title: Kazakhstan Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/kazakhstan/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # Kazakhstan KZ schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 75 sourced findings · 146 sources in the cumulative register 14 Modules baseline.modules[] 75 Findings modules[].findings[] 23 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Kazakhstan's payments infrastructure moved through a concentrated liberalisation window this cycle. The National Bank of Kazakhstan will begin issuing a new first-category payment-organisation licence from October 2026, a licence class that permits independent account opening, card issuance, and cross-border transfer without requiring bank intermediation. More than ten prospective applicants are reportedly preparing filings for this new category, signalling that non-bank entry into payment-organisation status is being treated by the market as a live opportunity rather than a theoretical option. This licensing move sits alongside two already-delivered pieces of national payments infrastructure: the digital tenge, which entered circulation on 18 July 2026 issued solely by the National Bank and accessed through existing bank applications, and the Interbank Mobile Payment System, launched nationwide the following day, which by 11 September 2026 had processed 20 million transactions worth approximately 400 billion tenge, or roughly 887 million US dollars. Together, the new non-bank licensing category and the two live infrastructure launches describe a state-directed push to formalise and modernise Kazakhstan's payment rails outside the traditional bank-led model, while keeping the National Bank as the central architect of both the licensing perimeter and the settlement infrastructure itself. #### Other Developments **A July 2026 presidential decree authorised stablecoin and digital-asset use in cross-border import and export settlement.** The mechanism operates alongside, rather than replacing, existing banking channels, and was paired with a personal-income-tax exemption on digital-asset trading income conducted through licensed domestic platforms. The Astana Financial Services Authority has also piloted accepting licence and supervision fees in USD-pegged stablecoins, an operational signal that stablecoin settlement is being tested within Kazakhstan's own regulatory-fee infrastructure, not only authorised for private cross-border trade. **VEON, through its Kazakhstan subsidiary KaR-Tel, signed a memorandum of understanding with the National Bank exploring a first-category payment-organisation licence.** The agreement was signed at the Central Asia Fintech Summit 2026 in Almaty and is reported as an early, specific commercial move tied directly to the new licensing category rather than a general statement of market interest. No transaction value has been disclosed in connection with this memorandum. #### Cross-Monitor Connections The same July 2026 presidential decree authorising stablecoin cross-border settlement is also material to financial-integrity analysis of Kazakhstan's AML/CFT perimeter, since a cross-border settlement channel routed through stablecoins rather than conventional correspondent banking raises a control-maturity question that sits outside this monitor's payments-infrastructure lens. Similarly, the new first-category payment-organisation licensing regime and the national digital-asset exchange licensing channel opened under separate legislation this same period both expand Kazakhstan's non-bank financial-services perimeter at the same time, a coincidence of timing that is itself a structural signal about the direction of Kazakhstani financial-sector policy this year. #### Outlook The clearest near-term marker to watch is the volume and identity of entities actually granted first-category payment-organisation licences once the National Bank begins issuing them in October 2026, which will indicate whether the more-than-ten reported prospective applicants convert into licensed, operating entities, and whether VEON/KaR-Tel's memorandum of understanding advances to a formal application. On the infrastructure side, continued growth in Interbank Mobile Payment System transaction volumes beyond the 20 million transactions recorded by 11 September 2026 would confirm sustained adoption of the interoperable QR and phone-number transfer rails, rather than an initial launch spike. _6 earlier updates not shown here._ ###### Standing brief · as of 4 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Kazakhstan enters the World Payments Monitor's jurisdiction spine this cycle with a first baseline synthesis spanning all fourteen modules, anchored by a corrected reading of the country's New Law on Banks and Banking Activities. President Tokayev signed the New Banking Law on 16 January 2026, and it entered into force roughly sixty days later, around 17 March 2026, introducing a two-tier basic/universal bank licensing system and formalising a digital-financial-asset and stablecoin legal category under National Bank of Kazakhstan oversight. This corrects an earlier baseline research draft that had characterised the law as still pending presidential signature; the correction is corroborated by parallel reporting describing enacted provisions. The reform sits atop an existing dual-track market-access architecture: the national Law on Payments and Payment Systems, in force since 2016, governs registration and licensing of payment organisations directly, running in parallel to the AIFC's separate Astana Financial Services Authority authorisation track, while non-bank payment organisations must complete National Bank registration before rendering payment services, with unregistered activity attracting statutory liability. The same in-force law carries a behavioural-supervision conduct regime shifting bank oversight from financial metrics toward fair treatment of clients, paired with a two-step complaint process escalating to a Unified Financial Ombudsman, though the ombudsman's operative commencement date is not yet independently confirmed. Layered onto this licensing reform is a second correction: Kazakhstan's digital-asset regime has moved from an AIFC-confined model to a unified nationwide framework, following a November 2025 amendment removing the Astana International Financial Centre-only restriction and the now-in-force New Banking Law's formal recognition of digital tenge and stablecoin issuance under National Bank oversight. The AIFC's own Astana Financial Services Authority stablecoin framework, it turns out, has been operative since 1 January 2024 rather than representing a future expansion as an earlier reading suggested. Taken together, these corrections mark Kazakhstan as a jurisdiction simultaneously liberalising bank and digital-asset market access while tightening conduct and anti-money-laundering supervision, a bifurcated regulatory trajectory that the jurisdiction risk tracker now formally logs as fragmenting. #### Other Developments Beneath the licensing headline, Kazakhstan's payments infrastructure and market structure show a mix of steady-state controls and live product rollouts. Critical-infrastructure operators continue to manage cyber risk under the 2015 Informatization Law, reinforced by a 2023-2029 national cybersecurity concept, while the National Bank's Anti-Fraud Center, launched in August 2024, blocks suspicious transfers and maintains a blacklist of suspicious mobile numbers. On the scheme side, the Interbank Money Transfer System remains the country's systemically important payment system, processing over 97% of FX, securities and banking-sector payments, with Visa classified separately as merely an important system in the same registry; card-data handling continues to run on PCI DSS as a scheme-mandated overlay rather than a domestic statute. Corridor dynamics carry the cycle's sharpest tension: Russia's Fast Payment System has expanded cross-border to include Kazakhstan among nine countries, with Kazakhstan ranking among the top five recipients of SBP transfer volume from Russia, even as the European Union's 19th sanctions package, adopted 23 October 2025, places VTB Bank Kazakhstan under a transaction ban for its connectivity to Russian financial-messaging and payment systems. Operational severance from those rails is not independently confirmed, and the National Bank has indicated the bank remains locally operational, so this finding is carried at Assessed rather than High confidence pending verification. Market structure remains heavily concentrated: of 23 licensed second-tier banks, the top five hold roughly 67% of sector assets, and government data indicates Kaspi.kz and Halyk Bank together handle approximately 80% of domestic payments, with fintech growth achieved through bank-led super-app ecosystems rather than standalone disruptors. On the legal and litigation front, VTB Bank Kazakhstan remains the country's only locally licensed institution appearing on a sanctions list following the 2022 restructuring of Sberbank, VTB and Alfa-Bank's Kazakh subsidiaries, while a 2025 addition to the Criminal Code criminalises transferring bank-account, e-wallet or internet-banking access to third parties for payments, with penalties up to five years' imprisonment. Merchant-acquiring regulation remains comparatively thin: no domestic interchange-fee cap, surcharging rule or high-risk merchant-category-code regime has been identified, leaving agent joint-and-several liability and scheme-level PCI DSS as the operative controls, a coverage gap logged for future targeted research. Product innovation continues to advance, led by the digital tenge, which is live for public-finance scenarios including a November 2025 road-repair financing programme jointly announced by the National Bank and Ministry of Finance, and by an upgraded Instant Payment System enabling 24/7 interbank transfers by mobile number or QR code. Consumer protection is consolidating around the pending Unified Financial Ombudsman's three-tier complaints system, replacing separate banking, insurance and microfinance mechanisms, alongside anti-fraud measures including money-mule criminalisation, though no UK-style mandatory reimbursement scheme for authorised-push-payment fraud has been identified. Correspondent-banking access remains structurally sound, underpinned by relationships with Citi, JPMorgan Chase and BNY plus an IMF Article VIII convertibility commitment requiring National Bank notification for transfers above $50,000, though this access base now sits alongside sanctions-driven de-risking pressure. Commercial activity in the trailing twelve months has been led by Kaspi.kz's international acceptance expansion, through partnerships with UnionPay International reaching near-full UnionPay card acceptance in November 2025 and with Alipay+ in August 2025, and by ForteBank's issuance of Kazakhstan's first international perpetual AT1 Eurobond in November 2025, advised by Dentons, though neither transaction's value has been publicly disclosed. #### Cross-Monitor Connections Two threads in this baseline carry significance beyond payments-market structure and are flagged to the Financial