REGULATORY LICENSING  ·  KAZAKHSTAN

Financial Services Licensing in Kazakhstan

Kazakhstan has three financial licensing authorities. The Agency for Regulation and Development of the Financial Market (ARDFM) licenses banks, insurers, securities firms and microfinance organisations. The National Bank of Kazakhstan (NBK) oversees payment organisations and licenses exchange offices. The Astana Financial Services Authority (AFSA) authorises firms that operate in or from the Astana International Financial Centre (AIFC).

Two recent changes alter most market entry plans. The Law on Banks and Banking Activities No. 258-VIII of 16 January 2026 replaced the single banking licence with universal and basic licences, and a new bank now needs KZT 20 billion or KZT 10 billion of capital. From October 2026, Law No. 352-VIII of 23 July 2026 also split payment organisations into two categories: the first is licensed by the NBK and the second is registered with it.

Who Licenses What

MCI is the monthly calculation index, KZT 4,325 for 2026. Periods run from a complete filing, and several stop while the regulator waits for corrections.

Legal Framework

• Banks: Law No. 258-VIII of 16 January 2026, first published on 17 January 2026 and in force 60 days later, on 19 March 2026, with some provisions on later dates (Art. 135). It repealed the Law of 31 August 1995, apart from listed provisions that continue for a transitional period. ARDFM Resolution No. 41 of 3 April 2026 sets the licensing procedure, Resolution No. 85 of 28 April 2026 the prudential standards, and Resolution No. 124 of 25 August 2026 the limits for basic banks.
• Owners and managers in all regulated firms: Law on State Regulation, Control and Supervision of the Financial Market and Financial Organisations No. 474-II of 4 July 2003 (Arts. 9-4 and 9-5).
• Insurance: Law on Insurance Activity No. 126 of 18 December 2000; NBK Resolution No. 304 of 26 December 2016 on prudential standards.
• Securities: Law on the Securities Market No. 461 of 2 July 2003; NBK Resolution No. 80 of 27 April 2018.
• Microfinance: Law on Microfinance Activities No. 56-V of 26 November 2012; NBK Resolution No. 192 of 14 November 2019.
• Payments: Law on Payments and Payment Systems No. 11-VI of 26 July 2016; NBK Resolution No. 129 of 27 October 2020.
• Licences generally: Law on Permits and Notifications No. 202-V of 16 May 2014 (Annex 1 lists licensed activities); Tax Code No. 214-VIII of 18 July 2025, Art. 616 (licence fees).

Since 1 May 2026 the NBK has also licensed operators of exchange of unsecured digital assets under the Law on Digital Assets No. 193-VII of 6 February 2023; see Fintech & Digital Assets.

Banks: Universal or Basic Licence

A bank must be a joint stock company (Art. 7). Residents and non-residents may found it (Art. 9). The licence is issued for an unlimited period, cannot be transferred, and a bank may carry out only the operations named in it (Art. 19(20)).

An Islamic bank needs a separate licence and generally KZT 10 billion. A basic bank whose assets exceed the ceiling for nine consecutive months must move to a universal licence within twelve months or shrink below the ceiling (Art. 21). Banks licensed before the Law had six months from its entry into force to apply to re-issue their licences as universal licences. A bank below the universal capital minimum has one year to reach it and, if it does not, must then apply for a basic licence (Art. 132(3)).

Owners

• Holding 10% or more of voting shares, or control, needs the ARDFM's prior written consent (Art. 9(2)). The ARDFM decides within 50 working days (Law No. 474-II, Art. 9-5(15)).
• A bank must have at least one major participant or bank holding company, unless the Government or the national management holding owns more than 50% (Art. 9(3)).
• A major participant may not be registered in an offshore zone on the ARDFM's list, except for a subsidiary of a non-resident bank with the required rating (Art. 9(4)).
• A non-resident corporate founder must file its home supervisor's consent, or confirmation that none is needed (Art. 10(4)).

Branch of a foreign bank

The parent must have total assets of at least USD 10 billion, a valid home licence, the required rating, and no breach of capital or liquidity ratios in the previous twelve months. Its home state must take part in international anti-money laundering cooperation (Art. 15). The branch forms reserve assets at a level set by the ARDFM (Art. 72(4)), and at least two of its executives must be Kazakhstani residents (Art. 45(4)).

