Why Choose Kazakhstan for Crypto Licensing?
Kazakhstan offers a common-law digital-asset regime whose capital floors start at USD 10,000 for advisory and arranging activity. The AIFC operates an English-language, English-law perimeter inside Kazakhstan with its own court, financial-services authority (AFSA), public register, and consolidated digital-asset rulebook in force since .[1] The IOSCO Thematic Review of placed the AIFC among the four of the twenty reviewed jurisdictions that fully implement all ten priority recommendations for crypto and digital-asset markets, in force as of 31 July 2025.[2]
IOSCO Top-Four Recognition Without the Dubai Price Tag
The AIFC sits in IOSCO’s top tier of digital-asset implementation, but its entry costs are lower than under Dubai’s VARA framework.[3][4] The base capital for operating a Digital Asset Trading Facility (DATF) is USD 200,000 or twelve months of operating expenses, whichever is higher,[5][36] compared with AED 1,500,000 (around USD 408,000) for a VARA Exchange Services Provider that does not use a VARA-licensed custodian.[6] The advantage is not uniform: VARA’s floor for custody services is AED 600,000 (around USD 163,000), below the AIFC’s USD 250,000 for custody and principal dealing.[4]
For founders who want regulatory credibility that holds up in front of EU correspondent banks and institutional counterparties, but cannot justify Dubai-scale capital deployment at launch, Kazakhstan is the structurally cheaper route to a credible licence.
A Working Crypto-to-Fiat Rail
For operators seeking a fiat off-ramp, the AIFC offers a live crypto-to-fiat rail: the AIFC and the National Bank of Kazakhstan formalised cooperation between AIFC-licensed exchanges and Kazakhstan second-tier banks in , building on a 2022 pilot that involved five exchanges and eight banks.[7] AFSA’s Annual Report 2025 records 29 DASPs at the end of 2025 (9 on the full regime, one that transitioned in the fourth quarter, and 19 in the FinTech Lab), with total DASP transaction volume of about USD 10.58 billion in 2025 and around 215,000 clients.[8] Twelve of them are exchanges, according to AFSA’s chief executive in December 2025.[28] The crypto-to-fiat bridge is not theoretical: it is operational at scale, with USD, KZT and EUR settlement.
A Tax Regime Worth Reading Carefully
The AIFC tax exemption is genuinely meaningful. AIFC participants pay 0% corporate income tax (CIT) on qualifying financial-services income until , those services are exempt from value-added tax (VAT), and foreign employees of AIFC Bodies and of participants providing those services are exempt from personal income tax (PIT) on AIFC employment income until the same date.[9][10] The single most important caveat to understand before structuring: digital-asset trading facility operators are explicitly excluded from the 0% CIT exemption and pay the standard Kazakhstan corporate rate of 20%. Custody, dealing, advising, arranging, and stablecoin-issuance DASPs retain the exemption; exchanges do not.
English-Language, Common-Law Operating Environment
The AIFC’s founding instrument adopts the principles of English law and establishes the AIFC Court under the leadership of Lord Burnett of Maldon, the former Lord Chief Justice of England and Wales.[10] English is the official working language of the AIFC, AFSA, the AIFC Court, and the public register.[11] For founders accustomed to BVI, Singapore or DIFC, the regulatory and dispute-resolution interface is familiar.
For founders coming from the EU, the gap is narrower than it is in BVI or Seychelles, because the AIFC’s IOSCO-aligned rulebook reads in the same conceptual register as MiCA.
Regulatory Framework
The AIFC operates a special legal order inside Kazakhstan, established by the Constitutional Statute on the AIFC No. 438-V of , which adopts the principles of English law within the AIFC perimeter and creates a financial-services regulatory regime separate from mainland Kazakhstan law.[10] The primary digital-asset rulebook is the AIFC Rules on Digital Asset Activities (DAA), AIFC Rules No. FR00062 of 2023, approved on and in force since ; a consolidated version (v2) commenced on , and further AFSA-adopted amendments commenced on .[1][12]
Definition: AIFC DASP
A Digital Asset Service Provider (DASP) is an entity authorised by the AFSA to carry on one or more of ten regulated digital-asset activities within the AIFC perimeter, including operating a Digital Asset Trading Facility, dealing in or providing custody of digital assets, advising on or arranging deals in digital assets, and providing money services in relation to digital assets (which includes fiat-stablecoin issuance). The framework is governed by the AIFC Rules on Digital Asset Activities (DAA), supervised by AFSA, and tax-treated under the AIFC’s special regime (with the DATF activity carved out from the 0% CIT exemption). Conceptually, the AIFC DASP designation maps to the FATF Virtual Asset Service Provider (VASP) perimeter, although terminology differs.
Regulatory History
The AIFC was established to anchor Kazakhstan’s financial-services modernisation strategy and was modelled in part on the DIFC. The digital-asset perimeter was progressively built between 2018 and 2023: an early FinTech Lab regime accommodated crypto exchanges from 2018; Article 4-1 of the Constitutional Statute (added on ) created an explicit constitutional basis for digital-asset regulation; the consolidated DAA replaced the fragmented earlier rules in .[13]
From 2022 onwards the National Bank piloted cooperation with AIFC-licensed exchanges to enable crypto-to-fiat conversion through Kazakhstani second-tier banks, formalised in .[7] At the end of there were 29 AFSA-licensed DASPs, with about USD 10.58 billion of DASP transaction volume in the year.[8]
Recent Regulatory Developments
- : amendments to the Law “On Digital Assets in the Republic of Kazakhstan” take effect and the National Bank of Kazakhstan begins licensing crypto-exchange operators outside the AIFC; AFSA continues to regulate digital-asset firms inside the AIFC.[30]
- : AFSA and Dubai’s VARA sign a memorandum of understanding on cooperation, mutual assistance and information exchange in licensing, supervision, and enforcement.[32]
- : AFSA fines two AIFC firms USD 249,770 and USD 139,533 for unauthorised Islamic-finance activity, and its Registrar petitions the AIFC Court to wind up both firms and two related special purpose companies.[14] The action is non-DASP, but signals AFSA’s enforcement appetite.
- : Phase 2 of the AIFC Rules on Providing Money Services (client protection and cyber resilience) commences, completing the framework AFSA adopted in , whose first phase took effect on .[21]
- : AFSA adopts capital-market, digital-asset, and crowdfunding framework amendments effective , including a revised DATF capital formula and a higher (50%, from 30%) inclusion rate for digital assets in the Assessed Professional Client net-asset test.[12]
- : Fees Rules amendments take effect, raising the digital-asset add-on application fee to USD 2,800 and capping the variable supervision fee at USD 250,000.[15]
- : IOSCO Thematic Review identifies AIFC as one of four among twenty reviewed jurisdictions fully implementing all ten priority recommendations on crypto and digital-asset markets.[2]
- : AFSA announces the first regulatory-fee payment in a USD-pegged stablecoin (USDT), processed by a provider that has signed a Multilateral Memorandum of Understanding (MMoU) with AFSA.[33]
- : AFSA grants the AIFC’s first fiat-backed stablecoin licence to a CNH-pegged issuer under DAA Part 4; the issuer is testing its services in the FinTech Lab.[34][8]
Regulatory Overlap
Three regimes can apply simultaneously to AIFC DASPs depending on activity:
- AIFC DAA. Primary licensing rulebook for all digital-asset activity inside the AIFC perimeter.
- AIFC AML/CFT/Sanctions Rules (Amendment No. 7, ). Applies to every DASP regardless of activity; embeds FATF Travel Rule obligations and aligns with the FATF Best Practices on Travel Rule Supervision of .[16]
- AIFC Rules on Providing Money Services. Applies to DASPs issuing fiat- or commodity-backed stablecoins (Phase 1 from ; Phase 2 from ).
