AIFC · AFSA LICENSING
AFSA Licensing — Insurance
Foreign insurers, reinsurers, captives, brokers and managers can all be licensed in the Astana International Financial Centre (AIFC), but Kazakhstan law decides how far each licence reaches. An insurer or reinsurer incorporated in the AIFC needs a Capital Floor of USD 7 million, and its capital must also cover a Prescribed Capital Requirement of at least 150% of its minimum. On our calculation that is USD 10.5 million at the floor; the rules do not state that figure. A captive starts at USD 100,000 to USD 300,000, and a broker or insurance manager at USD 7,000 or USD 13,000. Reinsurance of Kazakhstan insurers is open, on the conditions set out below. Direct cover for Kazakhstan residents is limited to listed classes such as aviation, marine, space, cyber and catastrophe risks.
This guide is part of the AFSA Licensing section. Takaful is outlined here and covered in AFSA Islamic Finance Licensing.
Legal Framework
| Instrument | Role |
|---|---|
| Constitutional Statute No. 438-V of 7 December 2015 | AIFC, the Astana Financial Services Authority (AFSA) (Art. 12), tax (Art. 6) |
| AIFC Financial Services Framework Regulations, No. 18 of 2017 (FSFR) | General Prohibition (s 24), licence criteria (s 34), appeals (s 35), change of control (s 48) |
| AIFC General Rules, FR0001 of 2017 (GEN) | Regulated Activities (Schedule 1), mandatory appointments, Controllers, audit |
| AIFC Insurance and Reinsurance Prudential Rules, FR0030 of 2018 (PINS) | Insurers, reinsurers and captives; latest published text amended 13 December 2020 |
| AIFC Prudential Rules for Insurance Intermediaries and Insurance Managers, FR0012 of 2017 (PRU(INT)); AIFC Takaful and Retakaful Prudential Rules, FR0031 of 2018 (TRR) | Intermediaries and managers; Takaful Operators |
| AIFC Conduct of Business Rules, FR0005 of 2017 (COB) | Intermediaries (COB 11), insurers (COB 19), managers (COB 20), client money (COB 8.5) |
| AIFC AML, CTF and Sanctions Rules, FR0008 of 2017 (AML); AIFC Fees Rules, FR0007 of 2017 (FEES); Representative Office Rules, FR0006 of 2017 (REP) | Financial crime controls; fees as amended from 1 December 2025; representative offices |
| Law on Insurance Activity No. 126 of 18 December 2000; AIFC Rules on Currency Regulation, No. 6 of 2021 | What AIFC firms may sell to Kazakhstan residents (Law, Arts. 5-1, 9; Rules, Schedule 2) |
Which Licence Fits Your Business
Insurance Business means Effecting Contracts of Insurance, Carrying on Contracts of Insurance, or both (PINS 1.1.3). Effecting covers offering, negotiating and concluding cover as principal. Carrying on covers performing the contract: premiums, records, claims. "Insurer" includes a reinsurer. Fees are in USD.
| Activity | Who it suits | Minimum capital | Application fee | Annual supervision fee |
|---|---|---|---|---|
| Insurance Business | General or long-term insurers and reinsurers | USD 7 million Capital Floor | 14,000 | 9,800 |
| Captive Insurance Business | Group, closely linked or association captives | USD 100,000 (Class 1), 200,000 (Class 2), 300,000 (Class 3), or higher risk components | 7,000; through a Protected Cell Company, 7,000 plus 1,000 per cell | 4,200; through a Protected Cell Company, 4,900 plus 700 per cell |
| Takaful Business | Takaful and Retakaful Operators | USD 7 million Capital Floor | 14,000 | 9,800 |
| Insurance Intermediation | Brokers and agents: advising on, arranging or acting as agent for policyholders | Greater of USD 7,000 or 2.5% of annual income; with Client Money, USD 13,000 or 5% | 7,000 | 1,400 |
| Insurance Management | Underwriting or administration on behalf of an insurer or captive, and arranging its reinsurance | As for Intermediation | 10,000 | 1,400 |
| Operating a Representative Office | Marketing services of a foreign regulated insurer offered outside the AIFC | None stated in REP | 4,200 | 1,400 |
An insurer may not combine Long-Term Insurance Business with General Insurance Business, except Categories 1 (accident) and 2 (sickness), and may not carry on activity unconnected with Insurance Business; Managing Investments is expressly not connected (PINS 1.4). A representative office needs its own AFSA Licence, may only market, and cannot hold any other Regulated Activity (GEN Schedule 1, para 16).
A captive must be incorporated in the AIFC and may be self-managed or managed by an AFSA-authorised Insurance Manager. Class 1 covers group risks only, Class 2 may take up to 20% of premium from closely linked third-party risks, and Class 3 covers owners in similar or common businesses. A Protected Cell Company may carry on only Captive Insurance Business, and cells need AFSA's written consent (PINS 14.1, 14.2).
