Kazakhstan: An Overview

Kazakhstan plays a prominent role in Central Asia and is reinforcing its position as an investment destination connecting the region with businesses in both Western and Eastern markets. The country has extensive natural resources, a strategic location, and ongoing economic diversification, and continues to update its regulatory environment in ways that may shape investment and business planning in 2026 and beyond.

Special Legal Frameworks

The AIFC

Established in 2015, the Astana International Financial Centre (AIFC) was designed to attract investment and support cross-border business. While operating within Kazakhstan’s broader civil law environment, the AIFC applies a framework based on English common law principles and is supported by dedicated institutions, including the Astana Financial Services Authority, the Companies Registrar, the Astana International Exchange, the AIFC Court, and the International Arbitration Centre.

The AIFC is not limited to financial services. It also enables the incorporation of companies for non-financial purposes (eg, holding structures) used for operations in Kazakhstan and internationally. For many foreign investors, the AIFC may feel familiar, due to its common law orientation.

Alatau City

In September 2025, the president of Kazakhstan issued a decree granting Alatau (approximately 47 km north of Almaty) special status as an advanced development city. The initiative is positioned as an innovation-focused development project, including the potential use of advanced technologies (eg, digital assets and smart city solutions) and international management practices.

A draft constitutional law on Alatau’s special status was submitted to parliament at the end of 2025 with the aim of completing parliamentary hearings by the end of March 2026. Presidential support of the Alatau City project brings a sense of confidence that the draft law will be adopted with all its embedded ideas.

Based on the current draft, Alatau would operate under city-specific legislation (the constitutional law and regulations adopted by the Alatau administration) within Kazakhstan’s legal system. Where ambiguity or conflict arises with other national-level regulations, Alatau rules would apply, while ratified international treaties would take precedence. The draft also contemplates a stability safeguard intended to protect existing residents, licences and contracts from materially adverse regulatory changes for ten years (subject to stated exceptions).

The draft further outlines investor protections and a dispute-resolution pathway, including the option to pursue arbitration if a dispute is not resolved through negotiations within a specified period. It also contemplates a framework for digital-asset regulation, a transition to blockchain-based registries for real estate and other registrable rights, and the use of international construction standards and recognised foreign permits, subject to core safety requirements.

Digitalisation

Kazakhstan has identified digitalisation as a policy priority, with 2026 declared the Year of Digitalization and Artificial Intelligence. Several initiatives under discussion or expected to take effect in 2026 may shape compliance expectations and market opportunities.

Digital Code

The Digital Code takes effect on 11 July 2026. The Code is intended to modernise the legal framework for personal data protection, regulate the use of AI, and introduce rules for smart contracts, digital identification, and advanced cybersecurity tools. If implemented as planned, it may bring Kazakhstan’s cyberprotection closer to international standards and provide a clearer baseline for technology-enabled business models.

Digital assets

Kazakhstan currently regulates digital assets under a dual-track framework. Within the AIFC, cryptocurrencies are recognised as an independent asset class, and licensed providers may operate exchanges and admit assets to trading under a dedicated supervisory regime. Outside the AIFC (in the general jurisdiction), the approach has been more conservative, including restricting the issuance and circulation of unsecured digital assets (including cryptocurrencies).

A new legal framework for the general jurisdiction is expected to enter into force in 2026. If enacted, it will introduce a more detailed regime that distinguishes between two categories:

• Financial digital assets (stablecoins, digital assets backed by financial assets other than money, and financial instruments in digital form) – these would be permitted to be issued and circulated only on digital financial asset platforms or trading platforms operated by entities registered with the National Bank of Kazakhstan.
• Unsecured digital assets (cryptocurrencies), including those obtained through digital mining – these would be permitted to circulate outside the AIFC only through operators of unsecured digital asset exchanges or digital asset trading platforms that are licensed or registered with the National Bank of Kazakhstan; however, they would not be recognised as a means of payment, as financial instruments, or as financial assets.

Banking Regulations

A new Law on Banks and Banking Activities, approved by parliament, is expected to be signed by the president in early 2026. The law will modernise the licensing, operational and technology framework, including how banks may engage with fintech and AI-enabled tools.

The law introduces a two-tier licensing model:

• a basic banking licence for more limited banking activity, subject to statutory and regulatory caps; and
• a universal banking licence for the full range of banking and related operations, subject to general prudential, governance and conduct requirements.

The law also introduces an “Islamic window” concept enabling a conventional bank with a universal licence to offer Islamic products without establishing a separate legal entity, subject to ring-fencing (segregated assets, separate accounting, and no cross-subsidisation) and governance requirements (including a Sharia governance body).

On technology, banks and non-resident bank branches may use AI for risk assessment and risk management but remain responsible for AI-driven decisions. The law also permits banks (within limits) to invest in or establish entities providing financial and payment services using AI, blockchain and other innovative technologies, as well as certain supporting services such as software development, cloud computing, cybersecurity/anti-fraud tools, biometric authentication, and specified internet-platform intermediation models.

Natural Resources

Kazakhstan’s natural resources sector remains a key driver of the economy and foreign investment. The legal regimes governing mining and oil and gas differ, and the principal legislative act regulating subsoil use is the Code on Subsoil and Subsoil Use (the “SSU Code”), which came into force on 29 June 2018.

Mining

Kazakhstan’s mining framework was significantly reformed through the SSU Code, including a shift to a “first come, first served” licensing approach that replaced the prior contract-based system. The sector has also seen growing international attention on rare earth elements and other critical minerals.

In 2025, Kazakhstan established an Agency for Atomic Energy reporting directly to the president. The Agency now oversees sectoral policy and regulates uranium exploration and mining – functions previously under the Ministry of Industry and Construction. Amendments to the SSU Code adopted in the same period tightened the regulatory framework and consolidated state control over uranium mining in favour of National Atomic Company Kazatomprom JSC.

Further structural changes are anticipated in the coal industry, with regulatory oversight expected to transfer from the Ministry of Industry and Construction to the Ministry of Energy.

For more on the coal industry in Kazakhstan, see the relevant chapter in Chambers 2026 Mining Global Practice Guide.

Oil and gas

Kazakhstan’s major oil and gas fields were largely discovered when the country was still part of the Soviet Union. Since independence, the focus has been on appraising and developing known reserves and bringing additional fields into production. As mature fields approach depletion, the state is seeking to attract upstream investment through measures such as state-funded geological exploration, new contractual models for underexplored areas, and targeted incentives for complex projects.

In parallel, Kazakhstan is prioritising higher value-added production, with petrochemicals identified as a strategic focus. A dedicated law on the petrochemical industry is expected in 2026, although the current focus is described as primarily on gas chemistry rather than the full petrochemical value chain.

Environment

A significant reform of environmental regulation was implemented in 2021, introducing a more stringent framework and increasing administrative and financial liability for breaches, including pollution-related offences. One notable trend in the natural resources sector has been increased enforcement and higher environmental fines, including substantial penalties imposed on major subsoil users. In practice, this has increased the importance of environmental permitting discipline and ongoing compliance monitoring for companies operating in Kazakhstan.

Further information can be found in the Kazakhstan chapter of the Chambers 2025 Environmental Law Global Practice Guide.