PRACTICE AREA · KAZAKHSTAN
Regulatory Licensing in Kazakhstan
Bond Stone advises international and domestic businesses on regulatory licensing across all regulated sectors in Kazakhstan — financial services, pharmaceuticals, energy and subsoil use, construction, fintech and digital assets, and media and telecommunications. Ranked Legal 500 EMEA Top Tier and IFLR1000 Market Leader.
Kazakhstan's regulatory licensing framework is governed by the Law on Permits and Notifications (Law No. 202-V dated 16 May 2014, as amended). Operating in a regulated sector without the required licence is a ground for compulsory liquidation of a legal entity by court order (Civil Code, Art. 49), can put the validity of related transactions at risk, and carries administrative fines of up to 150 MCI, or 500 MCI for a repeat offence by a large business (Code of Administrative Offences, Art. 463), with criminal liability in serious cases (Criminal Code, Art. 214).
Bond Stone handles the full licensing lifecycle — from initial regulatory strategy and eligibility assessment through application preparation, document compilation, regulatory liaison, and ongoing licence compliance. The standard licence issuance term under Kazakhstani law is 15 working days from complete application submission.
For general business licensing as part of company formation in Kazakhstan, see Business Licences & Permits in Kazakhstan →
Kazakhstan Licensing Framework — Key Facts 2026
202-V
Law No. 202-V — primary licensing law, as amended
15 working days
Standard licence term under Art. 30, unless another period applies
6
Permit classes under Art. 23 of the Law
500 MCI
Maximum fine under Art. 463: repeat offence, large business
Licensing Services by Sector
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Financial Services Licensing Banking, payment organisations, microfinance, insurance, brokerage, exchange operations — ARDFM, National Bank of Kazakhstan and AFSA authorisations |
Pharmaceutical Licensing Manufacturing, wholesale, retail distribution, import/export of pharmaceutical products and medical devices |
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Energy & Subsoil Use Licensing Subsoil use contracts and licences, renewable energy permits, electricity purchase for supply and transmission licences |
Construction Licensing Category I–III construction activity licences, EPC contractor licensing, engineering survey, technical supervision |
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Architectural Design Licensing Design organisation licences (Category I–III), author's supervision rights, state expert examination for design documentation |
The Licensing Framework
Law No. 202-V — On Permissions and Notifications
The primary licensing framework is the Law on Permits and Notifications (No. 202-V dated 16 May 2014, as amended). The Law distinguishes licences (first-category permits), second-category permits and notifications. Article 23 also sorts permits into six classes by object: activities, objects, one-off permits, activities with limited resources or quotas, professional activities of individuals, and products. The annexes to the Law show the regime and the issuing authority for each activity.
Green corridor — fast-track for qualifying investments
The Rules for the one-stop shop for investors (Order of the Minister of Foreign Affairs No. 11-1-4/327 of 26 June 2023, restated by Order No. 11-1-4/313 of 8 June 2026) include a "green corridor" for investment projects that pass a points test on investment amount, investor, priority sector and social focus. Such projects receive state services on an accelerated basis set by the investment attraction council, and problems are taken to that council (Rules, paras. 20, 21, Annex 1). The Rules themselves grant no tax relief. Bond Stone advises on structuring investments to qualify for green corridor treatment.
eGov digital licensing platform
The majority of licence applications in Kazakhstan are now submitted and processed through the egov.kz government services portal. Digital submission requires valid electronic digital signature (EDS) for all authorised persons, correct classification of the activity under the relevant register of licences, and complete documentation upload in the formats accepted by the portal. Bond Stone manages the full digital submission process on behalf of clients.
Consequences of unlicensed activity
Operating without a required licence is a ground for compulsory liquidation by court order (Civil Code, Art. 49) and can put the validity of related transactions at risk. Fines under Article 463 of the Code of Administrative Offences reach 150 MCI for a large business, and 500 MCI for a repeat offence within a year. Criminal liability applies in serious cases under Article 214 of the Criminal Code. Bond Stone advises on urgent licence remediation where unlicensed activity has been identified.
Experience
Licensing · Kazakhstan · Fintech
NBK Payment Organisation Registration
Advising a fintech company on payment organisation registration with the National Bank of Kazakhstan — eligibility assessment, capital requirements, AML/CFT policy preparation, IT systems documentation, and regulatory liaison throughout the application process.
Licensing · Kazakhstan · Pharma
Pharmaceutical Wholesale Licence
Obtaining a pharmaceutical wholesale distribution licence for an international pharmaceutical company entering Kazakhstan — product registration coordination, GMP compliance documentation, and Ministry of Healthcare regulatory liaison.
Licensing · Kazakhstan · Construction
Construction Licence — Category I
Obtaining a Category I construction activity licence for a foreign contractor entering Kazakhstan — qualification document preparation, personnel certification, equipment compliance, and licensing authority engagement.
Licensing · Kazakhstan · Mining
Subsoil Use Licence — Minerals
Advising a mining company on subsoil use contract negotiation and licence conversion under Kazakhstan's Subsoil and Subsoil Use Code (2017) — licence structuring, work programme obligations, and Ministry of Industry and Construction liaison.