The mainland Kazakhstan AML law (Law No. 191-IV of “On Counteracting Legalisation of Criminally Obtained Income and Financing of Terrorism”) governs reporting to the Financial Monitoring Agency (FMA) of the Republic of Kazakhstan, which AFSA-licensed DASPs file into for STRs and SARs.
Tokenised securities and RWA
Security tokens and tokenised real-world assets sit outside the DASP regime described above. They run through a separate AIFC pathway: the AIFC Security Token Offering (STO) Framework, in force since , which governs the issuance and trading of security tokens within the AIFC perimeter and is one of the earliest dedicated STO regimes globally. Authorisation for security-token issuance and trading is granted by AFSA under that framework, not under a digital-asset activity head. The distinction matters: a national crypto authorisation under Kazakhstan’s Law on Digital Assets (in force , which covers non-security crypto such as exchanges and mining) does not extend to security tokens, and neither does an AIFC DASP licence.
Where a token is a financial instrument, a tokenised share, bond or fund interest, we scope the security-token route through the AIFC STO Framework rather than the DASP heads, and we pair it with crypto custody or trading permissions only where the operating model needs them. For fund-unit tokenisation specifically, the analysis runs through our fund licensing guidance, where the vehicle stays under the fund regime rather than a securities regulator.
License Types and Activities Covered
The AIFC recognises ten Digital Asset Service Provider activity heads under the DAA, each requiring a separate AFSA authorisation. Applicants can hold one or several authorisations under the same legal entity, subject to AFSA approval. The activities collectively cover the FATF VASP perimeter and broadly map to MiCA’s ten CASP services, although terminology and capital differ.[1][17]
Covered Activities
- Operating a Digital Asset Trading Facility (DATF). Running a venue that matches buyers and sellers of digital assets, with or without integrated custody. The flagship DASP category: twelve of the 29 licensed DASPs operated exchanges in December 2025, according to AFSA’s chief executive.[28]
- Dealing in Digital Assets as Principal. Buying and selling digital assets on own account against clients, including over-the-counter (OTC) market-making.
- Dealing in Digital Assets as Agent. Executing trades on behalf of clients without taking principal risk; broker-style activity.
- Managing Investments (Digital Asset Portfolios). Discretionary or non-discretionary portfolio management of clients’ digital assets.
- Managing a Collective Investment Scheme (Digital Asset CIS). Operating a regulated fund whose constituent assets are digital assets, in line with the AIFC Collective Investment Scheme Rules.
- Providing Custody of Digital Assets. Holding, controlling or safeguarding clients’ digital assets, including private-key management.
- Arranging Custody of Digital Assets. Acting as an intermediary that places clients’ digital assets with a third-party custodian.
- Advising on Investments in Digital Assets. Providing personal recommendations to clients on digital-asset transactions.
- Arranging Deals in Investments in Digital Assets. Bringing parties together to enter into digital-asset transactions without dealing as principal or agent.
- Providing Money Services in Relation to Digital Assets. Issuance, transmission, and exchange of fiat-backed and commodity-backed stablecoins, governed by DAA Part 4 and the Providing Money Services Rules.
What Does NOT Require Registration
- Privacy-token activity is prohibited under the DAA, not merely unregistered. AFSA does not authorise activity in tokens designed to obfuscate transaction trails.
- Crypto services to Kazakhstan residents outside the AIFC fall under the national regime, not AFSA’s: Article 11(5) of the Law “On Digital Assets in the Republic of Kazakhstan” prohibits organising the circulation of digital assets in Kazakhstan without a licence under AIFC law or national legislation, and since the National Bank of Kazakhstan licenses and supervises crypto service providers outside the AIFC, licensing exchange operators and registering trading platforms.[31][30]
- Pure mining and validation activity falls under the mainland regime and Astana Hub framework, not under AFSA’s DASP perimeter. AIFC DASPs that wish to mine for their own account need separate consideration of mainland licensing. Since , large mainland miners can additionally opt into the voluntary strategic digital mining scheme under Government Resolution No. 638 of : an electricity quota at regulated ceiling tariffs in exchange for transferring a share of mined assets, via the Astana Hub fund, toward the National Strategic Crypto Reserve. Entry requires an owned digital-mining data centre of at least 150 MW, applications run through the e-licensing platform, and participation is voluntary, so the baseline mainland mining framework is unchanged.[24]
- Personal use of digital assets by AIFC employees and residents is not within the DASP perimeter.
Activity Restrictions
A DASP must stop an individual retail client resident in Kazakhstan from depositing more than USD 1,000 in a calendar month unless the client passes the provider’s test of knowledge and experience in high-risk investment, and a DATF may offer such clients margin trading only within the limits for their client category, with losses capped at the pre-funded amount.[35] From , the Assessed Professional Client net-asset test counts 50% of the market value of digital assets admitted to trading, up from 30%, and reserve-backed fiat or commodity stablecoins at 100%.[12][36]
Requirements
AFSA applies an integrated set of capital, substance, governance, technology, and AML requirements that scale by activity head. The minimum capital for advisory and arranging activity is USD 10,000, rising to USD 200,000 for DATF operators and USD 250,000 for principal dealers and custodians.[5]
Where Chapter 4 of the Prudential Rules for Investment Firms applies, applicants must also hold liquid assets of at least 25% of annual operating expenditure (Expenditure-Based Capital Minimum, EBCM);[41] all applicants must maintain physical presence on AIFC territory, and conduct their core income-generating activities (CIGA) on AIFC territory; outsourcing of CIGA outside Kazakhstan is not permitted.[18]
Capital Requirements by Activity
| Activity Head | Notes | Base Capital (USD) |
|---|---|---|
| Operating a DATF | If the DATF includes integrated custody, 250,000 | 200,000 or 12 months of operating expenses, whichever is higher |
| Dealing in Digital Assets as Principal | Matched-principal only: 50,000 | 250,000 |
| Dealing in Digital Assets as Agent | 50,000 | |
| Managing Investments | 100,000 | |
| Managing a Collective Investment Scheme | By scheme type (per AIFC CIS Rules) | 50,000 / 150,000 / 250,000 |
| Providing Custody | 250,000 | |
| Arranging Custody | 10,000 | |
| Advising on Investments | 10,000 | |
| Arranging Deals in Investments | 10,000 | |
| Providing Money Services (incl. fiat stablecoin issuer) | Plus 1:1 reserve requirement for stablecoin issuance | 200,000 |
| Liquid asset floor | Where PRU(INV) Chapter 4 applies | ≥25% of Annual Operating Expenditure (EBCM) |
Intangible assets are excluded from regulatory capital. Stablecoin reserves must be held 1:1, segregated, in a FATF-equivalent jurisdiction custodian, marked to market daily, and independently audited annually under DAA Part 4. Capital figures checked against the consolidated DAA on ; a firm holding several activities must meet the highest applicable floor, not their sum.[36]
Governance and Senior Management Regime
DASPs must appoint Approved Individuals (AIs) for six controlled functions: Senior Executive Officer (SEO), Finance Officer, Compliance Officer, Money Laundering Reporting Officer (MLRO), Deputy MLRO, and Chief Information Technology Officer (CITO). AFSA may direct appointment of a separate Risk Manager where the business model warrants. The Effective Board is collectively accountable for the firm’s compliance with the AIFC Acts. Each AI is subject to fit-and-proper assessment under the General Rules, Chapter 4, and approval before the firm can commence regulated activity.[19]
Substance and Substantial Presence
The AIFC Rules on Substantial Presence (adopted by AFSA in coordination with the Kazakhstan Ministry of Finance) require AIFC participants applying the CIT and VAT exemptions to conduct their CIGA on AIFC territory, maintain expenditure on AIFC territory commensurate with that CIGA, and employ adequate full-time staff on AIFC territory.
Outsourcing of CIGA outside Kazakhstan is not permitted. Compliance is determined by the state revenue authority in a tax audit, and a participant that fails the test is taxed under the ordinary Tax Code.[18] In practice this rules out the shell-with-virtual-office structure that some applicants assume is workable on a reading of the headline capital figures.