Intelligence Monitor rather than analysed here as illicit-finance conclusions. Kazakhstan's November 2025 anti-money-laundering reform package, comprising new money-mule criteria, a high-risk crypto-wallet registry, and blocking of unlicensed crypto exchanges effective 20 November 2025, is carried in this brief as Sentinel-fed provenance against the backdrop of Kazakhstan's 2023 FATF Mutual Evaluation rating of Substantially Effective on seven of eleven effectiveness criteria and its absence from the FATF strategic-deficiencies list. Separately, the EU transaction ban on VTB Bank Kazakhstan for Russian payment-rail connectivity, and the broader sanctions-enforcement posture visible in the country's legal and litigation theme, carry sanctions-evasion and illicit-finance dimensions that sit outside this monitor's payments-market-structure scope. Both threads intersect with Kazakhstan's correspondent-banking access, where sanctions-driven de-risking pressure is layered onto an otherwise structurally sound access base. #### Outlook Three dated items shape the forward view for Kazakhstan. The Unified Financial Ombudsman service is expected to become operational under the New Banking Law during the second quarter of 2026, which would formalise the consumer-dispute consolidation already underway. Full implementation of Open Banking and Open API product-access scenarios is expected in the fourth quarter of 2026, following a mid-pilot phase, extending the product-innovation trajectory visible in the digital tenge and Instant Payment System rollouts. And the operational status of VTB Bank Kazakhstan's connectivity to Russian payment rails remains an open verification point: confirmation either way, continued connectivity or genuine severance, would resolve one of this baseline's soft-flagged confidence downgrades and clarify whether Kazakhstan's correspondent-banking access is entering a more acute de-risking phase or holding at its current managed-risk equilibrium. trust tier: ai_unverified ###### Latest update · 18 October 2026 #### Regulatory Status Kazakhstan's payments regulatory environment moved through a concentrated liberalisation window centred on mid-to-late 2026. The National Bank of Kazakhstan is introducing a new first-category payment-organisation licence class, issuance beginning October 2026, that permits independent account opening, card issuance, and cross-border transfer without bank intermediation, with more than ten prospective applicants reportedly preparing filings, including a named memorandum of understanding between VEON's Kazakhstan subsidiary KaR-Tel and the National Bank. Alongside this licensing liberalisation, the National Bank delivered two pieces of national payments infrastructure within the same week in July 2026: the digital tenge, a central bank digital currency entering circulation on 18 July 2026 and accessed through existing bank applications, and the Interbank Mobile Payment System, launched nationwide on 19 July 2026, which processed 20 million transactions worth approximately 400 billion tenge (roughly 887 million US dollars) by 11 September 2026. A July 2026 presidential decree further authorised stablecoin and digital-asset use in cross-border import and export settlement alongside conventional banking channels, paired with a personal-income-tax exemption for digital-asset trading income on licensed domestic platforms. #### Outlook The National Bank's issuance of first-category payment-organisation licences from October 2026 onward, and the conversion of reported applicant interest, including the VEON/KaR-Tel memorandum, into formal licence applications, are the clearest near-term indicators of how far this liberalisation extends in practice. Continued growth in Interbank Mobile Payment System transaction volumes beyond the 20-million-transaction mark recorded as at 11 September 2026 would confirm sustained adoption of the new interoperable payment rails. _4 earlier updates not shown here._ ###### Standing brief · as of 4 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Kazakhstan's payments-regulatory environment this cycle is defined by a first full-spine baseline synthesis carrying one dominant theme: simultaneous liberalisation of bank and digital-asset market access alongside tightening conduct and financial-crime supervision. The New Law on Banks and Banking Activities, signed 16 January 2026 and in force since approximately 17 March 2026, introduces two-tier basic/universal bank licensing, a behavioural-supervision conduct regime, a Unified Financial Ombudsman, and a formal digital-financial-asset/stablecoin category under National Bank oversight - correcting an earlier baseline position that had treated the law as still pending signature. Alongside it, a November 2025 amendment removing the AIFC-only restriction on digital-asset circulation, combined with the now-in-force New Banking Law, has produced a unified nationwide digital-asset regime running in parallel with the AIFC's own Astana Financial Services Authority stablecoin framework, in force since January 2024. Beneath these headline reforms, Kazakhstan's payments infrastructure rests on steady-state foundations: a 2015 critical-infrastructure cybersecurity statute and a 2024 National Bank Anti-Fraud Center; a Payment Systems Register designating the Interbank Money Transfer System as systemically important; and a heavily bank-led, concentrated market structure in which Kaspi.kz and Halyk Bank together handle roughly 80% of domestic payments. Kazakhstan's corridor and correspondent-banking posture is best described as managed-risk rather than either fully open or blanket de-risked: established correspondent relationships with major international banks and deep CIS/Russia payment-rail connectivity coexist with EU sanctions pressure on VTB Bank Kazakhstan, the country's only locally licensed sanctions-listed institution, whose actual operational severance from Russian payment rails remains unconfirmed. A November 2025 AML/CFT reform package, carried here via Sentinel-fed provenance, tightens the financial-crime perimeter around these same payment rails, while a parallel domestic money-muling criminal offence reinforces consumer-facing enforcement. Consumer protection is consolidating around the pending Unified Financial Ombudsman, and product innovation continues to advance through the live Digital Tenge and an upgraded Instant Payment System, with Open Banking/Open API rollout pending for late 2026. Commercial activity in the period was led by Kaspi.kz's international-acceptance expansion and ForteBank's first international AT1 Eurobond issuance. Two research gaps persist: no domestic merchant-acquiring/interchange regime has been identified, and no non-bank-specific correspondent-banking access finding has been identified to set against the bank-level picture. #### Outlook Three items will most shape Kazakhstan's regulatory trajectory over the coming two quarters: operationalisation of the Unified Financial Ombudsman (expected Q2 2026), full Open Banking/Open API implementation (expected Q4 2026), and resolution of the open question over VTB Bank Kazakhstan's actual connectivity to Russian payment rails. Kazakhstan's regulatory direction is best characterised as fragmenting - liberalising on bank and digital-asset licensing while tightening on conduct, AML/CFT and sanctions exposure - a pattern likely to persist as the New Banking Law's implementing provisions come into fuller operation. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved Confirmed confirmed 2026-07-04 A new 'first-category payment organisation' licence class under the National Bank, able to combine payment services with certain banking operations, took effect from October 2026. Movement — NEW First-category payment organisation licensing regime opens October 2026._New licensing regime identified this cycle._ Horizon · 2026-03-17 (±quarter) New Banking Law (two-tier bank licensing, DFA/stablecoin framework) entry into force_in_force · TT3_ Standing sub-brief · as of 4 July 2026 356 words · last cycle 2026-10-18 #### Licensing, Authorisation & Market Access Kazakhstan's payment-market access runs on a dual track. The national Law on Payments and Payment Systems (26 July 2016, No. 11-IV LRK) is the core statute governing organisation and oversight of payment systems and payment-services market regulation, operating alongside a parallel authorisation regime administered by the Astana International Financial Centre's Astana Financial Services Authority. Within the national track, the National Bank of Kazakhstan requires non-bank payment organisations to complete a registration process before rendering payment services; unregistered activity is illegal and attracts statutory liability, making registration the operative market-access gate for non-bank payment-service providers, distinct from the bank-licensing track. That bank-licensing track has just been substantially reformed. President Tokayev signed the New Law on Banks and Banking Activities on 16 January 2026, and it entered into force approximately sixty days later, around 17 March 2026, introducing a two-tier basic/universal bank licensing system and a digital-financial-asset/stablecoin legal category under National Bank oversight. This finding corrects an earlier baseline position that had described the law as still awaiting presidential signature; the correction is supported by corroborating reporting describing the law's enacted provisions, and both the signing event and the entry-into-force timeline are now treated as settled rather than pending. The practical effect is a bifurcated but converging market-access architecture: banks now face a two-tier licensing calculus determining prudential scope, while non-bank payment organisations continue to operate under the registration-based gate that has applied since 2016, and AIFC-domiciled participants retain a third, parallel authorisation route through AFSA. Firms assessing Kazakhstan market entry should expect the bank-licensing tier question and the non-bank registration question to be resolved on materially different timelines and evidentiary standards, since one is now shaped by a freshly enacted statute while the other rests on longstanding NBK administrative practice. #### Outlook The New Banking Law's two-tier licensing system is now in force, but implementing regulations and NBK guidance on the basic/universal tier boundary have not yet been independently confirmed in this baseline; that operationalisation is the next milestone to track. The dual-track structure with AIFC/AFSA is expected to persist, since nothing in the current sourcing suggests convergence of the two authorisation regimes. Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access The National Bank of Kazakhstan is set to begin issuing a new first-category payment-organisation licence from October 2026. This licence class is reported to permit independent account opening, card issuance, and cross-border transfer by the licensed entity without requiring intermediation by a bank, a meaningful departure from a bank-led payments model in which non-bank payment institutions typically operate on a more constrained set of permissions or through a sponsor-bank arrangement. Market response has reportedly been immediate: more than ten prospective applicants are said to be preparing filings for the new category ahead of the October opening, indicating that the licence is viewed as commercially valuable rather than as a narrow regulatory accommodation. One specific applicant signal has surfaced directly: VEON, operating in Kazakhstan through its subsidiary KaR-Tel, signed a memorandum of understanding with the National Bank at the Central Asia Fintech Summit 2026 in Almaty to explore obtaining a first-category payment-organisation licence. A memorandum of understanding is a preparatory step rather than a licence application, and the agreement does not itself confer any authorisation; it signals intent and establishes a working relationship between VEON's Kazakhstan operations and the regulator ahead of the licence class becoming available. No commercial terms or investment figures were disclosed in connection with this memorandum. The structural significance of the new licence class lies in what it signals about the direction of market access policy in Kazakhstan's payments sector: a move toward enabling non-bank entities to hold a broader set of payment-processing permissions than has previously been standard, timed to coincide with the live rollout of the Interbank Mobile Payment System and digital tenge, both National Bank-led infrastructure projects. Read together with those infrastructure developments, the new licence class appears designed to broaden the base of entities able to build commercial payment products on top of the national rails, rather than confining that role to banks alone. #### Outlook The key test for this module going forward is how many of the reported more-than-ten prospective applicants actually file for, and receive, first-category payment-organisation licences once the National Bank begins issuing them in October 2026, and whether VEON/KaR-Tel's memorandum of understanding converts into a formal application. The pace and volume of licensing decisions in the months following October 2026 will indicate whether this is a narrow, slow-moving authorisation process or a genuine broadening of Kazakhstan's non-bank payments market. **5 earlier distinct update(s)** Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access The National Bank of the Republic of Kazakhstan's first-category payment organisation licence class came into force in October 2026, as confirmed both at the Central Asia Fintech Summit 2026 and in a statement from the National Bank Governor reported at an Akorda briefing. This new regulated-participant class permits holders to combine payment services with certain banking operations, a structural departure from the prior split between pure payment organisations and licensed banks. The Governor's framing emphasised competitive and cost objectives: the new class was introduced to promote competition and reduce costs for customers, suggesting the National Bank views the segment as under-served by the existing bank-versus-non-bank licensing split. No enforcement action or market-access dispute was reported alongside the new class's introduction, and no named first-category licensee has yet been confirmed. The regime's operative status as of October 2026 marks a liberalising shift in Kazakhstan's payment-market structure, expanding the range of institutions that can hold a combined payments-and-banking authorisation beyond the traditional bank licence. #### Outlook The practical significance of the first-category payment organisation class will depend on uptake: which firms apply, how the National Bank exercises its licensing discretion, and whether any applicant seeks to combine this new class with adjacent digital-asset or stablecoin activity given the parallel developments in Kazakhstan's digital-financial-asset regime this cycle. No timeline for a first licensee has been confirmed. Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access The National Bank of Kazakhstan's first-category payment-organisation licence commences October 2026, a confirmed structural change permitting non-bank entities to hold customer accounts and issue cards without a bank charter. This creates a new market-access category sitting between full banking licensure and existing narrower payment-service permissions, expanding the range of institutions able to participate directly in accepting and holding customer funds and issuing payment cards. The new licence category carries an explicit activity bar: first-category payment organisations are barred from accepting deposits, providing consumer loans, or offering mortgage lending. This distinction is significant for market structure — it draws a clear line between payment functionality (accounts, cards) and banking functionality (deposits, lending), placing first-category payment organisations firmly in the non-bank PI/EMI category rather than granting them bank-equivalent status. The primary source for the licensing regime itself is confirmed via the National Payment Corporation of Kazakhstan's own announcement; the specific activity-bar detail is corroborated by a secondary industry source. Separately, the National Bank of Kazakhstan launched a unified interbank QR-code and phone-number transfer system nationwide on 19 July 2026, representing a further market-access development in how payments are initiated and routed domestically, distinct from the account-holding licensing change above but part of the same broader National Bank-led push to formalise and modernise Kazakhstan's payments infrastructure. #### Outlook The October 2026 commencement date is the immediate near-term milestone: early licence applications and NBK implementation guidance for first-category payment organisations should clarify how this bank/non-bank distinction operates in practice, and whether further activity-bar detail or capital requirements emerge as the regime becomes operational. Periodic update · new data 2026-09-21 #### 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. Periodic update · new data 2026-08-25 #### 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. Periodic update · new data 2026-08-11 #### 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. **Sources and findings (6)** 1. T1 [https://www.adilet.zan.kz/eng/docs/Z1600000011](https://www.adilet.zan.kz/eng/docs/Z1600000011) retrieved 2026-07-04 2. T1 [https://nationalbank.kz/en/news/uchetnaya-registraciya-platezhnoy-organizacii](https://nationalbank.kz/en/news/uchetnaya-registraciya-platezhnoy-organizacii) retrieved 2026-07-04 3. T3 [https://www.bakermckenzie.com/en/insight/publications/2026/01/kazakhstan-new-banking-law-signals-major-reform](https://www.bakermckenzie.com/en/insight/publications/2026/01/kazakhstan-new-banking-law-signals-major-reform) retrieved 2026-07-04 4. T3 [https://astanatimes.com/2025/10/kazakhstans-new-banking-rules-innovation-or-more-oversight/](https://astanatimes.com/2025/10/kazakhstans-new-banking-rules-innovation-or-more-oversight/) retrieved 2026-07-04 5. T4 [https://ybcase.com/en/fintech/licenzia-plateznogo-operatora-v-kazahstane](https://ybcase.com/en/fintech/licenzia-plateznogo-operatora-v-kazahstane) retrieved 2026-07-04 6. T1 [https://afsa.aifc.kz/afsa-announces-new-rulebook-on-digital-asset-activities-3/](https://afsa.aifc.kz/afsa-announces-new-rulebook-on-digital-asset-activities-3/) retrieved 2026-07-04 ### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-07-04 Conduct regulation is being substantially rebuilt under the pending New Banking Law, which introduces behavioural supervision, mandatory suitability/disclosure duties, and a unified pretrial dispute-resolution ombudsman. Agent liability and joint-and-several responsibility rules already apply to payment organisations under existing law. Horizon · 2026-Q2 (±half_year) Unified Financial Ombudsman service operationalisation under New Banking Law_adopted · TT3_ Standing sub-brief · as of 4 July 2026 275 words · last cycle 2026-07-04 #### Conduct, Safeguarding & Financial Promotions Kazakhstan's conduct regulation is being rebuilt around the now-in-force New Banking Law. The law introduces a behavioural-supervision regime that shifts bank oversight away from a purely financial-metrics focus toward fair treatment of clients, and it establishes a two-step complaint process escalating to a Unified Financial Ombudsman. Because the parent law is confirmed signed and in force, this conduct regime is now assessed as likely operative, though the ombudsman's specific commencement date has not been independently confirmed and the finding is therefore held at Assessed rather than High confidence. Distinct from the New Banking Law, an established rule under existing payments legislation already governs agent conduct: a payment organisation that engages agents to accept payments on its behalf bears joint-and-several liability to customers for those agents' conduct, and must operate strictly within its authorised service scope. This agent-liability rule is a persistent feature of the payments-law framework rather than a product of the 2026 reform, and it functions as a standing safeguard for the non-bank payment-organisation channel that sits alongside - but separate from - the new bank-conduct regime. Read together, Kazakhstan's conduct perimeter is expanding on two fronts simultaneously: banks gain a new behavioural-supervision layer and a unified dispute-escalation path, while non-bank payment organisations continue to carry pre-existing agent-liability exposure. The bank-PSP and non-bank-PI/EMI conduct tracks remain distinct in both legal basis and enforcement mechanism. #### Outlook The Unified Financial Ombudsman's operationalisation is flagged on the regulatory horizon for the second quarter of 2026; confirmation of its commencement, and of how the two-step complaint process interacts with the pre-existing agent-liability rule, is the next material development to watch in this module. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://astanatimes.com/2025/10/kazakhstans-new-banking-rules-innovation-or-more-oversight/](https://astanatimes.com/2025/10/kazakhstans-new-banking-rules-innovation-or-more-oversight/) retrieved 2026-07-04 2. T3 [https://qazinform.com/news/one-ombudsman-one-system-kazakhstan-reshapes-financial-dispute-resolution-796606](https://qazinform.com/news/one-ombudsman-one-system-kazakhstan-reshapes-financial-dispute-resolution-796606) retrieved 2026-07-04 3. T3 [https://astanatimes.com/2025/10/kazakhstans-new-banking-rules-innovation-or-more-oversight/](https://astanatimes.com/2025/10/kazakhstans-new-banking-rules-innovation-or-more-oversight/) retrieved 2026-07-04 4. T3 [https://iclg.com/practice-areas/digital-business-laws-and-regulations/kazakhstan/](https://iclg.com/practice-areas/digital-business-laws-and-regulations/kazakhstan/) retrieved 2026-07-04 5. T3 [https://afi-global.org/news/kazakhstan-is-strengthening-consumer-protection-for-digital-financial-services/](https://afi-global.org/news/kazakhstan-is-strengthening-consumer-protection-for-digital-financial-services/) retrieved 2026-07-04 ### W2 Stablecoins & Digital Money Probable confirmed 2026-07-04 Kazakhstan runs a bifurcated digital-asset regime: unsecured digital assets (crypto) are generally confined to the AIFC under the Law on Digital Assets (No.193-VII, in force since April 2023), while a 2025 amendment opened nationwide crypto circulation, and a separate DFA/stablecoin bill and the pending New Banking Law formalise digital tenge and stablecoin issuance under NBK oversight. Standing sub-brief · as of 4 July 2026 295 words · last cycle 2026-10-18 #### Stablecoins & Digital Money Kazakhstan's digital-asset regime has undergone a substantive reclassification in this baseline. The historical position - under the Law on Digital Assets No. 193-VII, in force since 1 April 2023 - confined unsecured digital-asset circulation to the AIFC only. That confinement has since been superseded: a November 2025 amendment (Law No. 231-VIII) removed the AIFC-only restriction, and the now-in-force New Banking Law formalises digital tenge and stablecoin issuance under National Bank oversight, so unsecured digital assets and digital financial assets now circulate nationwide under national licensing rather than the earlier AIFC-confined, bifurcated model. This corrects an earlier baseline framing that had presented the nationwide opening and the DFA framework as parallel pending developments; both are now enacted, though the AIFC parallel track remains available for AIFC-registered participants. Within that AIFC parallel track, the Astana Financial Services Authority's AIFC Stablecoin Framework - covering capital, redemption, reserve-asset and disclosure requirements for single-currency-backed fiat stablecoins - has in fact been in force since 1 January 2024. An earlier reading had described this framework as a future expansion; that framing is now understood to be stale, and the framework should be treated as an established, operating regime rather than a pending one. The net effect is that Kazakhstan now runs two live, parallel stablecoin/digital-asset regimes - a nationwide track under the amended digital-assets law and New Banking Law, and an AIFC-specific track under the AFSA framework in force since 2024 - rather than a single bifurcated regime with one side still pending. #### Outlook With both the nationwide and AIFC tracks now confirmed in force, the next material development to track is how National Bank licensing practice under the New Banking Law's DFA/stablecoin category interacts with the AIFC's separate AFSA authorisation for entities operating across both tracks. Periodic update · new data 2026-10-18 #### Stablecoins & Digital Money A July 2026 presidential decree authorised the use of digital assets and stablecoins in cross-border import and export settlement, operating as a mechanism alongside Kazakhstan's existing banking channels rather than displacing them. The decree was paired with a personal-income-tax exemption applying to digital-asset trading income earned on licensed, domestically regulated platforms, giving the liberalisation both a payments-infrastructure dimension and a tax-incentive dimension aimed at channelling activity toward licensed domestic venues rather than offshore platforms. On the regulatory-operations side, the Astana Financial Services Authority has piloted accepting payment of its own licence and supervision fees in USD-pegged stablecoins, a concrete operational step that moves stablecoin settlement beyond private cross-border trade use into the regulator's own fee-collection infrastructure. This is a notable signal because a financial regulator accepting stablecoin payment for its own regulatory fees demonstrates a degree of institutional comfort with stablecoin settlement rails that goes beyond simply authorising private-sector use. The cross-border settlement authorisation and the AFSA fee-payment pilot together describe a jurisdiction actively building out stablecoin settlement infrastructure across both private trade-settlement and public regulatory-fee contexts within the same several-month window in 2026. The decree does not appear, on the evidence available, to establish a dedicated reserve, redemption, or issuance-authorisation regime specific to stablecoins; it authorises use of digital assets and stablecoins for settlement purposes and provides a tax incentive for trading on licensed platforms, which is a distinct question from whether stablecoin issuers themselves face a bespoke prudential regime. #### Outlook The development to track is whether the National Bank or another competent authority follows the July 2026 decree with implementing rules addressing operational questions such as reporting thresholds for cross-border stablecoin settlement transactions, and whether the AFSA's stablecoin fee-payment pilot is extended or formalised into a standing practice. Growth in the volume of cross-border trade settlement actually conducted via the authorised stablecoin mechanism, as distinct from the existence of the authorisation itself, would be the clearest indicator of whether this liberalisation is translating into real payment-flow volume. **1 earlier distinct update(s)** Periodic update · new data 2026-10-11 #### Stablecoins & Digital Money Kazakhstan's stablecoin and digital-money regime saw two developments this cycle. The National Bank and the Agency for Regulation and Development of the Financial Market published a draft joint resolution, opened for consultation on 9 October 2026, setting requirements for domestic financial organisations and residents, and AIFC participants, to issue digital financial assets through a platform operator. The draft has not been adopted and its primary text was not independently retrieved this cycle; reporting rests on secondary trade-press coverage of the National Bank's press release. Separately, Kazakhstan's existing digital-asset regulatory sandbox continues to host active pilots: the National Payment Corporation of Kazakhstan disclosed that 34 digital-asset sandbox projects had completed testing as of early October 2026, including the KZTE tenge-pegged stablecoin pilot involving Intebix, Eurasian Bank, Solana and Mastercard, which has operated within the sandbox since 2025. This sandbox activity indicates that stablecoin experimentation in Kazakhstan predates, and runs in parallel with, the newer draft DFA-issuance framework, rather than being contingent on it. #### Outlook The draft DFA-issuance resolution's consultation period and expected progress within the fourth quarter of 2026 is the development most likely to clarify the regulatory path for stablecoin issuance in Kazakhstan going forward. Whether the existing KZTE sandbox pilot or any future tenge-pegged stablecoin product, including any outcome of the Tether exploration MoU tracked separately under commercial intelligence, would transition onto the new DFA-issuance framework once adopted remains unconfirmed. **Sources and findings (6)** 1. T3 [https://www.lightspark.com/knowledge/is-crypto-legal-in-kazakhstan](https://www.lightspark.com/knowledge/is-crypto-legal-in-kazakhstan) retrieved 2026-07-04 2. T3 [https://astanatimes.com/2025/09/kazakhstan-to-introduce-legal-framework-for-digital-financial-assets-including-stablecoins/](https://astanatimes.com/2025/09/kazakhstan-to-introduce-legal-framework-for-digital-financial-assets-including-stablecoins/) retrieved 2026-07-04 3. T1 [https://afsa.aifc.kz/afsa-announces-new-rulebook-on-digital-asset-activities-3/](https://afsa.aifc.kz/afsa-announces-new-rulebook-on-digital-asset-activities-3/) retrieved 2026-07-04 4. T3 [https://coinpaper.com/12421/kazakhstan-opens-door-to-nationwide-crypto-use-with-new-law](https://coinpaper.com/12421/kazakhstan-opens-door-to-nationwide-crypto-use-with-new-law) retrieved 2026-07-04 5. T3 [https://www.bitget.com/amp/news/detail/12560605487419](https://www.bitget.com/amp/news/detail/12560605487419) retrieved 2026-07-04 6. T3 [https://www.bakermckenzie.com/en/insight/publications/2026/01/kazakhstan-new-banking-law-signals-major-reform](https://www.bakermckenzie.com/en/insight/publications/2026/01/kazakhstan-new-banking-law-signals-major-reform) retrieved 2026-07-04 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-04 Operational resilience runs through the 2015 Informatization Law's critical-infrastructure cyber-risk obligations, the 2023-2029 national Digital Transformation/Cybersecurity Concept, and NBK's 2022 mandatory cybersecurity-protocol directive to financial institutions, reinforced by the 2024 NBK Anti-Fraud Center. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/kazakhstan/) Standing sub-brief · as of 4 July 2026 200 words · last cycle 2026-09-05 #### Operational Resilience & Critical Infrastructure Kazakhstan's operational-resilience baseline for payments runs through general critical-infrastructure law rather than a payments-specific cybersecurity statute. Critical (information) infrastructure operators, a category that captures core payment-system operators, must assess and manage cyber risk under Article 54 of Law No. 418-V 'On Informatization' (24 November 2015), reinforced by the 2023-2029 national Digital Transformation/Cybersecurity Concept adopted under Resolution No. 269. On the operational side, the National Bank of Kazakhstan launched an Anti-Fraud Center in August 2024 to respond to fraudulent activity, block suspicious money transfers, and maintain a blacklist of suspicious mobile numbers. This builds on an earlier 2022 NBK directive requiring financial institutions to follow mandatory cybersecurity protocols, indicating a steady build-out of operational-resilience tooling over the past several years rather than a single reform event. Both elements - the statutory critical-infrastructure obligation and the NBK's operational anti-fraud tooling - are assessed as steady-state and unchanged this cycle, in contrast to the escalating trajectories visible in the licensing and digital-asset modules. #### Outlook No near-term change to this module's statutory basis is indicated in current sourcing; the Anti-Fraud Center's operational metrics and any expansion of its blacklist/blocking mandate are the items most likely to generate incremental developments. Periodic update · new data 2026-09-08 #### Operational Resilience & Critical Infrastructure Kazakhstan's payments infrastructure reached two structurally important milestones this cycle. The National Bank of Kazakhstan launched the nationwide Interbank Mobile Payment System on 19 July 2026, a system designed to enable phone-number-based transfers and a single interoperable QR-code payment standard across participating banks. This is a confirmed development, cross-corroborated by the National Bank's own Payment Systems Registry, which separately confirms that the pre-existing Interbank Money Transfer System already functions as the systemically important settlement layer for the country, processing more than ninety-seven percent of foreign-exchange-market, securities-market and banking-sector payments. Together, these two facts describe a national payments infrastructure that is both highly concentrated in its core settlement function and now being extended outward into retail-facing interoperability via the