What You Can Sell to Kazakhstan Residents
Under Art. 5-1(1) of the Law on Insurance Activity, property interests located in Kazakhstan and the interests of resident individuals may be insured only by a Kazakhstan insurer or a branch of a non-resident insurer, subject to the exceptions in Art. 5-1(2). Kazakhstan banks may not process premium payments to AIFC Participants outside those exceptions (Art. 5-1(3)). The AIFC Rules on Currency Regulation apply a parallel list. Services to AIFC Participants and non-residents are governed by the licence.
| Business with Kazakhstan residents outside the AIFC | Position | Source |
|---|---|---|
| Reinsurance of Kazakhstan insurers | Open for all risks. Requires an information exchange agreement between the Kazakhstan regulator and the AIFC regulator; no chain of two or more non-resident or AIFC brokers | Law Art. 9(8-1), (10), (13); Schedule 2, 2.2 |
| Reinsurance broking | Open: Kazakhstan insurers may cede through an AIFC broker | Law Art. 9(8-1); Schedule 2, 2.3 |
| Air, water and space transport risks, related cargo and liability | Open, excluding cabotage vessels | Law Art. 5-1(2)(2); Schedule 2, 2.1 |
| Catastrophe, climate, cyber and terrorism risks | Open | Law Art. 5-1(2)(2); Schedule 2, 2.5 |
| Guarantees and sureties, court costs, title | Open | Law Art. 5-1(2)(4); Schedule 2, 2.4 |
| Islamic insurance | Open; needs Takaful Business, as only Takaful licensees may use the term | Law Art. 5-1(2)(3); Schedule 2, 2.4.4; COB 19.1.2 |
| Direct broking of other risks | Not listed: Schedule 2 lists reinsurance broking only | Schedule 2, 2.3 |
| Insurance Management | Prohibited | AFSA Perimeter Guidance, 2.2.24 |
| Motor, property, health, life and other direct classes | Not listed: these stay with Kazakhstan insurers or branches | Law Art. 5-1(1) |
Schedule 2 also lists political risks, while Art. 5-1(2)(2) speaks of civil unrest and strikes, so these need checking risk by risk. Permitted services may be paid in any currency: tenge through an account at a Kazakhstan commercial bank, foreign currency through an AIFC bank or a Kazakhstan commercial bank. A firm wanting wider direct access in Kazakhstan needs a licence from the Agency for Regulation and Development of the Financial Market: see Financial Services Licensing in Kazakhstan.
Who Can Apply
Branches. The capital chapter applies only to AIFC-Incorporated Insurers (PINS 5.1.1). AFSA instead tests the whole firm against its threshold conditions, the equivalence of home supervision and supervisory co-operation, usually under a Memorandum of Understanding. If these fall short, the outcome is a subsidiary or added conditions (Supervisory Policy Statement on Branch Supervision, 2.3 to 2.10). A captive cannot be a branch (PINS 14.1.3).
Regulated foreign firms. A Representative Office licence requires regulation outside the AIFC, and AFSA may ask whether the home regulator has no objection (REP 2.2). AFSA's Fast-Track Authorisation Regime (Notice AFSA-ATD-NOT-2026-0018 of 20 August 2026) is open to firms supervised by the UK FCA, ASIC, MAS, the Hong Kong SFC and HKMA, ADGM FSRA, DFSA and QFCRA. Its published list includes Operating a Representative Office but names no insurance activity.
Requirements
Capital for insurers
An AIFC-Incorporated Insurer must keep Eligible Capital at or above both its Minimum Capital Requirement (MCR) and its Prescribed Capital Requirement (PCR) at all times (PINS 5.4). Paid-up share capital must be at least the Capital Floor, and shareholders' funds at least 75% of it (Schedule 4, 1.1).
| Measure | General insurance | Long-term insurance |
|---|---|---|
| Capital Floor | USD 7 million, or an amount AFSA specifies in writing | USD 7 million, or an amount AFSA specifies in writing |
| MCR | Highest of the floor, 12% of net gross written premiums, and 12% of net claims and premium reserves | Higher of the floor and 2.5% of total reserves net of reinsurance |
| PCR | Higher of 150% of MCR and the Risk-Based Capital Requirement | Same |
A captive's floor is the highest of its base requirement, a premium risk component of 18% of net written premium up to USD 5 million and 16% above it, and a technical provision component; captives do not calculate a PCR (PINS 14.4). The Takaful floor is USD 7 million, and USD 150,000 for a Captive Takaful Operator (TRR Schedule 4, 14.4.1), and a Takaful Operator's PCR follows the same 150% test (TRR Schedule 5, 1.1). AFSA's 2020 class modifications of the insurer and Takaful floors have expired.
