Overview
Kazakhstan operates two parallel crypto regimes. Inside the Astana International Financial Centre (AIFC), an English-style common-law free zone, the Astana Financial Services Authority (AFSA) licenses Digital Asset Trading Facilities (DATF), Custody, broker-dealers and a residual Digital Asset Service Provider (DASP) category under the AIFC Rules on Digital Asset Activities (No. FR00062 of 2023, as amended; consolidated DAA v2 effective 1 January 2025). Outside the AIFC, the national Law No. 193-VII On Digital Assets in the Republic of Kazakhstan (signed 6 February 2023, in force 1 April 2023) governs cryptomining and secured-token issuance through the Ministry of Digital Development.
The economically attractive route for an exchange or custodian is AIFC: 0% corporate tax on eligible financial-services income through 2065, English common law, AFSA-supervised. Cryptomining and secured-token circulation outside the AIFC sit under MDDIAI RK with the standard Kazakhstani tax base.
Official sources: AIFC, AFSA, AIFC Court, National Bank of Kazakhstan, State Revenue Committee, Astana Hub, eGov Kazakhstan corporate registry.
Track A. AIFC AFSA digital-asset regime
Licence categories
| Category | Scope |
|---|---|
| Operating a Digital Asset Trading Facility (DATF) | Multilateral trading venue for digital assets |
| Providing Custody | Holding client digital assets |
| Dealing in Investments as Principal / Agent (DA-extended) | Broker-dealer for digital assets |
| Digital Asset Service Provider (DASP), residual | Non-trading services, advisory, arrangement, etc. |
Capital (post-1 Jan 2026 amendments)
| Activity | Base capital |
|---|---|
| DATF Operator | Higher of USD 200,000 or 12 months of forecast working capital |
| Providing Custody (digital assets) | USD 500,000 (prudential Category 3 equivalent) |
| DASP without holding/controlling client assets | Reduced regime, proportional working capital only |
Track B. National regime under Law 193-VII (outside AIFC)
Law No. 193-VII divides digital assets into secured (tokenised rights to assets/services) and unsecured (mining-reward coins). Unsecured digital assets may only be circulated inside the AIFC, exchange-type activity for them outside AIFC is prohibited. MDDIAI RK licenses cryptomining, maintains pool accreditation and the hardware register. A November 2025 amendment package broadened definitions and supervisory scope under the wider digitalisation and AI legislative update.
Second-tier commercial banks may open accounts for AIFC-licensed digital-asset exchanges and AIFC digital-asset participants, expressly permitted under Law 193-VII and subsequent 2023 banking amendments. This is the bridge between AIFC operations and the wider Kazakhstani banking system, and it materially shortens onboarding for AFSA-licensed firms.
High-level checklist (AIFC)
- AIFC-registered Private Company (Ltd) or Recognised branch; physical office in Astana Hub.
- Senior Executive Officer (SEO), Compliance Officer and MLRO resident in Kazakhstan.
- Capital satisfied per category (USD 200k DATF, USD 500k Custody, proportional DASP-light).
- Governance under AIFC General Rules (GEN), Market Rules (MAR) and AML Rules (AML).
- Continuous capital maintenance with monthly reporting.
- Client-asset segregation and proof-of-reserves under the 1 January 2026 consolidated Business Rules.
- AML/CFT programme aligned with AIFC AML Rules and AFSA expectations.
- Regulatory business plan, three-year financial projections, technology and cybersecurity framework.
- AFSA application; Q&A rounds with the regulator; respond to fit-and-proper queries.
- Post-licensing: ongoing AFSA reporting, periodic supervisory checks, annual external audit.
Process and timeline
| Stage | Duration |
|---|---|
| AIFC entity incorporation and office | 1–2 months |
| Application pack, regulatory business plan, AML, tech, capital | 3–5 months |
| AFSA review and Q&A rounds | 6–9 months |
| Total. DATF / Custody | 10–16 months |
| DASP-light (post-2026 amendments) | 6–9 months |
Fees, licence validity and the FinTech Lab sandbox
The AFSA application route has three moving parts international founders frequently miss. First, the state application fee for Operating a Digital Asset Trading Facility is USD 70,000, payable on submission. Second, applicants routed through the AIFC FinTech Lab regulatory sandbox pay a reduced fee of USD 7,000, 10% of the headline figure, in exchange for restricted perimeter, limited client numbers and time-boxed piloting before a full licence. Third, AFSA licences are issued for a two-year validity period and renewed on evidence of continuing compliance and capital maintenance; an annual supervision fee applies over the life of the permission.