new mobile system. The interoperable QR-code standard is the more operationally significant element of the new system for market structure: a single national standard removes the fragmentation risk that arises when individual banks or payment providers maintain proprietary QR formats, and it is the kind of infrastructure decision that typically favours bank-affiliated payment rails over non-bank payment-institution alternatives, since the standard is being rolled out through the interbank system rather than through a competing non-bank scheme. This is consistent with the broader bank-PSP-versus-non-bank distinction that structures much of the payments regulatory landscape in comparable jurisdictions, and Kazakhstan's approach here is clearly bank-and-central-bank-led rather than non-bank-PI/EMI-led. Digital tenge's formal legal-status change, effective 18 July 2026, recognising it as the third form of the national currency alongside cash and non-cash money, is directly relevant to the critical-infrastructure picture as well: a CBDC with formal statutory currency status is a different category of resilience dependency than a pilot instrument, since its continued operation becomes a matter of currency-system integrity rather than simply a technology project. The timing — legal-status recognition landing within a day of the nationwide instant-payments launch — suggests a coordinated infrastructure push by the National Bank across both instant payments and CBDC in the same policy window. #### Outlook The key operational-resilience question for next cycle is bank participation breadth and transaction-volume uptake for the new Interbank Mobile Payment System, and whether the concentration of settlement activity in the existing Interbank Money Transfer System creates a single-point-of-failure profile that the new mobile system either mitigates or compounds. Confirmation of participating-bank counts and early volume data would materially sharpen this assessment. **1 earlier distinct update(s)** Periodic update · new data 2026-08-25 #### 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. **Sources and findings (5)** 1. T2 [https://ncsi.ega.ee/country/kz/](https://ncsi.ega.ee/country/kz/) retrieved 2026-07-04 2. T2 [https://ncsi.ega.ee/country/kz/](https://ncsi.ega.ee/country/kz/) retrieved 2026-07-04 3. T2 [https://www.csis.org/analysis/building-dpi-lessons-learned-kazakhstan](https://www.csis.org/analysis/building-dpi-lessons-learned-kazakhstan) retrieved 2026-07-04 4. T1 [https://nationalbank.kz/en/page/Digital-Financial-Infrastructure](https://nationalbank.kz/en/page/Digital-Financial-Infrastructure) retrieved 2026-07-04 5. T2 [https://www.csis.org/analysis/building-digital-public-infrastructure-lessons-learned-kazakhstan](https://www.csis.org/analysis/building-digital-public-infrastructure-lessons-learned-kazakhstan) retrieved 2026-07-04 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-04 Card-scheme and interbank network compliance sits on the NBK Payment Systems Registry (systemically-important/important classifications), with Visa itself classified as an important payment system domestically; PCI DSS applies as the standard scheme-level data-security mandate for any card-data-handling entity, enforced by Visa/Mastercard rather than a domestic regulator. Standing sub-brief · as of 4 July 2026 174 words · last cycle 2026-07-04 #### Scheme & Network Compliance Kazakhstan's scheme and network compliance baseline centres on the National Bank's Payment Systems Register. The Interbank Money Transfer System (IMTS), operated by the National Payment Corporation, is classified in that register as the systemically important payment system, processing more than 97% of foreign-exchange, securities and banking-sector payments; Visa, by contrast, is classified in the same registry as merely an 'important' - not systemically important - payment system. On data security, Visa- and Mastercard-facing entities that handle card data in Kazakhstan must comply with PCI DSS, which functions as a scheme-mandated overlay enforced through issuer/acquirer scheme contracts rather than as a domestic statute. In the absence of an identified domestic acquiring or interchange statute, PCI DSS compliance and the systemic-designation framework are the two operative controls in this module. #### Outlook No domestic interchange-fee cap, surcharging rule, or acquiring-specific statute has been identified to date (see the related merchant-acquiring gap logged under W8); this remains a coverage gap to close in future research cycles rather than a signal of forthcoming regulatory change. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://nationalbank.kz/en/news/reestr-platezhnyh-sistem](https://nationalbank.kz/en/news/reestr-platezhnyh-sistem) retrieved 2026-07-04 2. T1 [https://nationalbank.kz/en/news/reestr-platezhnyh-sistem](https://nationalbank.kz/en/news/reestr-platezhnyh-sistem) retrieved 2026-07-04 3. T1 [https://nationalbank.kz/en/news/reestr-platezhnyh-sistem](https://nationalbank.kz/en/news/reestr-platezhnyh-sistem) retrieved 2026-07-04 4. T2 [https://corporate.visa.com/en/resources/security-compliance.html](https://corporate.visa.com/en/resources/security-compliance.html) retrieved 2026-07-04 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-04 Kazakhstan's principal payment corridors run through CIS/Russia rails (SPFS messaging, Russia's SBP fast-payment cross-border expansion) and the emerging Trans-Caspian/Middle Corridor trade route, with digital-tenge cross-border pilots via SWIFT's CBDC Connector as a forward-looking rail. EU sanctions have begun to sever a Kazakh bank's connection to Russian payment/messaging rails. Standing sub-brief · as of 4 July 2026 241 words · last cycle 2026-09-28 #### Payment Corridor Dynamics Kazakhstan's payment corridors are shaped by two simultaneous forces: deepening CIS/Russia connectivity and rising sanctions pressure on that same connectivity. Russia's Fast Payment System (SBP) has expanded cross-border to include Kazakhstan among nine countries, and Kazakhstan sits among the top five countries by SBP transfer volume received from Russia, within a group (with Armenia, Belarus, Tajikistan and Uzbekistan) that together accounts for more than 90% of that volume. This SBP corridor, alongside SPFS messaging connectivity, functions as the principal CIS/Russia payment rail for Kazakhstan. That same corridor is now under sanctions pressure. The European Union's 19th sanctions package, adopted 23 October 2025, places VTB Bank Kazakhstan under a transaction ban specifically for its connectivity to Russian financial-messaging and payment systems, including Mir and SBP. However, operational severance of VTB Bank Kazakhstan from these rails is not independently confirmed by current sourcing - the EU source confirms only that the transaction ban was imposed, and the National Bank of Kazakhstan has stated the bank remains locally operational. Confidence in the severance question is accordingly held at Assessed rather than High, a downward correction from an earlier baseline reading that had over-stated confidence on this point. #### Outlook The unresolved question of VTB Bank Kazakhstan's actual operational connectivity to SPFS/SBP - transaction-ban designation versus genuine severance - is the single most consequential open item in this module and the one most likely to generate a material update in the next cycle. Periodic update · new data 2026-09-28 #### Payment Corridor Dynamics Kazakhstan's domestic instant-payments corridor took a significant step forward this cycle. The unified interbank QR-code and phone-number transfer system, launched nationwide on 19 July 2026, has processed more than 20 million transactions totalling approximately KZT 400 billion since launch. This scale of adoption in a relatively short window since a nationwide launch indicates rapid uptake of the new domestic rail, though the specific volume figures rest on a secondary industry source rather than a primary National Bank release and should be read with that caveat. This growth in domestic instant-payment volume sits within a broader structural shift toward cashless payments generally. Cashless payments reached 88 percent of transactions in Kazakhstan in 2026, up from 67 percent in 2019, a trajectory reported by a quality-journalism source. The new QR/phone-number rail is a plausible contributor to sustaining or accelerating that longer-run cashless trend, though the interpreter has not established a direct causal claim between the two data points this cycle — they are reported as parallel developments in the same corridor-dynamics domain. #### Outlook Watch subsequent transaction-volume reporting for the unified QR/phone-number system as it matures beyond its initial launch window, and watch for primary National Bank data corroborating both the instant-payments volume figures and the cashless-share trajectory, neither of which has yet been confirmed against a Tier-1 source this cycle. **1 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### 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. **Sources and findings (6)** 1. T3 [https://russiaspivottoasia.com/russias-fast-payment-system-via-phone-set-to-expand-into-the-global-south/](https://russiaspivottoasia.com/russias-fast-payment-system-via-phone-set-to-expand-into-the-global-south/) retrieved 2026-07-04 2. T3 [https://en.wikipedia.org/wiki/SPFS](https://en.wikipedia.org/wiki/SPFS) retrieved 2026-07-04 3. T2 [https://www.unescap.org/sites/default/d8files/event-documents/Remittances_in_NCA_ENG_20241126.pdf](https://www.unescap.org/sites/default/d8files/event-documents/Remittances_in_NCA_ENG_20241126.pdf) retrieved 2026-07-04 4. T3 [https://www.geopoliticalmonitor.com/the-middle-corridor-a-route-born-of-the-new-eurasian-geopolitics/](https://www.geopoliticalmonitor.com/the-middle-corridor-a-route-born-of-the-new-eurasian-geopolitics/) retrieved 2026-07-04 5. T2 [https://www.financialprotectionforum.org/sites/default/files/2025-04/14.%20English_Kazakhstan%20-%20Experience%20digital%20payments.pdf](https://www.financialprotectionforum.org/sites/default/files/2025-04/14.%20English_Kazakhstan%20-%20Experience%20digital%20payments.pdf) retrieved 2026-07-04 6. T1 [https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/) retrieved 2026-07-04 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-04 The market is bank-led rather than startup-led: 23 licensed second-tier banks, with Halyk Bank, Kaspi Bank and Bank CenterCredit as the dominant three, and Kaspi/Halyk together processing roughly 80% of payments. Fintech growth has been achieved primarily through incumbent banks building super-app ecosystems rather than standalone disruptors. Standing sub-brief · as of 4 July 2026 175 words · last cycle 2026-07-04 #### Industry Structure & Commercial Dynamics Kazakhstan's banking and payments market is concentrated and bank-led. Of 23 licensed second-tier banks, the top five - Halyk, Kaspi, Bank CenterCredit, Otbasy and ForteBank - hold approximately 67% ($88.3 billion) of sector assets as of 1 January 2025. Within that group, government data indicates that Kaspi.kz and Halyk Bank together handle approximately 80% of domestic payments, an extraordinary degree of duopoly concentration in payments specifically rather than banking assets generally. Fintech growth in Kazakhstan follows a distinctive pattern relative to many other emerging-market jurisdictions: it is achieved through bank-led super-app ecosystems rather than through standalone non-bank disruptors displacing incumbents. This bank-led model means that the market-structure and product-innovation trajectories in this jurisdiction (see W9) are substantially driven by the same small set of incumbent institutions that dominate the concentration picture here. #### Outlook Given the scale of the Kaspi/Halyk duopoly, any regulatory or commercial development affecting either institution - including Kaspi's international-acceptance expansion (see W13) - carries outsized market-structure significance for Kazakhstan relative to jurisdictions with more fragmented payments markets. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T4 [https://grokipedia.com/page/List_of_banks_in_Kazakhstan](https://grokipedia.com/page/List_of_banks_in_Kazakhstan) retrieved 2026-07-04 2. T1 [https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing](https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing) retrieved 2026-07-04 3. T4 [https://grokipedia.com/page/List_of_banks_in_Kazakhstan](https://grokipedia.com/page/List_of_banks_in_Kazakhstan) retrieved 2026-07-04 4. T4 [https://nextgeninvestors.substack.com/p/initial-report-kaspikz-nasdaq-kspi](https://nextgeninvestors.substack.com/p/initial-report-kaspikz-nasdaq-kspi) retrieved 2026-07-04 5. T3 [https://thefintechtimes.com/the-fintech-landscape-of-kazakhstan-in-2026/](https://thefintechtimes.com/the-fintech-landscape-of-kazakhstan-in-2026/) retrieved 2026-07-04 6. T4 [https://matrixbcg.com/blogs/competitors/halykbank](https://matrixbcg.com/blogs/competitors/halykbank) retrieved 2026-07-04 ### W7 Legal & Litigation Probable confirmed 2026-07-04 The dominant legal/enforcement theme is sanctions-driven: EU and US measures against Russian-linked banks operating in Kazakhstan (VTB, Sberbank, Alfa-Bank subsidiaries) have forced restructurings, asset freezes and a 2025 transaction ban, while domestic criminal law was amended to criminalise money-mule conduct. Standing sub-brief · as of 4 July 2026 180 words · last cycle 2026-07-04 #### Legal & Litigation Kazakhstan's legal and litigation theme this cycle is dominated by sanctions exposure and a new domestic money-muling offence. VTB Bank Kazakhstan remains the only locally licensed, sanctions-listed financial institution in the country, a position that traces back to the 2022 restructuring of the Kazakh subsidiaries of Sberbank, VTB and Alfa-Bank following US and other sanctions on their Russian parents. Commentary characterises Kazakhstan's overall posture as 'managed-risk' rather than blanket de-risking - the country continues to accommodate Russian-linked institutions under enhanced controls rather than excluding them outright. On the domestic-enforcement side, an amendment to the Criminal Code (Article 232-1), effective 2025, criminalises transferring bank-account, e-wallet or internet-banking access to third parties for payments - the domestic money-muling offence - with penalties ranging from a fine to five years' imprisonment. This functions as a domestic criminal-law complement to the November 2025 AML reform package addressed in W11. #### Outlook Sanctions-related enforcement action involving VTB Bank Kazakhstan, and the first prosecutions under the new money-muling provision, are the two developments most likely to generate the next material update in this module. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/) retrieved 2026-07-04 2. T1 [https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing](https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing) retrieved 2026-07-04 3. T3 [https://news.am/eng/news/703413.html](https://news.am/eng/news/703413.html) retrieved 2026-07-04 4. T3 [https://timesca.com/kazakhstans-banking-system-and-the-logic-of-early-enforcement/](https://timesca.com/kazakhstans-banking-system-and-the-logic-of-early-enforcement/) retrieved 2026-07-04 5. T3 [https://hcsbk.kz/en/most-important/antifraud/](https://hcsbk.kz/en/most-important/antifraud/) retrieved 2026-07-04 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-04 Domestic merchant-acquiring regulation is thin in the public record beyond the general payment-organisation licensing/agent-liability regime and scheme-level PCI DSS obligations; no Kazakhstan-specific interchange cap, surcharging rule, or high-risk-MCC regime was identified in this pass. Standing sub-brief · as of 4 July 2026 145 words · last cycle 2026-07-04 #### Merchant Acquiring & Risk This module remains the thinnest in Kazakhstan's coverage this cycle. No domestic interchange-fee cap, surcharging rule, or high-risk merchant-category-code classification regime has been identified in current sourcing. In their absence, the operative controls governing merchant-acquiring risk are indirect: the agent joint-and-several liability rule applying to payment organisations (see W1b) and the scheme-level PCI DSS overlay applying to card-data handling (see W4). This is a logged coverage gap rather than a substantive finding of an unregulated market; merchant-acquiring operations are a known under-indexed research vector in the methodology, and this baseline flags the gap explicitly for targeted follow-up rather than asserting that no such regime exists. #### Outlook Targeted research into Kazakhstan's domestic acquiring and interchange rules is flagged as a priority for the next research cycle; until that gap is closed, this module should be read as thin-coverage rather than genuinely no-regulation. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [https://iclg.com/practice-areas/digital-business-laws-and-regulations/kazakhstan/](https://iclg.com/practice-areas/digital-business-laws-and-regulations/kazakhstan/) retrieved 2026-07-04 2. T4 [https://ybcase.com/en/fintech/licenzia-plateznogo-operatora-v-kazahstane](https://ybcase.com/en/fintech/licenzia-plateznogo-operatora-v-kazahstane) retrieved 2026-07-04 3. T2 [https://corporate.visa.com/en/resources/security-compliance.html](https://corporate.visa.com/en/resources/security-compliance.html) retrieved 2026-07-04 ### W9 Product Innovation & Market Development moved Probable confirmed 2026-07-04 Kazakhstan runs one of the most advanced CBDC and open-banking programmes in the post-Soviet space: the digital tenge is in live/limited-production use for public-finance scenarios, a digital-asset regulatory sandbox is running its first cohort, and Open API/Open Banking is mid-pilot ahead of 2026 product-API rollout. NBK's Instant Payment System (IPS, launched June 2022) underpins phone-number/QR P2P and merchant payment scenarios. Movement — CHANGED Digital tenge and Interbank Mobile Payment System both reached operational milestones this cycle (circulation/launch and 20m-transaction throughput)._Material product-innovation milestones confirmed._ Horizon · 2026-Q4 (±year) Full implementation of Open Banking / Open API product-API scenarios_in_force_pending · TT1_ Horizon · 2026-Q4 (±year) Full implementation of Open Banking / Open API product-API scenarios_in_force_pending · TT1_ Standing sub-brief · as of 4 July 2026 204 words · last cycle 2026-10-18 #### Product Innovation & Market Development Kazakhstan's product-innovation trajectory is advancing on two fronts. The Digital Tenge central bank digital currency is live and in use for public-finance scenarios, including a November 2025 road-repair financing programme jointly announced by the National Bank of Kazakhstan and the Ministry of Finance - one of the more advanced CBDC-in-production programmes in the post-Soviet space. Separately, the National Bank's Instant Payment System (IPS), originally launched in June 2022, has been upgraded to enable 24/7 instant interbank transfers and payments using a mobile phone number or QR code between clients of different banks, underpinning continued growth in P2P and merchant QR payments. A further product-access development sits on the regulatory horizon rather than in the confirmed-live category: full implementation of Open Banking/Open API product-access scenarios is expected in the fourth quarter of 2026, following a mid-pilot phase, which would extend account-to-account product access beyond the IPS rails already in operation. #### Outlook The Open API/Open Banking rollout expected in Q4 2026 is the principal item to track in this module; its interaction with the existing IPS rails and with the bank-led market structure described in W6 will determine whether product innovation broadens payment-market access beyond the Kaspi/Halyk duopoly or reinforces it. Periodic update · new data 2026-10-18 #### Product Innovation & Market Development Kazakhstan delivered two major pieces of national payments infrastructure within a single week in mid-2026. The digital tenge entered circulation on 18 July 2026, issued solely by the National Bank of Kazakhstan and accessed by users through their existing bank applications rather than through a standalone wallet, which keeps the bank-led distribution model intact even as the underlying instrument is a central bank digital currency. The following day, 19 July 2026, the Interbank Mobile Payment System launched nationwide, enabling transfers by phone number and introducing a single interoperable QR code usable across all participating banks, replacing what had previously been a more fragmented set of bank-specific QR and transfer systems. Adoption of the Interbank Mobile Payment System has been rapid by the figures reported: by 11 September 2026, fewer than two months after nationwide launch, the system had processed 20 million transactions worth approximately 400 billion tenge, equivalent to roughly 887 million US dollars. This transaction volume sits within a broader context of already-high cashless adoption in Kazakhstan, where cashless transactions involving payment cards and electronic banking services reached 92.1 trillion tenge, approximately 180 billion US dollars, in the first half of 2026 alone. The Interbank Mobile Payment System's volume is therefore additive to an already substantial existing base of card and electronic-banking cashless activity, rather than representing the creation of cashless payment activity where none existed before. The bank-led distribution model is a defining structural feature of both launches: the digital tenge is accessed through existing bank apps rather than a National Bank-operated wallet, and the Interbank Mobile Payment System operates through participating banks' own interfaces using a common interoperability standard, rather than through a separate National Bank-operated consumer application. This design choice preserves banks' role as the primary consumer-facing interface for both new infrastructure pieces, even as the underlying settlement and interoperability layer is centrally coordinated by the National Bank. #### Outlook Continued growth in Interbank Mobile Payment System transaction volumes beyond the 20-million-transaction, approximately 