Technology and Cyber Requirements
Every DASP must maintain a documented cyber-security policy, segregate hot- and cold-wallet holdings, implement key-management procedures appropriate to scale, conduct daily reconciliation between book and on-chain balances, and commission an annual third-party audit of technology governance and IT systems before authorisation and on each subsequent renewal cycle.[1] DATFs must additionally subject member systems to regular testing.
There is no standalone DORA-style ICT rulebook in the AIFC: technology requirements are integrated into the DAA proper, which means cyber and operational-resilience obligations are read alongside conduct and prudential rules rather than as a separate workstream.
Application Process
AFSA’s published authorisation pathway runs from pre-application engagement through Authorisation In Principle (AIP) to full licence, with a parallel registration through the AIFC Registrar of Companies. AFSA describes pre-application engagement as a “general recommendation rather than an option” and applicants who skip it routinely face longer review cycles and additional information requests.[20] The application language is English throughout; supporting documents in Russian or Kazakh are accepted but must be accompanied by certified English translations.
Pre-application engagement
Engage the AIFC Client Office and AFSA Authorisation team before drafting documentation. AFSA expects to see the regulatory business plan, governance structure, and AI candidates discussed in principle before formal submission. Pre-application weeks are not counted in published timelines, but they meaningfully reduce the rejection and resubmission rate in the formal phase.
Form an AIFC entity and engage AIFC participants
Forming an AIFC Private Company through the AIFC Registrar of Companies is the first step. This runs in parallel with appointing an AIFC-based legal adviser, leasing AIFC office space, and onboarding key personnel. AIFC registration typically takes 5–20 working days, commonly about two weeks, through the digitalresident.kz self-service portal. See the Kazakhstan company formation guide for entity-type selection and registration mechanics.
Prepare the Regulatory Business Plan and supporting policies
Draft a three-year regulatory business plan with financial projections, AML/CFT/sanctions policies, IT and cyber-risk policies, custody and wallet-management procedures, complaints handling, conflicts of interest, business continuity plan, and a Risk Mitigation Programme. Commission the mandatory third-party technology audit. The compliance documentation pack is the most time-intensive component.
Submit through the AFSA Self-Service Portal
File the application with all supporting documents, paid application fee (the FEES table 1.1 activity fee plus the USD 2,800 digital-asset add-on, which a DATF does not pay), Approved Individual applications (USD 500 each in full regime, USD 200 in FinTech Lab), and the regulatory business plan.[26] AFSA acknowledges the application and begins formal review.
Formal AFSA review and information requests
AFSA assesses fit-and-proper of Controllers and AIs, capital adequacy, governance, operational readiness, and AML/CFT robustness. Expect one to three rounds of formal information requests, each typically with a 14- to 28-day response window.
Authorisation In Principle (AIP) and conditions
AFSA issues AIP with a set of conditions to be satisfied before the licence becomes effective: capital deposit, banking arrangement, final AI appointments, evidence of substance, completion of third-party audits, and so on.
Full licence and commencement
On satisfaction of AIP conditions, AFSA grants the full licence and the firm appears on the AFSA Public Register. The initial supervision fee is payable within 21 days of grant.
The compliance documentation (the AML/CFT/sanctions framework, the Travel Rule policy, the custody and wallet-management procedures, and the technology governance documentation) is the most time-intensive component of any AIFC DASP application, typically eight to twelve weeks of specialist work that generic templates cannot shortcut. It is drafted within the licensing engagement by the independent specialist introduced for the case.
AFSA specifically tests whether policies are bespoke to the applicant’s business model rather than generic boilerplate. Send us a written brief at the start of Stage 2 to scope the engagement.
FinTech Lab On-Ramp
For novel models or earlier-stage firms, the FinTech Lab offers a sandbox on-ramp. At the end of 2025, 19 of the 29 licensed DASPs were operating inside the FinTech Lab and 10 on the full regime; AFSA reports that graduation to the full regime has been slower than expected, with one migration in 2025.[8] Application and supervision fees are reduced, capital requirements are scaled, and AFSA provides closer supervisory engagement.
Required Documents
AFSA’s Authorisation Pack lists every document required at submission. The pack divides into five categories: corporate documents, personal documents for every Controller and Approved Individual, the compliance documentation suite, the business plan, and financial projections, and the technology and operational documentation. AFSA expects bespoke, AIFC-specific policies rather than generic crypto-industry templates; reviewers actively test against this.[20]
Corporate Documents
- Certificate of incorporation and constitutional documents of the AIFC entity (issued by the AIFC Registrar of Companies).
- Group structure chart from the operating entity up to ultimate beneficial owners, with percentages.
- Certified shareholders’ register and most recent annual return.
- Certified register of directors and senior officers.
Personal Documents (every Controller, Approved Individual and 10%+ UBO)
- Certified passport and proof of address (utility bill or bank statement dated within three months).
- Police clearance certificate (or equivalent) from every jurisdiction of residence in the past ten years, dated within three months.
- Curriculum vitae detailing relevant financial-services experience.
- Financial standing declaration with supporting bank statements or tax filings.
- Completed AFSA Fit and Proper Form, signed.
Compliance Documentation
The typical components of the AIFC-specific compliance pack are:
- AML/CFT/Sanctions Manual. Risk-based customer due-diligence framework calibrated to AIFC AML/CFT Rules Amendment 7 and Kazakhstan FMA filing requirements.
- Travel Rule Policy. Procedure for collecting, transmitting, and receiving originator/beneficiary information on virtual-asset transfers, aligned with FATF Recommendation 16.
- Custody and Wallet Management Procedure. Hot/cold segregation, multi-signature controls, key-management lifecycle, daily reconciliation.
- Cyber and Information Security Policy. Tested annually by a third-party auditor; integrated with the BCP and incident-response plan.
- Conflicts of Interest Policy. Identification, escalation, mitigation.
- Complaints Handling Procedure. Aligned with AFSA Conduct of Business (COB) Rules.
- Business Continuity and Disaster Recovery Plan. RPO/RTO assumptions tested annually.
- Outsourcing Policy. With AFSA-mandated carve-out: CIGA cannot be outsourced outside Kazakhstan.
- Risk Mitigation Programme. Post-licence compliance roadmap submitted with the application.
Business Plan and Financial Projections
- Three-year regulatory business plan describing target clients, products, distribution channels, market entry, regulatory rationale, and exit scenarios.
- Three-year financial projections (P&L, balance sheet, cash flow) including base, stretch, and downside scenarios.
- Capital deployment plan demonstrating compliance with the activity-specific capital floor and any applicable liquidity requirement.
Technology and Operational Documentation
- Description of the technology stack, including custody architecture, trading-engine design (for DATFs), settlement flow and on-chain integration.
- Third-party technology audit report (mandatory before AIP).
- CITO appointment and supporting CV.
- Outsourcing register with the AFSA-mandated CIGA carve-out.
Costs and Pricing
AFSA publishes its fee schedule in the AIFC Fees Rules, with the most recent amendments effective raising the digital-asset application add-on to USD 2,800 and reducing the variable supervision-fee cap to USD 250,000.[15] AFSA also accepts regulatory fees in USD-pegged stablecoins, paid through a licensed provider acting as the payer’s agent; it announced the first such payment, in USDT, on and describes the mechanism as the first of its kind in the region.[33] On the figures below, the total cost of an AIFC DASP licence sits below the VARA ranges shown in the comparison further down.
