Kazakhstan

Licensing, Authorisation & Market Access

From 1 May 2026, Kazakhstan's Law on Digital Assets brought crypto-exchange operators and digital-financial-asset trading platforms formally into the National Bank of Kazakhstan's market-access perimeter. Crypto-exchange operators must obtain an NBK licence, while DFA trading-platform operators complete an NBK registration procedure. This is confirmed by primary NBK communication and represents a closure of what had previously been a licensing gap for exchange-type activity conducted outside the Astana International Financial Centre.

The AIFC retains its own separate legal framework and AFSA licensing track for organisations operating within its jurisdiction, running parallel to the national NBK perimeter. This dual-track structure means a crypto-asset firm operating in Kazakhstan may fall under one of two distinct licensing regimes depending on whether it is established within or outside the AIFC's jurisdiction. This claim rests on a single T3 secondary source and has not been independently re-verified against AFSA's own publications this cycle, a gap flagged in the underlying research; the existence of the AIFC's separate framework is well established as a standing structural feature, but the precise current scope of AFSA's crypto-asset licensing activity carries lower confidence than the national NBK action.

For market-access purposes, the practical effect of the May 2026 change is that Kazakhstan has moved from a partially unregulated national perimeter for crypto-exchange activity to a fully licensed one, while preserving the AIFC as an alternative entry channel. This tightening/formalising direction is consistent with the broader payments-market pattern of expanding regulatory perimeter observed elsewhere in Kazakhstan's payment-organisation registration regime this cycle.

Outlook

Watch for whether firms operating across both the AIFC and the national perimeter face inconsistent licensing or supervisory expectations, and whether AFSA publishes updated guidance responding to the national Digital Assets Law's implementation. The single-source basis for the AIFC/AFSA parallel-channel characterisation should be treated as provisional pending independent re-verification.

Licensing, Authorisation & Market Access

Kazakhstan's Parliament adopted a new Law On Banks and Banking Activities on 25 December 2025, submitted to the President for signature and set to enter into force 60 calendar days after signing and official publication. This is the enabling instrument integrating digital-tenge accounts and the National Bank's National Digital Financial Infrastructure directly into the bank-licensing framework, marking the most significant licensing and market-access development for Kazakhstan this cycle. The reform is bank-centric in structure: it operates through the existing licensed-bank channel rather than creating a parallel non-bank licence for digital-tenge account provision, meaning the bank-versus-non-bank distinction that runs through this module remains material — digital-tenge integration is being built into bank licensing conditions rather than opened as a separate non-bank payment-institution or e-money-institution pathway. Assessed-confidence reporting characterises the reform as part of a coordinated national push to embed CBDC-linked payment functionality into mainstream bank licensing ahead of a fuller rollout.

The law's practical market-access implication is sequencing rather than eligibility: existing licensed banks will need to absorb new digital-tenge account and infrastructure-integration conditions within the 60-day post-publication commencement window, rather than facing a wholly new application process. No evidence was located this cycle of a parallel licensing track opening for non-bank entrants specifically to provide digital-tenge services.

Sourcing for this finding rests on Tier-4 secondary law-firm reporting; the primary text of the new Banking Law has not yet been cross-checked directly against a National Bank of Kazakhstan publication, which is a material gap in verification for a development of this significance.

Outlook

The near-term milestone is the law's entry into force, 60 days after presidential signature and official publication. Confirmation against a National Bank of Kazakhstan primary publication would materially strengthen confidence in the specific licensing conditions attached to digital-tenge integration. Watch for whether any non-bank licensing pathway is opened alongside the bank-centric integration model.