887-million-US-dollar figure recorded as at 11 September 2026 would confirm sustained adoption rather than an initial launch spike driven by novelty. Digital tenge circulation and usage figures, which were not separately reported this cycle, would be a useful complementary indicator of how the two infrastructure pieces are being adopted relative to each other, given that both launched within a single week of one another in July 2026. **4 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Product Innovation & Market Development Kazakhstan's digital tenge central bank digital currency project is reported to be moving into pilot phases with retail use-case exploration. This finding rests on a single quality-journalism source and has not been independently corroborated against a primary National Bank release this cycle, so it is carried with uncertain rather than confirmed confidence. If accurate, it would mark meaningful forward progress for a CBDC project that had previously been in earlier development stages, now advancing toward retail-facing pilot activity. This product-innovation signal sits alongside the National Bank's other infrastructure investments this cycle — the first-category payment-organisation licensing regime and the nationwide instant-payments rail launch — suggesting a National Bank strategy of building out multiple parallel strands of payments and monetary infrastructure (non-bank licensing, instant payments, and CBDC) concurrently rather than sequentially. #### Outlook The digital tenge pilot's progress is the least well-sourced development in this cycle's evidence and would benefit most from primary National Bank confirmation. Watch for any official National Bank communication specifying pilot scope, timeline, or retail use cases under consideration. Periodic update · new data 2026-09-21 #### 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. Periodic update · new data 2026-09-08 #### 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. Periodic update · new data 2026-08-25 #### 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. **Sources and findings (5)** 1. T3 [https://cbdctracker.hrf.org/currency/kazakhstan](https://cbdctracker.hrf.org/currency/kazakhstan) retrieved 2026-07-04 2. T2 [https://www.globalgovernmentfintech.com/kazakhstan-regulatory-sandbox-digital-assets-first-projects/](https://www.globalgovernmentfintech.com/kazakhstan-regulatory-sandbox-digital-assets-first-projects/) 3. T3 [https://astanatimes.com/2025/08/kazakhstan-becomes-regional-fintech-leader-as-startups-quadruple/](https://astanatimes.com/2025/08/kazakhstan-becomes-regional-fintech-leader-as-startups-quadruple/) retrieved 2026-07-04 4. T1 [https://nationalbank.kz/en/news/press-relizy/13764](https://nationalbank.kz/en/news/press-relizy/13764) retrieved 2026-07-04 5. T3 [https://www.globallegalinsights.com/practice-areas/fintech-laws-and-regulations/kazakhstan/](https://www.globallegalinsights.com/practice-areas/fintech-laws-and-regulations/kazakhstan/) retrieved 2026-07-04 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-04 Consumer protection is consolidating around a forthcoming Unified Financial Ombudsman and a 2025 package of anti-fraud legislative amendments (biometric first-loan ID, loan opt-out, money-mule criminalisation, NBK Anti-Fraud Center) rather than a UK-style mandatory APP-fraud reimbursement scheme. Standing sub-brief · as of 4 July 2026 154 words · last cycle 2026-07-04 #### Consumer Protection & APP Fraud Kazakhstan's consumer-protection framework is consolidating around a single forthcoming institution. The pending Unified Financial Ombudsman will replace separate banking, insurance and microfinance ombudsman mechanisms with a three-tier complaints system - institution, then ombudsman, then the Agency - covering the full range of financial-services complaints rather than sector-specific channels. This sits alongside a broader package of anti-fraud consumer measures, including biometric identification for first loans, a loan opt-out mechanism, and the money-mule criminalisation addressed in W7. Notably, no UK-style mandatory authorised-push-payment fraud reimbursement scheme has been identified in Kazakhstan; consumer protection against payment fraud is instead being built around the ombudsman-plus-anti-fraud-measures model rather than a liability-shifting reimbursement mandate. #### Outlook The Unified Financial Ombudsman's operationalisation, expected in the second quarter of 2026, is the key milestone for this module; its actual dispute-resolution throughput once live will indicate whether the three-tier model delivers faster consumer redress than the sector-specific mechanisms it replaces. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://qazinform.com/news/one-ombudsman-one-system-kazakhstan-reshapes-financial-dispute-resolution-796606](https://qazinform.com/news/one-ombudsman-one-system-kazakhstan-reshapes-financial-dispute-resolution-796606) retrieved 2026-07-04 2. T2 [https://www.csis.org/analysis/building-dpi-lessons-learned-kazakhstan](https://www.csis.org/analysis/building-dpi-lessons-learned-kazakhstan) retrieved 2026-07-04 3. T3 [https://hcsbk.kz/en/most-important/antifraud/](https://hcsbk.kz/en/most-important/antifraud/) retrieved 2026-07-04 4. T3 [https://afi-global.org/news/kazakhstan-is-strengthening-consumer-protection-for-digital-financial-services/](https://afi-global.org/news/kazakhstan-is-strengthening-consumer-protection-for-digital-financial-services/) retrieved 2026-07-04 5. T3 [https://astanatimes.com/2025/10/kazakhstans-new-banking-rules-innovation-or-more-oversight/](https://astanatimes.com/2025/10/kazakhstans-new-banking-rules-innovation-or-more-oversight/) retrieved 2026-07-04 ### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/kazakhstan/#sec-dom-D7) Probable confirmed 2026-07-04 Sentinel.gi payments-context position: Kazakhstan underwent a significant Nov 2025 AML tightening (money-mule criteria, crypto-wallet high-risk registry, unlicensed-exchange blocking) against a backdrop of a 2023 Mutual Evaluation rating it Substantially Effective on most FATF effectiveness criteria and not currently on any FATF deficiency list. Standing sub-brief · as of 4 July 2026 202 words · last cycle 2026-07-04 #### AML/CFT & Financial Crime This module is sourced from the Sentinel.gi feed and is carried here as payments-context provenance rather than original illicit-finance analysis, which is out of scope for this monitor and routed instead to the Financial Intelligence Monitor. Kazakhstan's AML/CFT regime tightened materially via a November 2025 reform package, effective 20 November 2025, comprising new money-mule criteria, a high-risk crypto-wallet registry, and blocking of unlicensed crypto exchanges. That tightening sits against a standing baseline: Kazakhstan's 2023 FATF Mutual Evaluation rated the country Substantially Effective on seven of eleven FATF effectiveness criteria (Highly Effective on none), and Kazakhstan does not appear on the FATF strategic-deficiencies list. The November 2025 reforms represent an incremental strengthening of an already-adequate baseline rather than a response to a deficiency finding. For substantive illicit-finance analysis of these developments, readers are directed to the Sentinel.gi feed and the corresponding Financial Intelligence Monitor coverage; this sub-brief confines itself to noting the payments-market-structure implications, principally the new compliance burden the crypto-wallet registry and exchange-blocking measures place on payment and digital-asset service providers operating in Kazakhstan. #### Outlook Continued Sentinel-fed reporting on implementation of the crypto-wallet registry and unlicensed-exchange blocking will be the primary source of forward developments in this module. no periodic updates on record for this sub-brief ** Sources and findings (8)** 1. T1 [https://egov.kz/cms/en/information/state_agencies/nadsor_control](https://egov.kz/cms/en/information/state_agencies/nadsor_control) retrieved 2026-07-04 2. T? FIM (sentinel.gi) per-JID baseline profile — Kazakhstan — Kazakhstan is assessed by the Eurasian Group (EAG), not FATF directly, under its 2023 Mutual Evaluation Report. The Agency for Financial Monitoring is the FIU/policy lead. Legal-person BO transparency is largely compliant, but legal-arrangement transparency and FI supervision remain weak (R.26 non-compliant). EAEU membership and border-free trade with Russia create structural sanctions-evasion exposure managed unevenly by a domestic Specific Goods Law licensing regime. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: EU listing 5. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: European Commission / Council of the European Union — Third-country suppliers based in Kazakhstan (alongside China, UAE, Uzbekistan, Belarus) 6. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: political-constraint 7. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure 8. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: enforcement-absence ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-04 Correspondent-banking access is structurally sound (Citi, JPMorgan, BNY relationships; IMF Article VIII currency-convertibility commitment) but increasingly shaped by sanctions risk-management: 2022 Russian-subsidiary restructurings and a 2025 EU transaction ban on a Kazakh bank illustrate the country's positioning as a 'managed-risk' rather than blanket-de-risked jurisdiction. Standing sub-brief · as of 4 July 2026 233 words · last cycle 2026-09-28 #### Correspondent Banking, Settlement & Access Kazakhstan's correspondent-banking access is structurally sound at the bank level: correspondent relationships with Citi, JPMorgan Chase and BNY, combined with Kazakhstan's IMF Article VIII convertibility commitment (which requires the servicing bank to notify the National Bank of transfers exceeding $50,000), give licensed second-tier banks an established settlement-access base. This module's analytical spine, however, is the asymmetry between that bank-level access and the position of non-bank payment institutions: the correspondent-banking claims underpinning this baseline are specifically documented at the bank_psp level, and no equivalent correspondent or settlement-access finding for non-bank payment organisations or e-money institutions has been identified in current sourcing - an asymmetry consistent with non-bank PSPs' reliance on partner-bank settlement rails rather than direct correspondent relationships. That bank-level access base is now layered with sanctions-driven de-risking pressure. The EU's 19th sanctions package restricts settlement access for Kazakh (and Belarusian) banks connected to Russian financial-messaging and payment systems via a transaction ban. This illustrates Kazakhstan's broader 'managed-risk' correspondent-banking positioning - continued access for the banking sector overall, with sanctions pressure concentrated on specific Russian-linked institutions - rather than a blanket de-risking of the jurisdiction. #### Outlook Watch for whether sanctions-driven de-risking pressure remains contained to Russian-linked institutions like VTB Bank