Government / AFSA Fees
| Fee Item | Notes | Amount (USD) |
|---|---|---|
| Activity application fee (FEES table 1.1) | 7,000 for a single activity such as Providing Custody or Advising on Investments; 98,000 for Operating a Digital Asset Trading Facility (DATF). Each further activity adds 50% of its own fee | 7,000–98,000 |
| Digital-asset add-on application fee (FEES 1.1-1) | Charged once on digital-asset activities other than a DATF; a DATF does not pay it | 0–2,800 |
| Approved Individual applications | 500 per AI in the full regime, 200 in the FinTech Lab. Minimum six AIs typically required; the upper figure assumes ten | 3,000–5,000 |
| AIFC company registration | Self-Service Portal 500; paper submission 1,500 | 500–1,500 |
| Change-of-control application | Charged only where a change of control is filed at launch | Up to 1,400 |
| FinTech Lab token-admission application | Per token, FinTech Lab participants only; not in the statutory total | Up to 50 |
| Initial supervision fee | Payable within 21 days of grant: the annual supervision fee pro-rated over the whole months left in the year of grant (FEES 3.1.2, 3.1.4). It depends on the grant date, so it is not in the total | Formula |
| Statutory cost, Year 1 | Lower end: one USD 7,000 activity with the add-on, six AIs and online registration. Upper end: a single-head DATF with ten AIs, paper registration and a change of control. The initial supervision fee is added on grant | 13,300–105,900 |
| Annual supervision fee (fixed + variable) | Set by formula (FEES 3.1.5, Schedule 6): the highest fixed fee of the licensed activities plus 50% of each further one, variable fees in full, and 2,800 for digital-asset activities other than a DATF. A DATF pays 30,000 plus a trading levy, invoiced up to 250,000 a year. For 2026 only the highest fixed and highest variable fee apply (FEES 3.1.6). The Registrar also charges annual filing fees (FEES Schedule 5-2): online, USD 50 for an annual return or for accounts and USD 20 for a confirmation statement, which an eligible private company may file instead of an annual return; paper filings cost double.[26][27] | Formula; levy capped at 250,000/year |
Total Cost Summary
| Cost Component | Notes | Year 1 Range (USD) |
|---|---|---|
| AIFC company formation and registered office | Formation agent and the first year of office and registered address; the AIFC registration fee is counted in the statutory table above | 3,000–8,000 |
| Legal advisory (AIFC counsel) | End-to-end authorisation guidance | 30,000–60,000 |
| Compliance documentation pack (AML, Travel Rule, custody, cyber) | Bespoke, not template | 20,000–40,000 |
| Third-party technology audit | Mandatory before AIP | 8,000–20,000 |
| Substance setup (AIFC office, local hires, executive search) | Genuine AIFC-territory CIGA, not virtual | 20,000–50,000 |
| Typical build, Year 1 (quoted per case) | Single-activity DASP at lower end; DATF at upper | 81,000–178,000 |
| Initial capital deposit | Depends on activity head; locked in rather than spent, so it sits outside both totals | 10,000–250,000+ |
| Indicative ongoing budget, Year 2 onward (quoted per case; not a DATF ceiling) | AFSA supervision, compliance, office, staff and technology audit must be budgeted for the actual permissions and volume. DATF supervision alone can reach USD 280,000 a year: USD 30,000 fixed plus up to USD 250,000 variable, before operating costs.[26] | 50,000–120,000/year |
Statutory fees as of (AIFC Fees Rules as amended from ); build figures as of . Verify against the current Fees Rules before submission: in July 2026 AFSA consulted on a fee model that would raise fees annually over 2027–2029.[39] Under FEES 5.1.3, AFSA may reduce, waive or refund all or part of any fee where it considers that equitable in a particular case.[26]
Timeline
The headline authorisation timeline runs from initial AFSA engagement to licence grant. A well-prepared single-activity DASP authorisation completes faster than a DATF or multi-activity package, because the technology audit, capital deposit, and Approved Individual approval cycle scale with scope. The cumulative figures below assume each stage runs in sequence; in practice several stages overlap.
| Stage | Duration | Cumulative |
|---|---|---|
| Pre-application engagement with AIFC Client Office and AFSA | 2–4 weeks | 2–4 weeks |
| AIFC entity formation through Registrar of Companies | 2–4 weeks | 4–8 weeks |
| Regulatory business plan and compliance documentation drafting | 8–12 weeks | 12–20 weeks |
| Third-party technology audit | 4–8 weeks (parallel) | 12–20 weeks |
| Formal AFSA review and information rounds | 8–20 weeks | 20–40 weeks |
| Authorisation In Principle conditions satisfaction | 4–12 weeks | 24–52 weeks |
| Full licence grant | 1–2 weeks | 25–54 weeks |
The fastest realistic timeline for a well-prepared single-activity DASP authorisation (Advising on Investments, Arranging Deals) is approximately six months (25 weeks on the stage table above) from initial AFSA engagement to licence grant. DATF authorisations and multi-activity packages routinely take longer, up to about twelve months, because the technology audit, capital deposit, and AI approval cycle take longer in proportion to scope. The FinTech Lab on-ramp typically adds six to eighteen months between FinTech Lab entry and full-regime migration, but reduces capital and fee burden during the testing phase; it suits novel models that can accept the longer path. Since , firms already licensed by a regulator on AFSA’s list of acceptable regimes (the FCA, ASIC, MAS, the Hong Kong SFC and HKMA, the ADGM FSRA, the DFSA and the QFCRA) can apply through a fast-track process with a reduced application package.[40]
Taxation
The AIFC operates a long-dated special tax regime, but the structure has one important carve-out for digital-asset operators that founders frequently miss. AIFC participants pay 0% corporate income tax on qualifying financial-services income until , those services are exempt from VAT, and foreign employees of AIFC Bodies and of participants providing those services are exempt from personal income tax on AIFC employment income, conditional on satisfying the AIFC Substantial Presence Rules.[9][10][18] The Constitutional Statute excludes the digital-asset exchange from the corporate-tax exemption, and so from the VAT exemption that follows it.[10]
Tax Table
| Tax Type | Rate | Crypto Application |
|---|---|---|
| Corporate Income Tax (AIFC participant, non-DATF) | 0% | Until 1 January 2066, conditional on substance test |
| Corporate Income Tax (DATF operator) | 20% | Standard Kazakhstan rate; AIFC exemption does not apply |
| Value Added Tax (AIFC participant, qualifying) | Exempt | Qualifying AIFC financial services; conditional on substance |
| Value Added Tax (DATF operator) | 16% | Standard Kazakhstan rate from 1 January 2026; AIFC exemption does not apply |
| Personal Income Tax (foreign employees of qualifying AIFC participants) | 0% | On AIFC employment income, for participants providing the exempt financial services (Article 6(6)) |
| Personal Income Tax (Kazakhstan tax residents) | 10% / 15% | On worldwide income; 15% on annual income above 8,500 MCI from 2026 |
| Withholding Tax (dividends, AIFC) | 0% | Subject to AIFC participant status |
| Withholding Tax (royalties, IP-derived income) | 15% | IP-derived income NOT exempt under AIFC regime |
| Capital Gains Tax (AIFC investment residents on AIX securities) | 0% | Limited exemption |
Rates as of September 2026, under the Tax Code in force from 1 January 2026.[37][42] Verify against the Kazakhstan State Revenue Committee and the latest AIFC tax notice before structuring.
CRS and CARF Reporting
Kazakhstan has exchanged financial-account information under the Common Reporting Standard (CRS) since 2021, although the OECD’s 2025 peer review rated its CRS legal framework “Not In Place” and its effectiveness “Non-Compliant”.[38] It is also in the OECD Inclusive Framework. Kazakhstan has committed to first automatic exchanges under the Crypto-Asset Reporting Framework (CARF) in 2027, and the OECD Global Forum ran an implementation support programme with the State Revenue Committee, the Ministry of Finance, the National Bank and the AIFC in May 2026. The domestic implementing rules that fix the first reporting period have not been published yet, so an AIFC DASP should be building CARF-shaped onboarding and record-keeping now rather than after they appear.[25]
Double Taxation Treaty Network
Kazakhstan has 55 conventions in force for the avoidance of double taxation, including with the United Kingdom, Germany, France, the Netherlands, Switzerland, Singapore, the United Arab Emirates, China, and most CIS member states.[22] AIFC participants generally qualify for treaty relief subject to the substance test under the AIFC Substantial Presence Rules.