Before the full licence is granted, AFSA issues In-Principle Approval (IPA), a conditional green light that fixes the regulatory perimeter and lists the remaining steps the applicant must close (capital injection, policy finalisation, key-person hires, technology onboarding). Only after the IPA conditions are satisfied does AFSA confirm the licence and add the firm to the public register. Binance KZ, Bybit KZ, ATAIX Eurasia and other current licensees all went through the IPA route.
Live AFSA licensees, what the ecosystem looks like
As of April 2026 the AFSA public DASP register lists 26 active licences across DATF, Custody, Dealing and Money-Services permissions. Notable holders include ATAIX Eurasia, Bybit Limited, BN KZ Technologies (Binance KZ), Intebix, Cronex, Neyco, Top Line, Bigone Investment, Swiftex.io, MAQO, Neomarkets, SkyBridge, Verum Payments, AnchorX.KZ and Collect & Exchange. The depth of the register matters for three reasons, banking counterparties have priors on AIFC DASPs, listing venues have clearing corridors, and AFSA itself has benchmarks for application quality against firms already through the gate.
Taxation
- AIFC residents: 0% CIT on eligible financial-services income through 2065 (AIFC Constitutional Law); 0% IIT on qualifying employee income; VAT exemption on AIFC-internal financial services.
- Outside AIFC: CIT 20%, VAT 12%, PIT 10%. Cryptomining is subject to a digital-mining surcharge based on electricity consumption under the Tax Code (since 2022).
FAQ
AIFC or national track for an exchange?
AIFC. Exchange-type activity for unsecured digital assets outside the AIFC is prohibited. AIFC DATF is the route, common-law regime, English-language documents, 0% CIT.
What is the actual capital floor?
Higher of USD 200,000 or 12 months of forecast working capital for DATF; USD 500,000 for Custody under the 1 January 2026 amendments.
Do I need Kazakh-resident officers?
Yes. SEO, Compliance Officer and MLRO must be resident in Kazakhstan. The licensee operates from the Astana Hub physical office.
How does Kazakhstan compare with Uzbekistan?
Uzbekistan licenses through NAPP under a domestic regime with a crypto-tax holiday until 1 January 2028. Kazakhstan AIFC is a free-zone common-law route with permanent 0% AIFC tax through 2065, the right pick depends on whether you want common-law contracts.
How much is the AFSA application fee?
The state fee for Operating a Digital Asset Trading Facility is USD 70,000, paid on submission. Applicants routed through the AIFC FinTech Lab regulatory sandbox pay USD 7,000–10% of the headline figure, in exchange for a restricted perimeter and time-boxed piloting. An annual AFSA supervision fee applies on top, and licences renew every two years.
How long is an AFSA licence valid?
Two years from issuance, renewed on evidence of continuing compliance and capital maintenance. Licensees file annual audited financials, quarterly regulatory returns and maintain capital continuously with monthly prudential reporting across the life of the permission.
What is In-Principle Approval?
IPA is AFSA's conditional green light before the full licence, it fixes the regulatory perimeter and lists the remaining conditions (capital injection, policy finalisation, key-person hires, technology onboarding). Only after IPA conditions are closed does AFSA confirm the licence and add the firm to the public register. Binance KZ, Bybit KZ and ATAIX Eurasia all ran through IPA first.
What is the AIFC FinTech Lab sandbox?
A time-boxed regulatory sandbox operated by the AIFC where firms can pilot digital-asset business models with a restricted client perimeter before committing to a full DATF or Custody licence. The licensing fee is USD 7,000 (10% of the full USD 70,000), and the route is popular with novel models, stablecoin issuance, tokenisation of real-world assets, non-custodial intermediation, where AFSA and the applicant jointly refine the regulatory treatment.
Is crypto legal in Kazakhstan?