Kazakhstan or begins to affect correspondent terms for the broader Kazakh banking sector; the bank/non-bank access asymmetry noted above also remains a research gap worth closing in future cycles. Periodic update · new data 2026-09-28 #### Correspondent Banking, Settlement & Access The analytical spine of Kazakhstan's correspondent-banking and settlement picture this cycle is the concentration of systemically important infrastructure within a single National Bank-operated system. The Interbank Money Transfer System (IMTS) processes over 97 percent of payments for the FX market, securities market and banking-sector participants, a confirmed figure drawn directly from a primary National Bank source. This level of concentration means that access to, and the operational integrity of, the IMTS is functionally equivalent to access to Kazakhstan's core settlement infrastructure for any institution operating in these sectors. This settlement-concentration picture should be read alongside this cycle's other National Bank-led infrastructure developments — the first-category payment-organisation licensing regime and the nationwide instant-payments rail — as part of a single institutional strategy in which the National Bank is positioned as the central architect of the domestic payments and settlement stack, with limited evidence this cycle of alternative settlement rails developing independently of National Bank control. #### Outlook Watch for any evidence of settlement-access conditions for the new first-category payment organisations once their October 2026 licensing regime commences — specifically, whether and how they connect to or interact with the IMTS given their bar on deposit-taking and lending. No such connectivity detail has been evidenced this cycle. **2 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### 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. Periodic update · new data 2026-08-11 #### 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. **Sources and findings (5)** 1. T1 [https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing](https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing) retrieved 2026-07-04 2. T1 [https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing](https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing) retrieved 2026-07-04 3. T1 [https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing](https://www.trade.gov/country-commercial-guides/kazakhstan-trade-financing) retrieved 2026-07-04 4. T3 [https://timesca.com/kazakhstans-banking-system-and-the-logic-of-early-enforcement/](https://timesca.com/kazakhstans-banking-system-and-the-logic-of-early-enforcement/) retrieved 2026-07-04 5. T1 [https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/](https://www.consilium.europa.eu/en/press/press-releases/2025/10/23/19th-package-of-sanctions-against-russia-eu-targets-russian-energy-third-country-banks-and-crypto-providers/) retrieved 2026-07-04 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-04 Trailing-12-month commercial activity is dominated by Kaspi.kz partnership/product expansion and shareholder moves, ForteBank's international bond debut, and regulatory-driven digital-asset licensing events, against a backdrop of otherwise modest standalone fintech VC funding in-market. Standing sub-brief · as of 4 July 2026 157 words · last cycle 2026-10-18 #### Commercial Intelligence (M&A, Investment & Product) Two discrete commercial events define Kazakhstan's trailing-twelve-month commercial-intelligence picture. Kaspi.kz completed two acceptance-partnership restructurings: a partnership with UnionPay International achieving near-full UnionPay card acceptance (November 2025), and a partnership with Alipay+ (August 2025). Both events expand Kaspi.kz's international card-acceptance footprint; the financial terms of both partnerships were not publicly disclosed. Separately, ForteBank issued Kazakhstan's first international perpetual Additional Tier 1 (AT1) Eurobond in November 2025, advised by law firm Dentons - a first-of-kind capital-markets instrument for a Kazakh bank. The amount raised was not publicly disclosed in available sourcing. Both events are commercial rather than regulatory in character: Kaspi.kz's partnerships are product/acceptance-network expansions distinct from any structural M&A trend, and ForteBank's Eurobond is a discrete capital-raising event rather than a market-structure shift. #### Outlook Further Kaspi.kz international-acceptance partnerships, and any follow-on AT1 or other capital-markets issuance by Kazakh banks, are the items most likely to populate this module in the next cycle. Periodic update · new data 2026-10-18 #### Commercial Intelligence & Fintech VEON, through its Kazakhstan subsidiary KaR-Tel, signed a memorandum of understanding with the National Bank of Kazakhstan at the Central Asia Fintech Summit 2026 in Almaty. The agreement covers exploring how VEON group companies could obtain a first-category payment-organisation licence, the new non-bank licence class the National Bank is set to begin issuing from October 2026. This is a discrete, named commercial event rather than a general statement about market interest in the new licence category, and it ties a specific, identifiable telecoms-sector entrant directly to Kazakhstan's payments-licensing liberalisation this cycle. The transaction value associated with this memorandum of understanding has not been publicly disclosed, and the event is classified at the announcement stage rather than as a completed licensing or investment transaction; a memorandum of understanding establishes an intent to explore an outcome rather than committing to one. The partnership sits within the broader category of telecoms operators moving toward embedded financial-services or banking-as-a-service positioning, since VEON's core business is telecommunications rather than financial services, and a first-category payment-organisation licence would represent a new line of business for the group's Kazakhstan subsidiary. This single, specific commercial event should be read as distinct from the structural, market-wide licensing development described in the Licensing, Authorisation & Market Access module: more than ten prospective applicants are reported to be preparing filings generally, of which VEON/KaR-Tel is the one named and specifically evidenced example this cycle. #### Outlook The indicator to track is whether VEON/KaR-Tel's memorandum of understanding converts into a formal licence application once the National Bank begins accepting first-category payment-organisation applications from October 2026, and whether other named entrants among the more-than-ten reported prospective applicants become publicly identifiable in the way VEON/KaR-Tel has. **3 earlier distinct update(s)** Periodic update · new data 2026-10-11 #### Commercial Intelligence & Fintech Two discrete commercial developments mark this cycle for Kazakhstan. On 7 October 2026, Tether signed a non-binding memorandum of understanding with the National Bank of the Republic of Kazakhstan and the Alatau City Authority to explore a tenge-pegged stablecoin and asset-tokenisation pilots. The agreement is explicitly a study and concept-exploration phase: no issuance date, reserve design, or binding commitment has been disclosed, and the amount involved, where applicable, is not publicly disclosed. Separately, the National Investment Corporation, a National Bank subsidiary, disclosed that Kazakhstan's National Strategic Crypto Reserve reached 700 million dollars as of 15 September 2026, with approximately 200 million dollars already invested, up from 350 million dollars in March 2026 — a disclosed capital commitment rather than an undisclosed one. These are distinct commercial events: the Tether MoU is a signed partnership at an exploratory stage, while the crypto reserve disclosure is a completed capital-commitment event with a specific, disclosed dollar figure. #### Outlook The Tether MoU's progression beyond the exploration phase, and any further disclosure on the pace of National Strategic Crypto Reserve deployment beyond the approximately 200 million dollars already invested, are the two commercial-intelligence threads most likely to produce the next concrete development for Kazakhstan's digital-asset commercial landscape. Periodic update · new data 2026-08-25 #### Commercial Intelligence & Fintech Two discrete commercial events define this cycle's fintech signal for Kazakhstan. The National Bank's cryptocard project, launched 3 June 2025, is a completed product release enabling non-cash payment-card transactions funded from wallets held on AIFC-licensed crypto exchanges — a high-confidence, Tier-1-sourced development distinct from the broader digital-assets legal-framework policy discussion tracked under product innovation. Second, the Astana Financial Services Authority, in partnership with the AIFC, has launched a pilot with Bybit Kazakhstan — a subsidiary of the Bybit exchange — allowing certain regulatory fees and government charges to be paid in USD-pegged stablecoins. This is an announced, assessed-confidence commercial partnership rather than a completed rollout; amount not publicly disclosed. Both events sit within the AIFC's distinctive regulatory-sandbox-adjacent commercial environment. Neither event has been confirmed as generating disclosed commercial value; the significance for market participants lies in the demonstration of AIFC-anchored product capability rather than in transaction scale. #### Outlook Watch for whether the AFSA/Bybit stablecoin-fee pilot expands beyond regulatory-fee payments into a broader commercial product, and for any disclosed volume or adoption data on the cryptocard project now that it has been operational for over a year. Periodic update · new data 2026-08-11 #### 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. **Sources and findings (6)** 1. T4 [https://tracxn.com/d/companies/kaspi/g5-wiGqv5O2ekPLG1vMJXv0WF7RIILsyYcdPiFbrSBA](https://tracxn.com/d/companies/kaspi/g5-wiGqv5O2ekPLG1vMJXv0WF7RIILsyYcdPiFbrSBA) retrieved 2026-07-04 2. T4 [https://tracxn.com/d/companies/kaspi/g5-wiGqv5O2ekPLG1vMJXv0WF7RIILsyYcdPiFbrSBA](https://tracxn.com/d/companies/kaspi/g5-wiGqv5O2ekPLG1vMJXv0WF7RIILsyYcdPiFbrSBA) retrieved 2026-07-04 3. T4 [https://grokipedia.com/page/List_of_banks_in_Kazakhstan](https://grokipedia.com/page/List_of_banks_in_Kazakhstan) retrieved 2026-07-04 4. T4 [https://tracxn.com/d/companies/kaspi/g5-wiGqv5O2ekPLG1vMJXv0WF7RIILsyYcdPiFbrSBA](https://tracxn.com/d/companies/kaspi/g5-wiGqv5O2ekPLG1vMJXv0WF7RIILsyYcdPiFbrSBA) retrieved 2026-07-04 5. T3 [https://www.bitget.com/amp/news/detail/12560605487419](https://www.bitget.com/amp/news/detail/12560605487419) retrieved 2026-07-04 6. T4 [https://tracxn.com/d/explore/fintech-startups-in-kazakhstan/3zSW3FiUKVYTSme93A1-gH5aLwUw8-BZL-oL1MYxmQg](https://tracxn.com/d/explore/fintech-startups-in-kazakhstan/3zSW3FiUKVYTSme93A1-gH5aLwUw8-BZL-oL1MYxmQg) retrieved 2026-07-04 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for Kazakhstan| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 75 finding(s), 146 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).