non-residents, companies with foreign personnel and with intracorporate transfers, payers of royalties and license payments.

What changes

A new Tax Code has been in effect since January 1, 2026, completely renewing the taxation system. The features of non-residents' taxation have changed significantly: new withholding tax rates have been introduced, a progressive scale for certain types of individuals' income and a new approach to the taxation of royalties. The withholding obligation rests with the Kazakhstan counterparty, therefore the risk of incorrect calculation is borne by it, rather than by the non-resident.

List of changes
  • Taxation of income of non-resident legal entities whose activities do not lead to the formation of a permanent establishment is regulated by Articles 683–687 of the Tax Code
  • New rates on non-residents' income at the source of payment have been introduced
  • A progressive scale has been introduced for the income of a non-resident employee and for the income of foreign citizens and stateless persons seconded by a non-resident not registered as a taxpayer of the Republic of Kazakhstan: ten percent on the amount up to eight thousand five hundred monthly calculation indices and fifteen percent on the excess
  • The progressive scale is applied under Articles 692 and 693 of the Tax Code
  • Incomes of non-resident individuals at the source of payment under civil law contracts and other incomes, with the exception of employees' incomes, are taxed under the former rules
  • The procedure for calculating and withholding corporate income tax at the source of payment when taxing income in the form of royalties has been amended
  • Amounts of income for maintenance and technical support services are not taxed as royalties if specified in the contract separately from the amount of royalties
  • In the absence of such separation, the entire amount of the non-resident's income is taxed as royalties
  • The tax agent submits the calculation for corporate income tax withheld at the source of payment from the non-resident's income to the state revenue body at its location under Article 685 of the Tax Code
Effective date

From January 1, 2026 — the new Tax Code has been enacted. Certain provisions have their own enactment dates.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Healthcare & pharmain force

A separate investigation procedure for violations in the circulation of medicines is introduced

Who is affected

Manufacturers, marketing authorization holders, importers and distributors of medicines and medical devices, pharmacy and medical organizations.

What changes

An independent procedure for investigating violations in the field of circulation of medicines and medical devices, separate from routine state control, is introduced into the Code "On Public Health and the Healthcare System". Starting next year, operational response measures and risk-based sampling without prior notice to the subject will be added to it.

List of changes
  • A separate investigation of violations in the field of circulation of medicines and medical devices is introduced
  • The authorized body is empowered to approve the rules for conducting such investigations
  • During the investigation, the subject is obliged to provide documents, materials and explanations, including electronic data
  • The subject is obliged to provide access to digital systems and facilities related to the investigation
  • Sampling of medicines, medical devices, raw materials and components is provided for
  • The results are formalized by an act, information that does not constitute a legally protected secret is published within ten working days after the end of the investigation
  • Starting January 1, 2027, operational response measures are introduced: suspension of production and sales, suspension, recall and withdrawal of products from circulation
  • Starting January 1, 2027, risk-based sampling without prior notice to the subject is introduced
  • Costs for sampling and laboratory testing are assigned to the manufacturer and the marketing authorization holder
Effective date

From September 7, 2026 - the main body, upon expiration of sixty calendar days after the first official publication. Certain provisions, including operational response measures and risk-based sampling, - from January 1, 2027.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Labor disputesin force

Claims for recovery of wages may cover three years instead of one

Who is affected

All employers, HR and legal departments, payroll services. Specifically — companies with overtime work, shift schedules, summarized working hours, and high staff turnover.

What changes

The Constitutional Court provided an official interpretation of Article 160 of the Labor Code. The one-year limitation period for applying to court in labor disputes does not in itself prevent the recovery of wages due to an employee and other mandatory payments related to remuneration, within the general three-year limitation period under the Civil Code. The practical effect is direct: the depth of potential financial claims of a former employee increases threefold.

