On our employment law practice page, we have noted the gradual shift in the state's approach to immigration control, including with respect to engaging foreign specialists, consultants, auditors and head-office representatives from visa-free countries. This clearly requires companies (employers) to comply with evolving migration legislation.
To regulate the entry and transit of foreign nationals, Government Decree of the Republic of Kazakhstan No. 890 of 10 October 2026 introduced a mandatory system of electronic travel authorizations (ETA) issued through the QazETA digital platform. This mechanism affects a wide range of persons, including companies inviting foreign experts, branches and representative offices of foreign legal entities, and organizers of business trips and conferences. The new system is being rolled out in phases, which sensibly allows a transition period for businesses to adapt their internal processes to the new requirements. But will businesses manage to adapt before the authorization becomes mandatory?
Implementation Stages and Application Procedure
The transition to the new form of migration control is divided into several consecutive stages:
- from 1 November 2026, checks begin at Aktau Airport and at four road border crossing points ("Urlyutobe", "Aukhatty", "Atameken" and "Nurly Zhol"). At this initial stage, the absence of an authorization does not result in denial of entry; arriving persons are merely informed that they need to obtain one;
- from 1 January 2027, the rule extends to the international airports of Astana and Almaty;
- from 1 March 2027, checks are introduced at all other state border crossing points;
- from 1 July 2027, the electronic travel authorization (ETA) becomes a fully mandatory condition of entry, and its absence will constitute grounds for refusal of entry.
Applications are submitted through a dedicated digital platform no later than 72 hours before the intended entry into the country, and the applicant must complete mandatory identity verification. Authorizations are issued by the Ministry of Internal Affairs in coordination with the national security authorities. The application is currently free of charge, and the authorization is valid for 180 calendar days, subject to compliance with the permitted length of stay. It is important to bear in mind that the same passport used for the application must be presented when crossing the border, since verification is carried out through the unified digital border control system of the Republic of Kazakhstan. Holding an authorization does not, however, in itself guarantee entry: the final decision is made at border control.
Business Risks and Practical Steps
From a practical standpoint, the fixed application deadline of no later than 72 hours before entry creates operational risk for businesses at this stage. For example, where an urgent business trip is arranged on the eve of negotiations, transactions or audits, failure to obtain the authorization in time may lead to the cancellation of a key specialist's visit. Migration legislation does, however, provide for a broad list of categories of persons exempt from this requirement upon presentation of supporting documents, including children under 16, persons over 65, and holders of valid Kazakh visas, temporary residence permits or permanent residence permits.
For transport companies, it is particularly important that the exemptions cover the main modes of international carriage: in air, sea and river transport — crew members of aircraft and of sea and river vessels; in rail transport — train and locomotive crews; and in road transport — drivers engaged in international cargo and passenger carriage in vehicles of the prescribed categories, whose role and authority are confirmed by the appropriate documents during international carriage. Whether each person involved in carriage falls within these exemptions is a matter that requires legal analysis. Nevertheless, companies should verify the status of their employees and guests in advance and take the following steps:
- Supplement internal policies on business travel and the hosting of foreign guests with a mandatory requirement to obtain an ETA through the QazETA platform in advance;
- Verify the passport details of invited persons to ensure that the authorization is issued for the same passport that will be used to cross the border, including where a passport has been replaced;
- Prepare in advance a set of supporting documents for employees and specialists who fall within the exempt categories;
- Appoint, by internal order and with corresponding amendments to the employment contract, an employee responsible for submitting applications through the QazETA platform and regularly monitoring notifications on the digital platform.
It is also important to bear in mind that:
- an ETA may be cancelled if the period of stay is shortened, in the event of administrative expulsion, or if irregularities are found in the application;
- official notifications are sent through the digital platform.
A missed notification or a delayed response may only come to light at the border crossing point. Businesses should therefore establish proper internal controls over the status of authorizations and keep track of incoming messages in a timely manner.
The phased introduction of electronic travel authorizations through the QazETA platform requires employers and inviting organizations to adjust their HR and operational processes in good time. Advance preparation helps minimize the risk of transport delays, disrupted business meetings or denial of entry to foreign specialists.
We are ready to provide the legal support you need in connection with this new migration control requirement.