Substance Condition
Every tax exemption is conditional on satisfaction of the Substantial Presence Rules (set out under Requirements, above): CIGA on AIFC territory, adequate full-time employees, commensurate local expenditure, and no outsourcing of CIGA outside Kazakhstan, assessed by the state revenue authority in a tax audit. A participant that fails the test is taxed under the ordinary Tax Code.[18]
Ongoing Compliance & Post-Registration
AFSA supervises authorised DASPs through periodic reporting, thematic reviews, on-site inspections, and enforcement powers. The AIFC’s IOSCO-recognised supervisory model is one of the AIFC’s clearest competitive advantages over light-touch offshore peers, but it does translate into a real ongoing compliance burden. Founders should plan for a year-round compliance cadence rather than a one-off authorisation push.
Annual Reporting
- Audited financial statements filed within four months of financial year-end.
- Quarterly prudential returns demonstrating compliance with the applicable capital and liquidity requirements.
- Annual AML/CFT return covering customer-due-diligence statistics, STR/SAR volumes and risk assessment updates.
- Annual Risk Mitigation Programme update to AFSA.
- Annual third-party technology audit (refreshed each year).
Inspections and Thematic Reviews
AFSA conducts both routine and thematic supervisory visits. The AFSA 2025 Annual Report records 51 supervisory engagements with FinTech Lab DASPs in 2025, covering rule breaches, supervisory conditions, late-filing fees and changes of ownership or senior management.[8] In practice, visit frequency scales with firm size and activity head: DATFs typically receive annual on-site engagement; smaller advisers operate on a remote-supervision cadence with periodic spot checks.
Enforcement Powers
AFSA’s enforcement toolkit includes warnings, financial penalties, licence variation or withdrawal, prohibition orders against named individuals, public censure, and AIFC Court compulsory winding-up petitions. The AFSA Revised Enforcement Policy of sets out the calibration framework. On AFSA fined one AIFC firm USD 249,770 and a related firm USD 139,533 for unauthorised Islamic-finance activity, and its Registrar petitioned the AIFC Court to wind up both firms and two related special purpose companies.[14] The action was non-DASP, but it confirms AFSA’s willingness to act decisively when warranted.
Material Change Notifications
Any change of Controller, change of senior management, material amendment to the regulatory business plan, change of auditor, or addition of new activities requires AFSA notification or pre-approval. AFSA’s change-of-control application fee is USD 1,400. Material changes implemented without notification can result in licence variation, financial penalty or enforcement action.
Banking
The AIFC has an operating crypto-to-fiat banking rail, anchored by formal cooperation between AIFC-licensed exchanges and Kazakhstan second-tier banks since the National Bank and AFSA signed implementing rules in .[7] The 2022 pilot involved five AIFC exchanges and eight Kazakhstani banks; the framework now supports the whole DASP ecosystem (29 licensed DASPs at the end of 2025) with USD, KZT, and EUR settlement. Banking onboarding remains a process that takes time, but unlike some offshore jurisdictions the rail is operational rather than aspirational.
Banking Archetypes Available to AIFC DASPs
The institutional bank landscape relevant to AIFC DASPs falls into four archetypes:
- Kazakhstan second-tier banks with AIFC cooperation status. Provide KZT accounts, crypto-to-fiat conversion under the National Bank / AFSA framework, and increasingly USD and EUR multi-currency facilities. The natural fit for an AIFC DASP’s primary operating account.
- International banks with AIFC branches or representative offices. Provide multi-currency banking, often with global treasury management capability. Onboarding selectivity reflects each bank’s own risk appetite for digital-asset clients.
- EU and UK electronic money institutions accepting AIFC-licensed clients. Useful for international receivables and cross-border B2B flows. AIFC licence-recognition by EU EMIs has improved materially since the IOSCO Thematic Review of .
- MENA and APAC payment institutions. Relevant for AIFC DASPs whose client base is concentrated in GCC, Turkey, Pakistan or Southeast Asia.
Settlement Currencies and FX
USD, KZT, and EUR are the operational settlement currencies. The Kazakhstani tenge floats freely; AIFC participants are exempt from certain Kazakhstan currency-control restrictions under Article 5 of the Constitutional Statute.
Onboarding Reality
Bank onboarding typically takes 30–90 days from first contact to operational account. The common friction points are source-of-funds documentation for Controllers, beneficial-ownership disclosure for AIFC group structures, and sanctions screening where the Controller is Russian-origin or has CIS exposure. Pre-qualified introductions reduce both onboarding time and rejection rate.
Jagelski & Partners’ banking placement network spans more than 90 institutions across Europe, the United Kingdom, the Middle East, Asia-Pacific, the Caribbean, and the Americas. We do not mark up institutional banking or EMI pricing. A licence without banking access is a certificate on the wall: learn about our Banking service →
Kazakhstan is the rare market in the region where the domestic rail already works: the AFSA cooperation framework gives AIFC DASPs a live route into second-tier banks, while USD and EUR correspondent access still turns on the quality of the introduction.
Kazakhstan second-tier banks under the AFSA cooperation framework, international banks with AIFC presence, EU, and UK EMIs, and MENA and APAC payment institutions, planned as a single architecture. Jagelski & Partners scopes banking options in writing and introduces an independent specialist before a licence application is filed. You contract directly with the specialist; account approval remains the financial institution's decision.
Explore Banking SolutionsFATF Status & International Standing
Kazakhstan is a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), a FATF-style regional body, and is not currently on the FATF list of “Jurisdictions under Increased Monitoring” (grey list) or “High-Risk Jurisdictions subject to a Call for Action” (black list) as updated at the FATF plenary of .[23] The AIFC has independently achieved international recognition as a regulator through the IOSCO Thematic Review of (see Why Choose Kazakhstan, above).[2]
AFSA is a signatory to the IOSCO Multilateral Memorandum of Understanding (MMoU) and the Enhanced Multilateral Memorandum of Understanding (EMMoU), joined IOSCO’s I-SCAN investor-alert network in 2025,[8] and signed a cooperation and information-exchange MoU with Dubai’s VARA on .[32]
EU Market Access
An AIFC DASP authorisation does not confer EU passporting rights. MiCA contains no third-country equivalence regime for crypto-asset service providers, so an AIFC licence cannot be recognised as equivalent in the EU. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative.
ESMA’s Article 61 Guidelines (applicable from ) interpret this restrictively: EU-targeted promotion can amount to solicitation and defeat the exemption; website language, app availability and influencer activity are assessed in context, and none is an automatic test on its own. For full detail on what constitutes solicitation, the negative-scope test, and the documentation requirements, see Reverse Solicitation Under MiCA →.
Advantages and Limitations
The AIFC presents a coherent set of trade-offs rather than a uniformly easy or hard choice. The IOSCO recognition and the AIFC’s English-law common-law operating environment are genuine differentiators; the DATF tax carve-out and the absence of an MiCA passport are real constraints. The decision turns on target market, activity mix, and the founder’s tolerance for the AIFC’s substance bar.
- IOSCO top-four implementation recognition (October 2025). AIFC is one of the four of twenty reviewed jurisdictions fully implementing all ten priority crypto-asset and digital-asset recommendations.
- 0% corporate tax on qualifying income until 2066 for non-DATF DASPs. Custody, dealing, advising, arranging, and stablecoin-issuance DASPs benefit from the AIFC tax exemption subject to the substance condition.
- Common-law environment with English-language regulator and court. AFSA and the AIFC Court operate in English under principles of English law, materially reducing the legal-interface gap for founders coming from UK, BVI, Singapore or DIFC backgrounds.