List of changes
  • The one-year period of Article 160 of the Labor Code does not mean the impossibility of applying the general three-year limitation period under Article 178 of the Civil Code
  • The interpretation extends to claims for the recovery of wages and other mandatory payments related to remuneration
  • Payment for overtime work is explicitly named
  • The basis for consideration was an application by a citizen whose claims for overtime work were satisfied by the courts only for the last year
  • The Constitutional Court simultaneously reviewed subparagraph 2) of part one and paragraph three of part five of Article 160 of the Labor Code
  • The Government is recommended no later than one year from the date of publication of the resolution to initiate a draft law on bringing the Labor Code into compliance with the legal positions of the Constitutional Court
Effective date

The normative resolution was adopted on June 8, 2026. Normative resolutions of the Constitutional Court are universally binding throughout the territory of the Republic of Kazakhstan and apply from the moment determined by the resolution itself.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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FMCG · retailin force

A new list of goods subject to mandatory labeling has been approved, with individual deadlines by category

Who is affected

Manufacturers, importers, distributors, retail chains, and other participants in the turnover of consumer goods. Primarily the turnover of tobacco products, beer and beer-based beverages, certain types of food products, dietary supplements, light industry goods, cosmetics and perfumery, household chemicals, toys, and motor oils.

What changes

The list of goods subject to labeling and the dates of its introduction have been defined by a new order and set out in a new edition. Different start dates for mandatory labeling have been established for various product categories; therefore, applying a single date to the entire product range will lead to errors. Applicability is determined simultaneously by the EAEU FEACN code and the product name.

List of changes
  • The list of goods subject to labeling and the dates of introduction are set out in a new edition
  • A separate start date for mandatory labeling has been established for each product category
  • When classifying a product as part of the list, it is necessary to be guided simultaneously by the EAEU FEACN code and the product name
  • Beer and beer-based beverages: products in kegs and bottles starting from February 1, 2026, and packaged in cans starting from January 1, 2027
  • Motor oils: with respect to products manufactured starting from February 1, 2026
  • Saiga derivatives: processed or unprocessed saiga horns, powder, and waste are subject to mandatory labeling starting from December 1, 2025
  • The list includes categories of tobacco products, certain types of food products, dietary supplements, light industry goods, cosmetic and perfumery products, household chemicals, and toys
Effective date

The new edition of the list of goods subject to labeling, approved by Order No. 215-NQ, applies starting from September 9, 2026. The baseline Order No. 199-NQ, which defined the list, entered into force on August 14, 2026. The start dates for mandatory labeling for each category are established directly in the annex to the order and do not coincide with these dates.

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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Personal Data Protectionin force

Personal Data Protection Rules restated in a new edition

Who is affected

All owners and operators of databases containing personal data, as well as third parties carrying out processing, including branches and representative offices of foreign legal entities. Specifically affects companies with databases exceeding one hundred thousand records, employers, medical organizations, banks, insurance companies, retail chains, and any business maintaining client databases.

What changes

The Rules for implementing personal data protection measures are restated in a new edition. The amendments are substantive rather than editorial, introducing a one-day notification period for data security breaches, detailing technical requirements for the processing of restricted access data, and establishing the obligation to integrate with the state access control service. Concurrently, a new edition of certain provisions of the Law on Personal Data became effective on July 12, 2026.

List of changes
  • The Rules are restated in a new edition
  • Personal data is divided by accessibility into publicly available data and restricted access data
  • The owner, operator, and third party shall identify business processes containing personal data and determine the list of persons performing collection and processing or having access thereto
  • Legal entities shall appoint a person responsible for organizing the processing of personal data, with duties regarding internal control, informing employees, and supervising the handling of requests from data subjects
  • Notification of the authorized body regarding a personal data security breach shall be sent within one business day from the moment of detection
  • When interacting with state digital objects, integration of own digital objects with the state personal data access control service is required
  • For restricted access data, a database management system event log, a user action log, integrity control tools, and transmission via secure communication channels are mandatory
  • Storage and transmission of restricted access data shall be carried out using cryptographic protection tools with parameters no lower than the third security level according to ST RK 1073-2007, except for cases of cross-border transfer
  • For databases containing more than one hundred thousand records, user identification or authentication tools shall be used, including biometric authentication
  • Collection and processing of restricted access data shall be conducted via digital objects located on the territory of the Republic of Kazakhstan, and storage shall be in a server room or data processing center on the territory of the republic
  • The State Technical Service shall be granted access to digital objects to inspect the security of storage, processing, and dissemination processes of restricted access data
Effective date

Effective from July 12, 2026

Details and status

For further details and to check the status, please contact us. This material is for information only and does not constitute legal advice.

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