Licensing · Kazakhstan · Compliance
Licence Remediation — Urgent Advisory
Urgent licence remediation advisory for a Kazakhstan company identified as operating without a required sector licence — risk assessment, interim operational restructuring, expedited licence application, and regulatory engagement to avoid forced liquidation proceedings.
Licensing · Kazakhstan · Foreign Investment
Green Corridor — Investment Project
Structuring a foreign investment project to qualify for Kazakhstan's green corridor fast-track licensing mechanism — investment contract preparation, national pool application, and coordination with the Ministry of National Economy on expedited regulatory approvals.
Why Bond Stone for Regulatory Licensing
Full licensing lifecycle — strategy, eligibility assessment, document preparation, eGov submission, regulatory liaison, and ongoing compliance
All regulated sectors covered — financial services, pharma, energy, construction, mining, fintech, media
Green corridor fast-track structuring for qualifying investment projects
Ranked Legal 500 EMEA Top Tier and IFLR1000 Market Leader — Almaty and Astana offices
Related Industry Practices
Licensing is often the first step into Kazakhstan's most regulated sectors. See the industry guides.
Frequently Asked Questions — Regulatory Licensing in Kazakhstan
What is the primary law governing business licences and permits in Kazakhstan?
The Law on Permits and Notifications No. 202-V dated 16 May 2014 (as amended) governs the full licensing system in Kazakhstan. It separates licences (first-category permits, generally issued within 15 working days of a complete application under Art. 30) from second-category permits and notifications. The Law's annexes list regulated activities by category, issuing authority and permit class. Bond Stone advises on licence classification, application preparation, and pre-submission engagement with the issuing authority to reduce the risk of delay.
How long does it take to obtain a business licence in Kazakhstan?
The general period for a licence under Art. 30 of Law No. 202-V is 15 working days from a complete application, unless another period applies; financial licences, for example, have their own periods. Second-category permits have their own terms. For investment projects in the green corridor under the Rules for the one-stop shop for investors, state services are accelerated as the investment attraction council decides. Bond Stone advises on green corridor eligibility and manages the multi-agency coordination process for qualifying projects.
What are the consequences of operating without a required licence in Kazakhstan?
Unlicensed operation is an administrative offence under Article 463 of the Code of Administrative Offences. Fines for a large business are 150 Monthly Calculation Indices, and 500 for a repeat offence within a year; lower amounts apply to smaller businesses. It is also a ground for compulsory liquidation by court order, and serious cases can be criminal (Criminal Code, Art. 214). For regulated financial and digital asset activities, unlicensed operation additionally triggers ARDFM, National Bank of Kazakhstan or AFSA enforcement action. Bond Stone advises on regulatory risk and licence gap analysis at the outset of every market entry mandate.
What licences are required for a pharmaceutical company operating in Kazakhstan?
Pharmaceutical operations require sector-specific licensing under both Law No. 202-V and the Code on Public Health and the Healthcare System (No. 360-VI of 7 July 2020). Pharmaceutical activity, including manufacturing, wholesale and retail sale of medicines, is licensed (Code No. 360-VI, Art. 17(1)). Commercial import of medicines is open to licensed manufacturers, licensed wholesalers (and, for medical devices, wholesalers on the register by notification), research organisations and laboratories for registration work, and healthcare organisations for their own medical activity (Art. 252), and the products must be registered, nationally or under the EAEU rules. Each stage of the pharmaceutical supply chain has its own regulatory authorisation requirement. Bond Stone advises pharmaceutical clients on the full set of licences and the interaction between Kazakhstani requirements and international GMP standards recognised under Eurasian Economic Union harmonisation.
Do fintech and digital asset companies need a Kazakhstani government licence or an AFSA licence?
The applicable regulatory regime depends on where the entity is incorporated and operating. AIFC entities carrying on regulated activities need an AFSA licence — the AIFC has its own regulatory framework. Kazakhstani-incorporated companies providing payment services need a banking licence from the ARDFM or authorisation from the National Bank of Kazakhstan as a payment organisation, under the Law on Payments and Payment Systems (No. 11-VI of 26 July 2016). Since Law No. 352-VIII of 23 July 2026 there are two categories. A first category organisation (LLP or JSC) holds an NBK licence and can offer the wider range, including electronic money issuance and money transfers. A second category organisation (LLP) is registered with the NBK and offers a narrower range, such as accepting cash for payments, distributing electronic money and processing payments (Arts. 12, 13). The NBK is to reclassify organisations already on its register as second category. Since 1 May 2026, digital asset service providers outside the AIFC are licensed or registered by the National Bank. An AIFC entity actively soliciting Kazakhstani customers outside the AIFC perimeter may require additional notification or registration with Kazakhstani authorities. Bond Stone advises on the regulatory perimeter analysis and the optimal structure — AIFC or Kazakhstani entity — based on the business model and target market.
Discuss your licensing matter
Contact Bond Stone for a confidential discussion about regulatory licensing in Kazakhstan.
[email protected]
+7 (701) 729 76 72 — Almaty
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