- Lower capital floors than VARA for trading facilities and advisory work. The DATF base floor is USD 200,000, but twelve months of working capital can require more;[5] the comparator is AED 1,500,000 (around USD 408,000) for the standard VARA Exchange Services tier, and advising needs USD 10,000 against AED 100,000. Custody and dealing-as-principal floors of USD 250,000 sit above VARA’s AED 600,000 (around USD 163,000) for custody and AED 400,000–600,000 for broker-dealer services.[4]
- Operational crypto-to-fiat banking rail. AFSA’s cooperation framework with Kazakhstan second-tier banks (formalised January 2024) provides KZT, USD, and EUR settlement at scale for AIFC DASPs (29 licensed at the end of 2025).
- No grey-list overhead. Kazakhstan was on neither the FATF grey nor black list after the June 2026 plenary.
- No EU passporting. AIFC DASP licence does not confer rights to provide crypto-asset services to EU residents. Mitigation: Operators targeting EU clients can obtain a separate CASP authorisation in an EU member state (full market access via passporting) or, for services provided at the client’s own exclusive initiative only, may fall within the narrow reverse solicitation exemption under MiCA Article 61. Reverse solicitation is an exemption for specific circumstances, not an alternative to CASP authorisation.
- DATF tax carve-out. Exchange operators do not benefit from the 0% AIFC corporate-tax regime and pay Kazakhstan standard CIT of 20%. Mitigation: Structure exchange activity as a sister entity to other AIFC activities where consolidated tax benefit is sought; some operators run custody and stablecoin issuance in a tax-exempt AIFC entity alongside a separate DATF entity that pays standard CIT.
- Substance bar is genuine, not nominal. AFSA requires AIFC-territory CIGA, AIFC office space, and full-time AIFC-based staff; outsourcing of CIGA outside Kazakhstan is not permitted. Mitigation: Plan AIFC physical presence (office, executive search, AIFC-resident senior staff) from the outset; budget approximately USD 20,000–50,000 for substance setup in Year 1.
- Russian-origin Controllers face additional banking-onboarding friction. Kazakhstan is not under OFAC sanctions, but USD and EUR correspondent screening means Russian-passport beneficial owners face deeper due diligence at the international bank layer. Mitigation: Pre-qualified banking introductions, source-of-funds dossier preparation, and (where appropriate) AIFC-resident Controllers as part of the launch team.
- Single-jurisdiction supervisor. Unlike the FCA (UK), DFSA (DIFC) and MAS (Singapore), AFSA does not have the same depth of cross-border enforcement track record. Mitigation: For operators whose institutional counterparties weight regulator track record heavily, plan dual-licensing with a Tier-1 jurisdiction (DIFC, Singapore) once scale supports it.
How Kazakhstan Compares
For founders weighing the AIFC against regional alternatives, the natural peer set is Kyrgyzstan and Uzbekistan within the CIS bloc, and the United Arab Emirates (Dubai’s VARA) as the regional regulatory upgrade. The AIFC sits clearly above Kyrgyzstan and Uzbekistan on regulatory rigour and banking access, and below the UAE on total Year-1 cost. Estonia, under MiCA, is the natural cross-tier EU reference for operators weighing AIFC credibility against full EU passporting access.
| Factor | Kazakhstan (AIFC) | Kyrgyzstan | Uzbekistan | UAE (VARA, Dubai) |
|---|---|---|---|---|
| Licence Type | AIFC DASP under AFSA | Virtual Asset Service Provider licence (NAVA) | NAPP activity-specific crypto licence (exchange / store / depository / mining-pool) | VARA VASP licence (Dubai) |
| Regulator | Astana Financial Services Authority (AFSA) | NAVA (licensing); Financial Market Regulatory and Supervisory Service (FMRS / Finnadzor, supervision) | National Agency for Prospective Projects (NAPP) | Virtual Assets Regulatory Authority (VARA) |
| Timeline | 6–12 months | 2–4 months | 3–6 months | 6–12 months (Exchange 12+) |
| Min. Capital | USD 10,000–250,000 by activity | KGS 40M (around USD 460,000) exchange office; KGS 300M (around USD 3.4M) trading operator from | 5,000 BRV (around USD 186,400 since 1 September 2026) for a crypto-exchange; no published floor for other categories | AED 100,000–1,500,000 (around USD 27,000–408,000) |
| Total Year 1 cost | USD 94,300–283,900 plus the initial AFSA supervision fee | USD 33,000–60,000 | USD 234,100–3,320,800 | USD 360K–2M |
| Corporate Tax | 0% qualifying to 2066; else 20% | 10% standard; some exemptions | 15% standard; 0% on licensed crypto operations until 2029 | 9% federal CIT |
| Local Presence | AIFC office + CIGA on territory + AIFC-resident staff | Kyrgyz entity + in-country servers; resident sole executive for a trading operator only | Uzbek entity; servers in Uzbekistan; 5-year data retention | Dubai office + UAE staff |
| EU Passporting | No (reverse-solicitation only) | No | No | No |
| FATF Status | Member EAG; not grey-listed | Member EAG; not grey-listed | Member EAG; not grey-listed | Member MENAFATF; removed from grey list 2024 |
| Best For | IOSCO-grade operators serving CIS, MENA, APAC | Lightest-touch CIS entry point | Domestic Uzbek market + regional reach | Global Tier-1 operators with deeper capital |
Compare every crypto jurisdiction side by side →
Kyrgyzstan competes on cost and timeline and Uzbekistan on access to its closed domestic market, at a Year-1 cost of USD 234,100–3,320,800 against USD 94,300–283,900 in the AIFC; neither competes on regulatory depth. Founders selecting Kyrgyzstan typically prioritise speed-to-market and minimum capital deployment over institutional banking access, IOSCO recognition or enforcement track record. The AIFC’s regulatory standing and crypto-fiat banking rail are materially stronger. The UAE outranks Kazakhstan on absolute institutional banking depth and global brand recognition, but at several times the all-in Year 1 cost.
When Kazakhstan Is the Right Choice
Choose Kazakhstan if your target market is CIS, Eurasian, MENA or APAC; you prefer a common-law operating environment under English-language supervision; you want IOSCO-grade regulatory rigour with a lower trading-facility capital floor than VARA’s; or you intend to issue a regional stablecoin under DAA Part 4. Consider alternatives if your primary market is EU retail (Cyprus, Lithuania or Malta under MiCA are the better routes); you require minimum-substance lightest-touch authorisation at lowest cost (Kyrgyzstan); or you require global Tier-1 institutional banking depth and your capital deployment is comfortable above USD 400,000 (Dubai VARA or DIFC).
Not sure which column is you? Ask Emma. She compares these jurisdictions in seconds, in your language.
Common Mistakes in Kazakhstan Applications
AFSA’s authorisation process is sufficiently structured that the most common reasons for delay or rejection are predictable. Applicants who anticipate these issues and prepare against them in pre-application engagement materially reduce both the timeline and the iteration count with AFSA reviewers.
- Underestimating the substance requirement. Founders who arrive at AFSA with a virtual office, outsourced CIGA, and no AIFC-resident senior staff routinely return for substantial rework. The Substantial Presence Rules are a hard condition for the tax exemption and a material factor in the authorisation assessment. Plan AIFC physical presence and AIFC-territory CIGA from the outset of the application, not at Authorisation In Principle.
- Submitting generic compliance documentation. AFSA reviewers explicitly test whether AML/CFT policies, custody procedures, Travel Rule policies, and cyber-risk frameworks are bespoke to the applicant’s business model. Generic templates pulled from offshore libraries are recognised on sight and trigger additional review rounds. Compliance documentation must reference the AIFC AML/CFT Rules Amendment 7, Kazakhstan FMA reporting interface, and the applicant’s specific custody and execution architecture.
- Skipping pre-application engagement. AFSA describes pre-application engagement as a “general recommendation rather than an option”: applicants who skip it routinely face longer review cycles and additional rounds of information requests. The pre-application phase is also where AFSA flags activity-head selection issues that, if caught late, force re-submission of the regulatory business plan.