Licensing, Authorisation & Market Access

Kazakhstan's digital-financial-asset regime shifted to a systemic dual-track model on 1 May 2026, per Tier-1 National Bank of Kazakhstan primary sourcing. The National Bank of Kazakhstan licenses cryptoasset exchanges and digital-financial-asset platform registration, applicable across both bank and non-bank market participants, while the Agency for Regulation and Development of the Financial Market supervises non-stablecoin digital-financial-asset turnover specifically for non-bank payment-institution and e-money-institution-type entities. The pre-existing AIFC/AFSA regime continues to operate in parallel, meaning market entrants must now navigate a three-way supervisory perimeter rather than the prior single-track structure. This distinguishes unsecured cryptoassets from digital financial assets for the first time under national law and is judged high-impact given the dual National Bank of Kazakhstan primary citations underpinning both the licensing scope and the supervisory split.

Outlook

A dedicated digital-asset market regulator is expected to begin operations in Kazakhstan in the second half of 2026, per Tier-3 reporting, alongside decree provisions reportedly authorising digital assets and stablecoins for cross-border settlement; the practical interaction between this prospective fourth institutional node and the existing NBK/ARDFM/AIFC-AFSA structure is the main item to watch next cycle.

Operational Resilience & Critical Infrastructure

The National Bank of Kazakhstan has stood up a National Digital Financial Infrastructure, including a unified QR-code standard and an interbank payment system, synchronised with the new Banking Law and the digital-tenge rollout. This is assessed-confidence reporting describing a foundational infrastructure build-out rather than an incremental upgrade to an existing rail. Separately, and on a more standing basis, the National Bank maintains a Payment Systems Registry, dividing payment systems into systemically important, important, and other categories under the Law on Payments and Payment Systems — a Tier-1-sourced, high-confidence structural feature that pre-dates this cycle's Banking Law reform but frames how the new infrastructure build-out will be classified and supervised. For operators and infrastructure providers, the bank-versus-non-bank distinction is again material here: the National Digital Financial Infrastructure is being built and operated by the National Bank itself, a public-sector critical-infrastructure model.

Outlook

Watch for the National Digital Financial Infrastructure's operational go-live relative to the new Banking Law's entry into force, and for confirmation of how the unified QR standard and interbank rail are classified within the existing tiered Payment Systems Registry once operational. No resilience-incident or outage-specific development was located for Kazakhstan this cycle.

Payment Corridor Dynamics

Kazakhstan's domestic payment-corridor infrastructure scaled materially this cycle. The National Bank's Instant Payment System now supports 24/7 phone-number and QR-code interbank transfers, confirmed by primary National Bank press communication. This upgrade positions instant, low-friction interbank transfer as a standard consumer capability across participating banks.

Alongside the instant-payments upgrade, a unified interbank QR acceptance scheme launched in November 2025 and has been scaling nationwide through 2026. The scheme allows a consumer to pay any participating merchant from any bank's mobile application, regardless of which bank the consumer or merchant holds their account with, corroborated by trade-press reporting. This interoperability removes a friction point that previously required consumers and merchants to align on a single bank's QR ecosystem, and it is a significant driver of domestic retail-payments consolidation around bank-operated rails rather than card-network or third-party wallet rails.

The Interbank Money Transfer System underpins this corridor activity structurally: it is designated a systemically important payment system under the Law on Payments and Payment Systems, and processes over 97 percent of foreign-exchange-market, securities-market, and banking-sector payments nationally, per the National Bank's own payment-systems register. The combination of a systemically important settlement backbone and a rapidly interoperating instant/QR retail layer indicates that Kazakhstan's domestic payment-corridor dynamics are consolidating around bank-centric, NBK-supervised rails rather than fragmenting across competing private schemes.

Outlook

Watch for further nationwide scaling milestones of the unified interbank QR scheme through the remainder of 2026, and for any NBK disclosure of transaction-volume metrics that would allow independent verification of adoption rates. The corridor dynamics observed this cycle suggest continuity of the current trajectory rather than an inflection point.

Product Innovation & Market Development

The unified interbank QR acceptance scheme, launched in November 2025 and scaling nationwide through 2026, is the clearest product-innovation signal for Kazakhstan this cycle. Corroborated by trade-press reporting, the scheme standardises merchant QR acceptance across participating banks, letting a consumer pay from any bank application at any participating merchant. This is a genuine product-level development distinct from the structural market-access licensing change covered elsewhere, since it concerns how payments are made and accepted rather than who is permitted to provide payment services.