Step-by-Step: Opening a Bank

1. Permission to establish. File the founders' documents, audited accounts for two years, source of funds evidence and the application for major participant status. The ARDFM has 65 working days and may suspend the period. The applicant then has up to ten working days to answer comments (Art. 10).
2. State registration. Register with the State Corporation "Government for Citizens" within two months of the permission, or the permission lapses (Art. 12).
3. Capital. Pay the minimum charter capital in full, in tenge and in cash, within 30 calendar days after registration (Art. 8).
4. Readiness. Prepare premises, equipment and accounting software. Approve the rules on general conditions, a three-year strategy and internal risk documents (Art. 19(3)).
5. Licence application. Apply within one year of the permission, or it lapses (Arts. 12, 19(2)). File the charter, strategy, staffing schedule, proof of capital, proof of the fee, and documents for approval of executives (Art. 19(6)).
6. Decision. The ARDFM has 30 working days from a compliant filing (Art. 19(17)). It must refuse if the strategy fails to show that the bank will be profitable after its first three financial years (Art. 20).

The licence fee is 800 MCI for each banking operation, about KZT 3.46 million at the 2026 MCI, and 10% of that rate for re-issue (Tax Code Art. 616; Resolution No. 41). A bank that does not take part in mandatory deposit insurance loses the right to take retail deposits (Art. 83(3)).

Insurance

An insurer or reinsurer must be a joint stock company (Art. 22). The route has two stages: a permit to establish, decided within 50 working days (Art. 27(6)), then a licence, decided within 30 working days of a complete filing (Art. 37). The permit lapses if no licence is obtained within six months (Art. 27(5)). Minimum charter capital must be paid in full within three working days after state registration, in tenge and in cash (Art. 25).

Before applying, the company must have risk management and internal audit systems, approved executives, internal rules and a licensed actuary on staff, and must join the guarantee and database organisations where the law requires it (Art. 37(1-2)). The fee is 500 MCI for each class of insurance. Holding 10% or more of voting shares needs prior consent (Art. 26).

A foreign insurer may open a branch if it has total assets of at least USD 5 billion and at least ten years of experience, and if the ARDFM has a cooperation agreement with its home supervisor (Art. 30-1). The review period for the branch permit is 50 working days.

Securities Market

One licence covers the activities in Annex 1, item 54 of the Law on Permits: brokerage, dealing, investment portfolio management, custody, transfer agency, clearing and the organisation of trading. A licensee must be a joint stock company. Transfer agents, and brokers or dealers without the right to keep client accounts as nominee holder, may be LLPs (Art. 47-1). Residents and non-residents may be founders, but entities registered in listed offshore zones may not hold voting shares, subject to an exception for subsidiaries of rated non-resident firms (Art. 47). The ARDFM decides within 30 working days (Art. 50).

The capital test is a daily ratio of at least 1 (Resolution No. 80, para. 1). The minimum own capital used in the formula is 50,000 MCI for a broker or dealer that keeps client accounts as nominee holder, about KZT 216 million, and 10,000 MCI without that right, about KZT 43 million. For a portfolio manager it is 50,000 MCI. Article 46 leaves the minimum charter capital to the regulator's acts, so that figure should be checked for the specific licence at filing. Fees are 30 MCI for each of brokerage, dealing, portfolio management and custody.

Microfinance

A microfinance organisation may be a joint stock company or a business partnership (Art. 11). Minimum charter capital and minimum own capital are each KZT 200 million (Resolution No. 192, paras. 3 and 4), and charter capital must be paid in tenge, in full, by state registration (Art. 12). The company notifies the ARDFM and the financial monitoring authority within ten calendar days of registration, and must apply for the licence within six months of it. The ARDFM decides within 30 working days (Art. 14). The fee is 30 MCI. The annual effective rate may not exceed a cap set by a joint act of the ARDFM and the NBK (Art. 5).

Payment Organisations

Payment services without the required licence or registration are prohibited, and services provided that way are void (Law on Payments, Arts. 13, 15).

Capital must be formed in tenge and in cash before the application (Art. 15-1). A second category application includes the charter, proof of capital, the agreement with the settling bank, internal AML control rules, the operating rules, and evidence of a head of IT and a compliance officer (Art. 16(2)). The company must apply within one year of its state registration (Arts. 15-4, 17). Organisations already on the register are to be told by the NBK, within three months of the amendments taking effect, that they are second category (Law No. 352-VIII, Art. 2). The amendments took effect 60 days after publication on 21 August 2026.