- Not running formation and AFSA application in parallel. AIFC entity formation through the Registrar of Companies and AFSA authorisation are separate workstreams that can run in parallel. Applicants who treat them sequentially add four to six weeks to the overall timeline unnecessarily.
- Underweighting the technology audit. The mandatory third-party technology audit takes four to eight weeks and must be complete before Authorisation In Principle. Applicants who commission it after Stage 4 information requests have already started add unnecessary time to the AIP phase.
- Treating Russian-origin Controller screening as an afterthought. Kazakhstan is not under OFAC sanctions, but USD and EUR correspondent banks screen Russian-passport beneficial owners with deeper diligence. Source-of-funds dossier preparation, pre-qualified bank introductions, and a clear answer to the Controller-residency question should be set at the start of Stage 1, not at the banking stage.
Frequently Asked Questions
An AIFC Digital Asset Service Provider (DASP) licence is an authorisation granted by the Astana Financial Services Authority (AFSA) permitting a legal entity registered in the Astana International Financial Centre (AIFC) to carry on one or more of ten regulated digital-asset activities. These include operating a digital-asset trading facility, dealing in or providing custody of digital assets, advising on or arranging deals in digital assets, and providing money services in relation to digital assets (including fiat-stablecoin issuance). The framework is governed by the AIFC Rules on Digital Asset Activities, in force since .
Yes. AFSA permits a single AIFC-incorporated entity to hold authorisations for several activity heads, subject to AFSA approval of the regulatory business plan, capital, and substance arrangements for each. Multi-activity applications attract the highest single application fee plus 50% per additional activity. The capital requirement for a multi-activity firm is the highest of the activity-specific floors, not their sum, and the substance requirement (CIGA on AIFC territory) applies across the consolidated entity.
No. AIFC DASP authorisations cover the ten regulated activity heads under the DAA, which are predominantly market-facing services. Mining and validation activity falls under Kazakhstan’s mainland regime and Astana Hub framework, supervised by different authorities. AIFC DASPs that wish to mine for their own account or operate validation infrastructure need separate consideration of mainland licensing requirements.
Not through the crypto regimes. Security tokens and tokenised real-world assets run through a separate AIFC pathway: the AIFC Security Token Offering (STO) Framework, in force since , one of the earliest dedicated STO regimes globally, which governs the issuance and trading of security tokens inside the AIFC and is supervised by AFSA. It is distinct from both an AIFC DASP licence and Kazakhstan’s national Law on Digital Assets (in force ), which covers non-security crypto such as exchanges and mining. A national crypto authorisation does not cover security tokens. Where the token is a fund interest rather than a standalone instrument, see our fund licensing guidance, where the vehicle stays under the fund regime.
The fastest realistic timeline for a well-prepared single-activity DASP authorisation is approximately six months from initial AFSA engagement to licence grant. DATFs and multi-activity packages routinely take longer, up to about twelve months, because the third-party technology audit, capital deposit, and Approved Individual approval cycle take longer in proportion to scope. These ranges apply to a direct full-regime application. The AIFC’s FinTech Lab on-ramp is slower: it typically adds six to eighteen months between FinTech Lab entry and full-regime migration, in exchange for lower capital and fees during testing, and suits novel models that can accept the longer path.
The FinTech Lab is AFSA’s structured on-ramp for early-stage or novel-model DASPs. At the end of 2025, 19 of the 29 licensed DASPs were operating inside the FinTech Lab and 10 on the full regime; AFSA reports that graduation to the full regime has been slower than expected, with one migration in 2025. Application and supervision fees are reduced, capital requirements are scaled to the testing phase, and AFSA provides closer supervisory engagement. The FinTech Lab can suit first-time AFSA applicants, novel business models, and operators who want to validate technology and operational design under regulatory supervision before committing to full-regime capital deployment, but it is the slower path to a full licence.
AIFC entity formation, signing-of-documents, and key Controller interactions typically require at least one in-person visit to Astana, although several stages of the AFSA application run remotely through the Self-Service Portal. Senior management (the SEO, Compliance Officer, and MLRO at minimum) are expected to be present on AIFC territory once the firm commences regulated activity, in line with the Substantial Presence Rules and substance requirements.
Minimum capital ranges from USD 10,000 for Advising on Investments, Arranging Deals, and Arranging Custody, through USD 50,000 for Dealing as Agent, USD 100,000 for Managing Investments, USD 200,000 for DATFs and Providing Money Services (including fiat-stablecoin issuance), to USD 250,000 for Providing Custody and Dealing as Principal. For a DATF, the USD 200,000 floor is subject to a higher requirement where twelve months of working capital in fiat, forecast under positive and negative market scenarios, exceeds it. [5]A multi-activity firm must hold the highest of the applicable floors. Where Chapter 4 of the Prudential Rules for Investment Firms applies, the firm must also hold liquid assets of at least 25% of annual operating expenditure (the Expenditure-Based Capital Minimum); otherwise capital and liquidity requirements follow the licensed activity.
Two numbers. AFSA’s published application-stage fees run USD 13,300–105,900 in Year 1, from a single USD 7,000 activity to a single-head Digital Asset Trading Facility, plus an initial supervision fee set by formula on grant. The build around them is quoted per case by the partner carrying the mandate, with an indicative range of USD 81,000–178,000: legal advisory, compliance documentation, third-party technology audit, AIFC entity formation, and substance setup.
The indicative annual operating budget of USD 50,000–120,000 is not a DATF ceiling. DATF supervision alone can reach USD 280,000 a year: USD 30,000 fixed plus a variable trading levy capped at USD 250,000, before staff, office, compliance, and audit costs.[26] DATF authorisations and multi-activity packages run at the upper end of these ranges; simple advisory authorisations run at the lower end. Capital deposit (USD 10,000–250,000+) is locked rather than spent.
No. Kazakhstan is a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), a FATF-style regional body, and is not on the FATF list of “Jurisdictions under Increased Monitoring” (grey list) or “High-Risk Jurisdictions subject to a Call for Action” (black list) as updated at the FATF plenary of . The AIFC has additionally received international recognition through the IOSCO Thematic Review of , which identified AIFC as one of four among the twenty reviewed jurisdictions fully implementing all ten priority crypto-asset and digital-asset recommendations.[2][3]
Yes. The AIFC and the National Bank of Kazakhstan formalised cooperation between AIFC-licensed exchanges and Kazakhstan second-tier banks in , building on a 2022 pilot. AIFC DASPs can open KZT, USD, and EUR accounts with cooperating second-tier banks; international correspondent access depends on each institution’s risk appetite. Onboarding typically takes 30–90 days. Russian-origin Controllers face deeper diligence at the international bank layer; pre-qualified introductions and source-of-funds dossier preparation reduce both onboarding time and rejection rate.
An AIFC DASP licence does not grant EU market access or passporting rights. MiCA contains no third-country equivalence regime for crypto-asset service providers. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative, and ESMA’s guidelines read this exemption narrowly: EU-targeted promotion can amount to solicitation and defeat the exemption; website language, app availability and influencer activity are assessed in context, and none is an automatic test on its own.
Operators seeking systematic EU market access should obtain a separate CASP authorisation in an EU member state. See the Jagelski & Partners guide to reverse solicitation under MiCA for full detail.
AIFC DASPs file audited annual financial statements within four months of financial year-end, quarterly prudential returns demonstrating compliance with the applicable capital and liquidity requirements, an annual AML/CFT return covering customer-due-diligence statistics and STR/SAR volumes, an annual Risk Mitigation Programme update to AFSA, and an annual refresh of the mandatory third-party technology audit.
STRs and SARs are filed to the Kazakhstan Financial Monitoring Agency under the mainland AML law. Material changes (Controllers, senior management, business plan, new activities) require AFSA notification or pre-approval.
