LEGAL GUIDE \u00a0\u00b7\u00a0 2026 EDITION<\/p>\n
Astana International Financial Centre \u2014 2026 Edition<\/p>\n
The AIFC is an English common law jurisdiction operating within Kazakhstan \u2014 with its own companies registry, court system staffed by former UK Supreme Court and Court of Appeal judges, arbitration centre, and tax regime exempt from Kazakhstani CIT, VAT, and IIT until 2066. By end 2025 it had 4,954 participants from 91 countries, USD 6 billion raised through the Centre in 2025, and USD 10.58 billion in digital asset transaction volume. It is now a substantive international financial centre \u2014 not a regulatory sandbox.<\/p>\n
This guide is written for international investors, financial institutions, fintech companies, and legal counsel deciding whether and how to use the AIFC framework. It tells you what the AIFC is, what it is not, what changed in 2026, and what Bond Stone \u2014 as an AIFC Registered Legal Adviser \u2014 can do for you within it.<\/p>\n
Bond Stone AIFC practice \u2014 firm profile \u2192<\/a> \u00a0\u00b7 <\/p>\n AIFC \u2014 Key Facts 2026<\/p>\n 4,954<\/p>\n Participants from 91 countries \u2014 end 2025<\/p>\n<\/div>\n USD 6B<\/p>\n Raised through AIFC in 2025<\/p>\n<\/div>\n 2066<\/p>\n Tax exemption horizon \u2014 CIT, VAT, IIT<\/p>\n<\/div>\n 4,600+<\/p>\n AIFC Court and IAC cases completed<\/p>\n<\/div>\n<\/div>\n<\/div>\n <\/p>\n The five decisions every AIFC participant faces<\/p>\n 1. AIFC entity or Kazakhstan civil law entity?<\/p>\n An AIFC entity is governed by English common law, registered with the AIFC Registrar, subject to AFSA regulation (if providing financial services), and exempt from Kazakhstani taxes until 2066. A Kazakhstan civil law entity (LLP\/JSC) is governed by Kazakhstani law and subject to standard Kazakhstani tax. Most international investors benefit from at least an AIFC holding layer \u2014 even for non-financial investments \u2014 for governance, dispute resolution, and tax structuring purposes.<\/p>\n<\/div>\n 2. Which AIFC entity type?<\/p>\n AIFC Private Company (equivalent to English private limited company), AIFC Public Company, AIFC Limited Liability Partnership, AIFC Foundation (for private wealth and family office structures), or AIFC Branch (for foreign companies establishing a presence). Each has different governance requirements, capital rules, and AFSA licensing implications. Choice depends on activity, ownership structure, and intended use of the AIFC framework.<\/p>\n<\/div>\n 3. AFSA licence \u2014 which category?<\/p>\n Financial services within the AIFC require an AFSA licence. Six broad categories: banking and credit, capital markets (brokerage, dealing, advisory, underwriting), investment management (fund management, portfolio management), insurance, Islamic finance, and digital assets. Each category has specific capital, qualified personnel, systems, and compliance requirements. The wrong licence category \u2014 or missing a required category \u2014 creates regulatory exposure. Bond Stone advises on licence structuring before application.<\/p>\n<\/div>\n 4. FinTech Lab or full licence?<\/p>\n The AFSA FinTech Lab allows digital asset and fintech firms to test products and services within the AIFC regulatory framework before committing to full authorisation. 19 DASPs operated under FinTech Lab supervision in 2025. Seven firms successfully graduated to full regulatory mode. The Lab is a genuine pathway to authorisation \u2014 not a substitute for it. Bond Stone advises on whether a firm qualifies for FinTech Lab entry and on the graduation pathway to full authorisation.<\/p>\n<\/div>\n 5. AIFC Court or IAC arbitration?<\/p>\n The AIFC Court provides English common law litigation before judges of international standing \u2014 former members of the UK Supreme Court, Court of Appeal, and Hong Kong Court of Final Appeal. The International Arbitration Centre (IAC) provides institutional arbitration under UNCITRAL-based rules with awards enforceable under the New York Convention. AIFC Court judgments are directly enforceable across Kazakhstan without re-litigation. The choice between Court and IAC depends on the nature of the dispute, confidentiality requirements, enforcement needs, and counterparty jurisdiction. For AIFC-governed contracts, the Court is generally preferable for certainty and enforceability within Kazakhstan.<\/p>\n<\/div>\n<\/div>\n<\/div>\n AFSA regulatory amendments \u2014 effective 1 January 2026<\/p>\n AFSA introduced amendments to three core frameworks \u2014 capital markets, digital assets, and crowdfunding \u2014 effective 1 January 2026, following public consultation from 21 July to 15 September 2025. The amendments improve effectiveness, proportionality, and international alignment of the AIFC regulatory framework. AFSA introduced Feedback Statements for the first time as part of this process, marking a step toward greater regulatory transparency. Participants and prospective participants should review their existing licences and activities against the amended frameworks.<\/p>\n<\/div>\n 4,954 participants \u2014 25% growth in 2025<\/p>\n AFSA registered 1,467 new companies in 2025 \u2014 a 25% increase on 2024 \u2014 bringing total AIFC participants to 4,954 from 91 countries, averaging 28 new registrations per week. The AIFC has reached a scale that creates genuine network effects \u2014 the depth of financial services participants, legal advisers, and infrastructure now available within the AIFC ecosystem is materially greater than it was in 2022 or 2023.