A separate, lower-confidence signal concerns the digital tenge. A single lower-tier source reports that January 2026 banking-law amendments formally recognise the digital tenge as national fiat currency. This claim carries Uncertain confidence and rests on a single T4 source not independently corroborated by a T1 or T2 source this cycle; it should be read as a monitored signal rather than a confirmed regulatory fact. If accurate, formal fiat recognition of a central-bank digital currency would be a significant product-and-legal-status development, but the evidentiary basis for it is currently thin.

Outlook

Watch for independent T1/T2 corroboration of the digital-tenge fiat-recognition claim, since its current single-source basis leaves it unconfirmed. Watch also for further merchant-acceptance and transaction-volume disclosures from the unified QR scheme as it continues its nationwide rollout through 2026.

Product Innovation & Market Development

The digital tenge moved decisively from pilot instrument to mandated practical-use instrument within this single cycle, marking one of the clearer central-bank-digital-currency product-development milestones tracked across the monitor this year. By early 2026, approximately 336.6 billion tenge, equivalent to roughly $640 to $700 million, had been issued across more than one hundred pilot projects, establishing a substantial base of prior experimentation. Building directly on top of that pilot base, and following the digital tenge's formal legal-status recognition as the third form of the national currency, the government is reported to have mandated digital-tenge use for eight categories of budget expenditure exceeding 100 million tenge (approximately $184,000), including infrastructure spending, budget lending, subsidies and procurement, effective from August 2026.

This budget-expenditure mandate is the more commercially and structurally significant of the two related developments for product-development purposes, because it converts the digital tenge from an optional or experimental payment rail into one with guaranteed transactional volume driven by mandatory government use. A CBDC that is mandated for large categories of state spending has a materially different adoption trajectory than one relying purely on voluntary consumer or merchant uptake, and this mandate should be read as a deliberate government strategy to seed real transaction volume through its own procurement and spending channels rather than waiting for organic private-sector adoption.

The key judgment applicable here is that Kazakhstan is positioning itself as a regional CBDC leader through this pilot-to-mandate trajectory, a strategy that stands in explicit contrast to Kyrgyzstan's alternative approach of a gold-backed stablecoin model. Where Kyrgyzstan has pursued asset-backed stablecoin issuance, Kazakhstan has pursued direct central-bank digital currency issuance backed by state mandate, a materially different product-development and market-structure path within the same regional neighbourhood. This divergence in regional CBDC/stablecoin strategy is itself a notable product-innovation data point, distinct from any single national development on its own.

Outlook

The key product-development test for next cycle is whether the budget-expenditure mandate is executed as described from August 2026, and whether transaction volumes attributable specifically to mandated government use become distinguishable from organic pilot-project volume in subsequent National Bank or National Payment Corporation reporting. Any broadening of the mandate beyond the initial eight budget-expenditure categories would be a further escalation of this product-development trajectory worth tracking closely.

Product Innovation & Market Development

Kazakhstan's product-innovation trajectory this cycle runs on two parallel tracks. First, the President has urged lawmakers to develop a comprehensive digital-assets legal framework by 2026, with a National Digital Asset Fund under the National Bank's Investment Corporation as its centrepiece — an assessed-confidence signal that state-directed digital-asset product development is the leading edge of this market. Second, the National Bank's cryptocard project, launched 3 June 2025 and now a completed, high-confidence, Tier-1-sourced development, enables payment cards for non-cash transactions funded from wallets held on AIFC-licensed crypto exchanges — a concrete product bridging licensed digital-asset custody and mainstream card-payment rails.

Taken together, these developments describe a market where the state is actively shaping the product roadmap for digital-asset-linked payments rather than leaving product innovation to private AIFC-licensed operators alone. The National Digital Asset Fund, if implemented as announced, would give the National Bank's Investment Corporation a direct participation vehicle in digital-asset markets, distinct from AIFC's existing licensing-based approach.