Yes. The AIFC AML/CFT/Sanctions Rules Amendment No. 7 () embeds Travel Rule obligations in the AIFC perimeter, and AFSA is among the regulators referenced in the FATF Best Practices on Travel Rule Supervision of . AIFC DASPs must collect, transmit, and verify originator and beneficiary information on virtual-asset transfers in line with FATF Recommendation 16, subject to the threshold and counterparty conditions set out in the AIFC AML Rules.
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References
Show all references
- Astana Financial Services Authority, AIFC Rules on Digital Asset Activities (DAA) v2, AIFC Rules No. FR00062 of 2023 (consolidated 1 January 2025), aifc.kz, accessed .
- International Organization of Securities Commissions, Thematic Review on Implementation of the Recommendations on Crypto and Digital Asset Markets (FR/13/25), October 2025, iosco.org, accessed .
- Astana International Financial Centre, AIFC Recognised Among Global Leaders in Implementing IOSCO Digital Asset Standards, October 2025, afsa.aifc.kz, accessed .
- Virtual Assets Regulatory Authority (Dubai), Company Rulebook Part VI.B.1: Capital Requirements, rulebooks.vara.ae, accessed .
- Astana Financial Services Authority, Operating a Digital Asset Trading Facility, Capital Requirements, afsa.aifc.kz, accessed .
- Virtual Assets Regulatory Authority (Dubai), Exchange Services Rulebook, rulebooks.vara.ae, accessed .
- Astana International Financial Centre, Rules and Mechanisms of Cooperation Between AIFC Participants Carrying Out Digital Asset Activities and Second-Tier Banks, January 2024.
- Astana Financial Services Authority, AFSA 2025 Annual Report: Regulatory Developments and Supervisory Outcomes, afsa.aifc.kz (report PDF, May 2026; announcement on aifc.kz), accessed .
- Astana International Financial Centre, Tax Regime in AIFC, aifc.kz, accessed .
- Republic of Kazakhstan, Constitutional Statute on the Astana International Financial Centre No. 438-V (7 December 2015, consolidated text), aifc.kz, accessed .
- Astana Financial Services Authority, About AFSA, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, AFSA Introduces Amendments to Capital Market, Digital Assets, and Crowdfunding Frameworks in the AIFC, December 2025, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, AFSA Announces New Rulebook on Digital Asset Activities, September 2023, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, AFSA Fines Proportunity Management Company Limited and ACLB Management Company Limited; AIFC Court Compulsory Winding-Up Petition, 21 January 2026, afsa.aifc.kz, accessed .
- Astana International Financial Centre, AFSA Introduces Amendments to the AIFC Fees Rules, November 2025 (effective 1 December 2025), aifc.kz, accessed .
- Financial Action Task Force, Best Practices on Travel Rule Supervision, June 2025, fatf-gafi.org, accessed .
- Astana Financial Services Authority Online Rulebook, Rules Applicable to Digital Asset Service Providers, orderly.myafsa.com, accessed .
- Astana International Financial Centre, Rules on the Substantial Presence of AIFC Participants Applying Tax Exemptions, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, General Rules: Authorisation and Approved Individuals, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, Licensing at AIFC: How to Obtain an AFSA Permit, aifc.kz, accessed .
- Astana International Financial Centre, AFSA Adopts Comprehensive Framework on Providing Money Services, 29 July 2025 (phases in force 13 October 2025 and 13 January 2026), aifc.kz, accessed .
- Republic of Kazakhstan State Revenue Committee, Conventions for the Avoidance of Double Taxation, kgd.gov.kz, accessed .
- Financial Action Task Force, Jurisdictions under Increased Monitoring and High-Risk Jurisdictions subject to a Call for Action, statements of 19 June 2026, fatf-gafi.org, accessed .
- Government of the Republic of Kazakhstan, Resolution No. 638 of 18 July 2026 approving the Rules for conducting strategic digital mining, adilet.zan.kz, accessed .
- OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, Global Forum supports Kazakhstan’s implementation of the Crypto-Asset Reporting Framework ahead of its first exchanges in 2027, oecd.org, accessed .
- Astana Financial Services Authority, AIFC Fees Rules (FR0007 of 2017), with amendments in force from 1 December 2025: Schedule 1 table 1.1 and 1.1-1, FEES 3.1.2-3.1.6, 5.1.3, Schedule 5-2, Schedule 6 table 6.1 and 6.1-1, orderly.myafsa.com, accessed .
- Astana Financial Services Authority, AIFC Companies Regulations, sections 26 (annual returns) and 26-1 (annual confirmation of accuracy of information in the register), orderly.myafsa.com, accessed .
- The Astana Times, report of December 2025 quoting the AFSA chief executive (“29 licensed Digital Asset Service Providers operate in the AIFC, including 12 digital asset exchanges”), astanatimes.com, accessed .
- President of the Republic of Uzbekistan, Decree UP-140 of 18 September 2024, Annex 1, item 3 (0% on crypto-asset operations under PP-3832, paragraph 2, until 1 January 2029), lex.uz; PP-3832 consolidated text, edition of , lex.uz, accessed .
- National Bank of the Republic of Kazakhstan, Kazakhstan introduces regulation of digital asset turnover (30 April 2026) and Regulation of the digital assets market, nationalbank.kz, accessed .
- Astana Financial Services Authority, AFSA Warning on Unlicensed Digital Asset Platforms (Article 11(5) of the Law “On Digital Assets in the Republic of Kazakhstan”), 28 April 2026, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, AFSA and Dubai Virtual Asset Regulatory Authority sign MoU to enhance cooperation in digital asset regulation, 9 April 2026, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, AFSA received first-ever regulatory fee payment in stablecoins, 6 October 2025, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, AFSA Grants First Stablecoin Issuer License, 17 June 2025, afsa.aifc.kz, accessed .
- Astana Financial Services Authority Online Rulebook, Rules and Mechanisms of Cooperation of Unbacked Digital Asset Exchanges and/or Centre Participants Authorised to Carry Out Digital Assets-Related Activities with Second-Tier Banks of the Republic of Kazakhstan, rules 3.1.1 and 3.1.6, orderly.myafsa.com, accessed .
- Astana Financial Services Authority Online Rulebook, AIFC Rules on Digital Asset Activities, consolidated text with the amendments in force from 1 January 2026: rule 2.2 table 1, rule 3.2 table 2, rules 2.11.3 and 3.11.2, orderly.myafsa.com, accessed .
- PwC Worldwide Tax Summaries, Kazakhstan: Individual – Taxes on personal income and Corporate – Other taxes (last reviewed 23 July 2026), taxsummaries.pwc.com, accessed .
- OECD Global Forum, Peer Review of the Automatic Exchange of Financial Account Information 2025 Update, Kazakhstan chapter (exchanges since 2021; legal framework “Not In Place”, effectiveness “Non-Compliant”), December 2025, oecd.org, accessed .
- Astana Financial Services Authority, AFSA launches consultation on proposed amendments to the AIFC Fees Rules, 16 July 2026, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, AFSA Introduces Fast-Track Authorisation for Firms Licensed in Acceptable Regulatory Regimes, 24 August 2026, afsa.aifc.kz, accessed .
- Astana Financial Services Authority, AIFC Prudential Rules for Investment Firms (PRU(INV)), Chapter 4, rules 4.1–4.2 (Expenditure-Based Capital Minimum: liquid assets of at least 25% of annual operating expenditure, within the Chapter’s scope), orderly.myafsa.com, accessed .
- Republic of Kazakhstan, Code on Taxes and Other Obligatory Payments to the Budget (Tax Code), No. 214-VIII of , in force : Article 357(2) (corporate income tax 20%; 25% for banks and gambling), Article 363 (personal income tax 10%, 15% above 8,500 MCI), Article 503(1) (VAT 16%) and Article 557(1) (social tax 6%), adilet.zan.kz, accessed .
- European Securities and Markets Authority, Guidelines on reverse solicitation under MiCA (ESMA35-1872330276-2030), paragraphs 14, 23 and 25 and Annex, published , applicable from , esma.europa.eu, accessed .