People
- All firms: Senior Executive Officer, Finance Officer, Compliance Officer and Money Laundering Reporting Officer as Approved Individuals at all times (GEN 2.1.1). Directors are also Controlled Functions.
- Insurers: an Insurance Risk Manager and an Insurance Internal Audit Manager, plus risk management and actuarial functions (PINS 2.1, 2.2.2).
- Approved Actuary: required for long-term business, and for general business where more than 15% of gross outstanding liabilities are accident or sickness, or more than 20% are motor, aircraft, ships or general liability, credit or suretyship (PINS 2.2.2). Other insurers commission an independent actuary's report at least every 3 years (PINS 9.2.2).
- Residency: the MLRO must be resident in Kazakhstan, and a deputy is required (AML 13.1). The Senior Executive Officer has no strict residency rule but is expected to spend an appropriate amount of time in Kazakhstan.
- Captives: an AFSA-authorised Insurance Manager may provide the Senior Executive Officer and MLRO (PINS 14.3.1).
Intermediaries and managers
Professional indemnity insurance is mandatory unless AFSA approves an equivalent such as a guarantee, and it may not cover AFSA fines (PRU(INT) 4). Money held for clients is Client Money under COB 8.5 unless held as agent of the insurer under a written agreement.
Documents
- Application for Regulated Activities with the Insurance Business supplement, for insurers and for intermediaries holding Client Money. AFSA has a shorter form for Insurance Management and Intermediation without Client Money.
- A Regulatory Business Plan with three-year financial projections showing minimum capital.
- Approved Individual applications, and fitness and propriety information on Controllers, meaning holders of 10% or more of shares or votes, or significant influence (GEN 3.1.1).
- Compliance manual and monitoring programme, risk management, conflicts and AML/CTF policies, and a business continuity plan. Insurers also need a Risk Management Strategy (PINS 3).
Procedure, Timeline and Fees
The FSFR sets no deadline for a licence decision. AFSA states an average of about two to three months from a materially complete application, excluding time waiting for the applicant. The commitments below are AFSA's own.
| Step | What happens | Timing |
|---|---|---|
| 1. Preparation | AIFC Client Office, preliminary meeting, then draft Regulatory Business Plan to AFSA for feedback. | No fixed period |
| 2. Formal application | File forms and fees; AFSA acknowledges and assigns a case officer. | 2 working days |
| 3. Initial review | Initial Review Letter on the threshold conditions. | Within 4 weeks |
| 4. Response | Applicant answers comments; key candidates may be interviewed. | Up to 2 months |
| 5. Further review | Further comments; a third round may attract a supplementary fee. | 2 weeks per round |
| 6. In-Principle Approval | AFSA sets conditions for the licence. | Follows a complete application |
| 7. Conditions | Register the entity, appoint the board, inject the capital. Registrar fee: USD 500 online for a private, public or recognised company, USD 100 for a Protected Cell Company. | In the applicant's hands |
| 8. Licence | Licence issued; pro-rated supervision fee due within 21 days. | After conditions are met |
Registration follows In-Principle Approval and comes before the Licence. AFSA's FAQ does not allow a company to register first and seek authorisation later. AFSA recommends starting the Registrar process when the application is filed. See AIFC Entity Formation.
Fees. With more than one activity the applicant pays the highest fee in full and 50% of each other fee, plus USD 500 for each Approved Individual (FEES Schedule 1). Application fees are non-refundable (FEES 1.4). From 1 January 2027 annual supervision is the highest fixed fee plus 50% of the fixed fee for each additional activity; for 2026 only the highest is payable (FEES 3.1.5, 3.1.6). A rejection may be appealed to the AIFC Court (FSFR s 35).
Ongoing Obligations
- Prudential returns: insurers file annual returns within 4 months of year end with an external audit opinion, and quarterly and biannual returns within 1 month (PINS 13). A Class 1 captive may file half-yearly instead of quarterly. Intermediaries and managers file quarterly and annual returns (PRU(INT) 5.2).
- Solvency and actuarial reports: an Own Risk and Solvency Assessment at least annually, and an annual Financial Condition Report where an Approved Actuary is required (PINS 4.1, 9.1.2).
- Capital shortfalls: inform AFSA immediately, file a finance scheme within 1 month for the PCR or 2 months for the MCR, and restore capital within 6 months. Below the Capital Floor, stop writing new contracts at once (PINS 5.4). Dividends must be reported within 15 business days (PINS 5.6).
- Intermediaries and managers: notify a PRU(INT) breach within 1 Business Day (PRU(INT) 5.5).
- Conduct: claims handled promptly and fairly, with records kept for 3 years (COB 19.5). Retail Clients may cancel within 30 days for life policies and 14 days for general insurance (COB 19.2, 19.3). Intermediaries must disclose status and costs (COB 11).