<\/p>\n<\/div>\n Digital assets \u2014 USD 10.58 billion transaction volume, first stablecoin licence<\/p>\n DASPs generated USD 10.58 billion in transaction volume in 2025 across a client base of 215,000 users. AFSA issued its first licence for the issuance of fiat-backed stablecoins \u2014 the first such licence in Central Asia. AFSA officially joined IOSCO’s I-SCAN fraud alert network, signalling continued integration with global securities regulation standards. The AIFC digital asset framework is now one of the most substantive in the CIS and Central Asia region.<\/p>\n<\/div>\n AFSA fee framework review \u2014 2026<\/p>\n AFSA launched a consultation on proposed regulatory fee updates in 2025 \u2014 the first revision since 2017. With the AIFC now supervising 510 financial ecosystem entities and USD 1.85 billion in assets under supervision in H1 2025 alone, fee increases are expected when the revised framework is confirmed. Participants should factor updated AFSA fees into their 2026 operating cost models.<\/p>\n<\/div>\n AFSA 2026 regulatory priorities<\/p>\n AFSA’s published 2026 regulatory agenda includes: Appointed Representative Framework (new category allowing AFSA-licensed firms to appoint representatives); Derivatives Framework amendments; Asset Management Framework review (Call for Evidence launched); Multilateral and Organised Trading Facility amendments; and updates to Fitness and Propriety Guidance. Bond Stone tracks all AFSA regulatory developments and advises participants on compliance implications as frameworks are revised.<\/p>\n<\/div>\n<\/div>\n Legal system<\/p>\n English common law \u2014 applied through the AIFC Contract Regulations 2017, AIFC Companies Regulations, and other AIFC Acts. The AIFC Court applies English common law as developed by English courts. AIFC law operates independently of Kazakhstani civil law within the AIFC territory.<\/p>\n AIFC legal services \u2192<\/a><\/p>\n<\/div>\n Tax environment<\/p>\n AIFC participants exempt from Kazakhstani CIT, VAT, and IIT on qualifying AIFC activities until 1 January 2066. No customs duties on goods imported for AIFC activities. No currency restrictions. The 50-year tax exemption horizon is the single most powerful AIFC structural advantage for international investors.<\/p>\n AIFC tax residency programme \u2192<\/a><\/p>\n<\/div>\n AIFC Court<\/p>\n Staffed by former UK Supreme Court and Court of Appeal judges. Applies English common law. Judgments directly enforceable across Kazakhstan without re-litigation. 4,600+ cases completed. Increasingly used by international parties for commercial disputes with Kazakhstan nexus \u2014 not only by AIFC participants.<\/p>\n AIFC Court proceedings \u2192<\/a><\/p>\n<\/div>\n AFSA regulation<\/p>\n 510 financial ecosystem entities regulated by AFSA. 6 broad licence categories: banking, capital markets, investment management, insurance, Islamic finance, digital assets. FinTech Lab sandbox pathway for innovation. Amended frameworks for capital markets, digital assets, and crowdfunding effective 1 January 2026. Fee framework under revision.<\/p>\n AFSA licensing advisory \u2192<\/a><\/p>\n<\/div>\n Who uses the AIFC<\/p>\n International investors using AIFC as a holding structure for Kazakhstan and Central Asia investments. Fintech and digital asset companies seeking regulated market access in the CIS. Fund managers establishing investment vehicles. Banks and insurance companies establishing AIFC presence. Professional services firms (legal, accounting, consulting) serving the AIFC ecosystem. Chinese, Gulf, European, and US companies entering Central Asia via the AIFC gateway.<\/p>\n AIFC entity formation \u2192<\/a><\/p>\n<\/div>\n What the AIFC is not<\/p>\n The AIFC does not replace Kazakhstan civil law for activities outside the AIFC territory. A company registered in the AIFC conducting business in Kazakhstan (outside the AIFC) remains subject to Kazakhstani law and taxes for those activities. The tax exemption applies to qualifying AIFC activities \u2014 not to all activities of an AIFC-registered entity. Correct structuring of the boundary between AIFC and Kazakhstan activities is essential.<\/p>\n AIFC compliance advisory \u2192<\/a><\/p>\n<\/div>\n<\/div>\n AIFC Registered Legal Adviser status<\/p>\n The AIFC Registered Legal Adviser (RLA) designation is held by our partners personally \u2014 enabling them to advise on AIFC law and English common law and to appear before the AIFC Court. Bond Stone is the only Central Asia law firm ranked Legal 500 EMEA Top Tier and IFLR1000 Market Leader that also holds RLA status \u2014 meaning clients receive both Kazakhstani law and AIFC\/English common law advice on a single mandate without coordinating separate counsel.<\/p>\n Bond Stone advises on AIFC entity formation, AFSA licensing across all categories, AIFC Court proceedings, AIFC regulatory compliance, and AIFC investment tax residency \u2014 from the Almaty and Astana offices.<\/p>\n<\/div>\n
\nAIFC legal services \u2192<\/a><\/p>\n
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\nWhat changed in 2025\u20132026<\/h2>\n
\nThe AIFC framework \u2014 what you need to know<\/h2>\n
\nBond Stone \u2014 AIFC Registered Legal Adviser<\/h2>\n
AIFC legal services<\/h2>\n