Outlook

The 2026 deadline the President has set for a comprehensive digital-assets legal framework is the key date to track; whether the National Digital Asset Fund materialises as a National Bank Investment Corporation vehicle, and how it relates institutionally to the AIFC's existing licensing regime, will determine whether Kazakhstan's product-innovation model becomes more state-directed or remains split between a state track and a private AIFC-licensed track.

Correspondent Banking, Settlement & Access

The Interbank Money Transfer System is Kazakhstan's structurally central settlement system, designated systemically important under the Law on Payments and Payment Systems and confirmed via the National Bank's own payment-systems register. It processes over 97 percent of foreign-exchange-market, securities-market, and banking-sector payments in the country, a concentration that makes it the de facto backbone of correspondent and interbank settlement nationally.

This module's analytical spine is the asymmetry between bank and non-bank access to settlement infrastructure, and the evidence this cycle reinforces rather than disturbs that asymmetry: the systemically important designation attaches to a bank-centric settlement system, and the new crypto-exchange/DFA licensing regime tracked under market access operates as a separate, parallel structure rather than as direct participants in the IMTS itself. No claim located this cycle indicates non-bank payment institutions or crypto-asset operators have gained direct settlement access to the IMTS; their market-access route continues to run through NBK licensing and registration rather than through direct systemic-settlement participation.

Outlook

Watch for any future NBK decision extending direct or indirect IMTS access to non-bank payment institutions or licensed crypto-exchange operators, which would represent a meaningful shift in the bank/non-bank settlement-access asymmetry that currently defines this module.

Correspondent Banking, Settlement & Access

The bank-versus-non-bank access asymmetry is the analytical spine of this cycle's correspondent-banking picture in Kazakhstan. Second-tier bank-PSPs were mandated into active de-risking against gambling-linked flows, blocking an assessed twenty-one million US dollars across roughly four hundred and two thousand transactions between October 2025 and March 2026, and freezing 1,144 mule-linked cards, following the March 2026 go-live of the ESU/NomadPay payment-centralisation mandate; this is a Tier-3-sourced, dashboard-level dated entry rather than a standing explainer, and no Tier-1 primary has yet been located for the underlying figures. On the non-bank PI/EMI side, bookmakers that missed the 5 March 2026 integration deadline, including Olimpbet, 1xBet, and Tennisi, lost payment processing outright, while early integrators Fonbet and Winline retained access. The result is a rapid, measurable bifurcation in correspondent-banking access tied directly to integration timing rather than to licensing status itself, since all affected bookmakers held equivalent underlying licences.

Outlook

The bifurcation between early and late integrators is likely to persist for as long as the payment-rail mandate remains the operative gate on market access; the absence of a Tier-1 primary source for the blocking and freezing figures remains a documentary gap worth monitoring for corroboration next cycle.

Commercial Intelligence & Fintech

The state-owned Unified Accounting System Operator LLP appointed private contractor NomadPay LLP as technical operator of Kazakhstan's betting-sector payment rail, an arrangement assessed as structurally significant: a single private contractor now controls the technical execution of the entire regulated betting-payment flow, a concentration risk for market entrants and payment-service providers alike that is independent of any question about the contractor's ownership. Kazakh media have separately alleged an affiliation between NomadPay and a Russian businessman, though no documentary evidence for this exists in Kazakh public registries; this allegation is carried at low confidence and treated as monitored rather than established. No deal value or investment figure is associated with this commercial arrangement in this cycle's sourcing, and no Tier-1 primary source has been located for the underlying contractor relationship.

Outlook

The concentration risk inherent in a single-contractor payment chokepoint remains a structural watch item independent of the unresolved ownership allegation; a Tier-1 primary source for the commercial arrangement, and any follow-on reporting on the ownership question, are the items to track next cycle.