- Controllers: prior AFSA approval to become a Controller of an AIFC-incorporated firm or to cross 30% or 50%; fee USD 1,400 (FSFR s 48; GEN 3.2).
- Accounts and financial crime: IFRS statements and audit reports within four months of year end (GEN 6.3); suspicious transaction reports to the Financial Intelligence Unit of the Republic of Kazakhstan and an annual AML Return within two months after year end (AML 13.7). See AML/CFT Compliance in Kazakhstan.
Tax Position
Until 1 January 2066, AIFC Participants are exempt from corporate income tax on listed financial services provided in the territory of the AIFC, and those services are exempt from VAT (Constitutional Statute, Art. 6(3), (8-2)). The Statute names reinsurance and insurance brokerage. It also covers services set by a joint AIFC Act, and the Joint Order of May and June 2020 (AIFC No. 126, Ministry of Finance No. 547, Ministry of National Economy No. 118) lists Effecting and Carrying on Contracts of Insurance (Reinsurance), Insurance Intermediation, Insurance Management and Takaful Business. Checked in November 2026: Article 6(3) was last amended on 30 December 2022 and still refers the list to a joint act, the Tax Code No. 214-VIII of 18 July 2025 did not change it, the AIFC still publishes the Order, and we found no amendment to it.
The exemption is conditional. The firm must perform its main activities in the AIFC, with adequate expenses and qualified full-time staff there, may not outsource core income-generating work outside Kazakhstan (Substantial Presence Rules, paras 6, 13), and must keep separate accounts (Art. 6(5)). Otherwise the ordinary Tax Code applies.
Common Mistakes Foreign Investors Make
- Assuming an AIFC licence opens the Kazakhstan direct market. Art. 5-1 keeps most direct classes with Kazakhstan insurers and branches, and Kazakhstan banks may not pay premiums outside the exceptions.
- Budgeting USD 7 million. Our calculation from PINS 5.4.2 and Schedule 5, 1.1: 150% of a USD 7 million MCR is USD 10.5 million of Eligible Capital for a new AIFC-incorporated insurer.
- Selling "Islamic insurance" under a conventional licence. The term is reserved for Takaful licensees (COB 19.1.2).
- Broking direct risks for Kazakhstan clients. Schedule 2 covers reinsurance broking only.
- Moving core work offshore. Outsourcing it outside Kazakhstan puts the tax exemption at risk.
Frequently Asked Questions
How much capital does an AIFC reinsurer need?
The same as an insurer: a USD 7 million Capital Floor and Eligible Capital covering the PCR, which is at least 150% of the MCR. "Insurer" includes reinsurers in PINS, and no separate reinsurer figure appears in the published rules.
Can an AIFC reinsurer accept risks from Kazakhstan insurers?
Yes. Kazakhstan insurers may cede directly or through specified brokers (Law on Insurance Activity, Art. 9(8-1)), and Schedule 2 of the Currency Rules permits all risks in any currency. Art. 9(10) requires an information exchange agreement between the Kazakhstan regulator and the AIFC regulator, and Art. 9(13) bars placement through two or more AIFC or non-resident brokers.
Can an AIFC insurer cover a Kazakhstan company's property?
Generally not. Property interests located in Kazakhstan must be insured with a Kazakhstan insurer or a branch of a non-resident insurer, unless the risk falls within an Art. 5-1(2) exception. An AIFC firm can instead reinsure the local insurer.
Can a Kazakhstan group set up an AIFC captive?
Yes, subject to AFSA authorisation: a Class 1 captive starts at USD 100,000 and must be AIFC-incorporated. The captive remains an AIFC insurer, so Art. 5-1 still governs direct cover of Kazakhstan-located risks, and the structure should be tested against it first.
Is a branch subject to the USD 7 million requirement?
The capital chapter of PINS applies to AIFC-Incorporated Insurers, so not directly. AFSA looks at the whole firm and the equivalence of its home regulator instead, and may impose conditions or require a subsidiary.
Related Pages
AFSA Licensing · AFSA Banking & Credit Licensing · AFSA Islamic Finance Licensing · AIFC Entity Formation · Financial Services Licensing in Kazakhstan
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Primary sources: aifc.kz, afsa.aifc.kz, zakon.uchet.kz — Constitutional Statute No. 438-V; FSFR; GEN; PINS; PRU(INT); TRR; COB; AML; FEES; REP; AIFC Rules on Currency Regulation; AFSA Perimeter Guidance; Supervisory Policy Statement on Branch Supervision; AFSA Guide on the Authorisation Process; Joint Order of 2020 on the List of Financial Services; Rules on Substantial Presence; Law on Insurance Activity No. 126