AIFC Route

AFSA authorises banking, insurance, investment, payment and digital asset activities in or from the AIFC. Base capital is USD 10 million for a bank and USD 2 million for a credit provider. The AIFC Framework Regulations set no deadline for licence decisions, and AFSA states an average of about two to three months from a materially complete application. An AFSA licence does not replace national authorisation for retail operations in Kazakhstan. AIFC participants may have a corporate income tax exemption until 1 January 2066 on qualifying financial and ancillary services. See AFSA Licensing.

Ongoing Obligations and Renewals

There is no periodic renewal. Licences have no expiry date unless Annex 1 of the Law on Permits says otherwise (Art. 29(7)), and a banking licence is expressly unlimited. Obligations continue instead:

• Re-issue. Apply within 30 calendar days of a change that triggers it, such as a change of name (Law on Permits, Art. 33). For a bank the ARDFM has 15 working days (Art. 19(17)).
• Changes. A bank files documents on a change of name or location within 14 calendar days (Art. 7(6)) and reports changes among 10% holders within 15 calendar days (Art. 9(10)). A second category payment organisation reports changes to its documents within ten calendar days (Art. 16(7)).
• Executives. Bank executives must meet Art. 9-4 of Law No. 474-II, including five years of experience for the chair of the board and three for the chief accountant.
• Suspension and revocation. Grounds for a bank include false licensing data, three or more breaches within twelve months, and twelve months without licensed activity (Art. 83). An appeal does not suspend the decision (Art. 133).

Common Mistakes by Foreign Investors

• Assuming a payment business only needs registration. Issuing e-money and transfers without an account are first category services and need an NBK licence.
• Treating an AFSA licence as national coverage. It covers activity in or from the AIFC, not retail business across Kazakhstan.
• Crossing 10% without consent. The holder may not vote and can be ordered to sell within six months (Banks Law, Art. 9(8)). Indirect holdings count.
• Letting a deadline lapse. The one-year window for a bank and the six-month windows for insurers and microfinance organisations run from a fixed date, and missing them undoes the earlier work.
• Planning non-cash capital. Banks, insurers, microfinance and payment organisations must be funded in money, in tenge.

Frequently Asked Questions

Who licenses banks in Kazakhstan?

The ARDFM licenses banks and branches of foreign banks. The NBK is the central bank and sets macroprudential standards. It licenses only exchange offices and cash collection companies among banking operations (Law No. 258-VIII, Art. 19(23)).

How long does it take to open a bank?

The statutory periods add up to 95 working days: 65 for the permission and 30 for the licence. Real timing is longer because the periods stop for comments and do not cover registration, capital payment and operational readiness. The founders have one year from the permission to apply for the licence.

Can a foreign bank open a branch in Kazakhstan?

Yes, if the parent has assets of at least USD 10 billion and meets the conditions in Art. 15 of the Law. The branch needs a permission and a universal licence. It cannot hold a basic licence.

Is a payment organisation licensed or registered?

Both now exist. Since October 2026 first category organisations hold an NBK licence and second category organisations are registered with the NBK. Which applies depends on the payment services offered.

Do financial licences have to be renewed?

No. They run without a time limit, but they must be re-issued after certain changes and can be suspended or revoked.

Experience

Related Pages

Regulatory Licensing in Kazakhstan →
Fintech & Digital Assets →
AML/CFT Compliance →
AFSA Licensing →
AFSA Banking & Credit Licensing →
AFSA Payment Services Licensing →

Discuss your licensing matter

Bond Stone prepares licence applications and regulatory filings before the ARDFM, the NBK and AFSA. It holds AIFC Legal Adviser status. Contact us at [email protected].

Request a Confidential Consultation ← Licensing Hub Pharmaceutical Licensing →

Primary sources: zakon.uchet.kz — Law No. 258-VIII of 16 January 2026; Law No. 352-VIII of 23 July 2026; Law No. 474-II; Law No. 126; Law No. 461; Law No. 56-V; Law No. 11-VI; Law No. 202-V; Tax Code No. 214-VIII Art. 616; ARDFM Resolutions Nos. 41, 85 and 124 of 2026; NBK Resolutions Nos. 304 (2016), 80 (2018), 192 (2019) and 129 (2020). AIFC rules: aifc.kz.