Yes, on two defined tracks. Exchange-type activity for unsecured digital assets is legal inside the AIFC under AFSA DATF / Custody / Dealing / DASP permissions. Cryptomining and secured-token issuance are legal nationally under Law 193-VII (2023) and licensed by MDDIAI RK. Unlicensed exchange of unsecured digital assets outside the AIFC is prohibited.
Which exchanges are licensed by AFSA today?
The AFSA DASP register lists 26 active licences as of April 2026, including ATAIX Eurasia, Bybit Limited, BN KZ Technologies (Binance KZ), Intebix, Cronex, Neyco, Top Line, Bigone Investment, Swiftex.io, MAQO, Neomarkets, SkyBridge, Verum Payments, AnchorX.KZ and Collect & Exchange. The live register is published on the AFSA website and is the authoritative source.
What about cryptomining?
Cryptomining sits under MDDIAI RK on the national side, separate from AFSA. The mining electricity surcharge applies. Most exchanges and custodians operate inside AIFC; mining operators sit on the national track.
What is the scope of an AFSA DATF licence?
Operating a Digital Asset Trading Facility is the multilateral trading-venue permission under the AIFC DAA Rules (FR00062/2023, v2 in force 1 January 2025). Base capital is the higher of USD 200,000 or 12 months of forecast working capital under the 1 January 2026 amendments, with market-surveillance, listing-rules and clearing obligations under AIFC Market Rules (MAR).
Can Custody and Issuer activities sit in the same entity?
They are separate regulated activities. Custody (holding client digital assets) carries USD 500,000 base capital at prudential Category 3 equivalent. Issuer/Dealing-in-Investments permissions can be bundled in one AIFC Private Company if the application pack covers each, but capital stacks to the highest applicable threshold and governance must ring-fence client assets from principal books.
What is the benefit of AIFC English-law jurisdiction?
The AIFC operates under an English common-law framework separate from Kazakhstani civil law. Contracts, shareholder agreements and custodial terms are drafted and enforced in English on common-law principles, readable to international investors, counterparties and auditors without translation or civil-code adaptation.
How are disputes resolved in the AIFC?
The AIFC Court and the International Arbitration Centre (IAC) handle civil and commercial disputes from AIFC entities. Both operate in English on common-law procedure, with judgments enforceable inside Kazakhstan and across New York Convention states. Licensees typically elect AIFC Court jurisdiction in customer and counterparty agreements.
What does the AFSA application pack require?
A full Regulatory Business Plan covering prudential, conduct and technology risk; AML/CFT programme aligned to AIFC AML Rules and the FATF Travel Rule; market-rules compliance for DATFs; client-asset segregation and proof-of-reserves; technology and information-security risk assessment; and fit-and-proper files for controllers, SEO, Compliance Officer and MLRO.
How does AML/CFT work under the AFSA AML Rulebook?
AIFC firms run risk-based CDD, sanctions screening, transaction monitoring, the FATF Travel Rule for digital-asset transfers, and MLRO reporting to AFSA. The MLRO must be resident in Kazakhstan. Annual independent AML audit and suspicious-transaction reporting into the Kazakhstan FIU apply.
What AIFC tax holidays apply?
0% CIT on eligible financial-services income through 2065 under the AIFC Constitutional Law, 0% IIT on qualifying employee income, and VAT exemption on AIFC-internal financial services. Activity outside the AIFC perimeter falls back to standard rates (CIT 20%, PIT 10%, VAT 12%).
Is a mining licence the same as a trading licence?
No, separate tracks. Cryptomining is licensed by MDDIAI RK under Law 193-VII (in force 1 April 2023) with an electricity-consumption surcharge under the Tax Code (since 2022). AFSA DATF, Custody and Dealing sit inside the AIFC. A miner that wants to trade unsecured tokens must still route that activity through an AIFC DATF.
What banking access is available onshore?
Second-tier banks are expressly authorised under Law 193-VII and the 2023 banking amendments to open accounts for AIFC-licensed digital-asset exchanges and participants. Several Kazakhstani banks run live corridors with AIFC DATFs, bridging crypto-on-ramp flows into tenge and USD accounts onshore.
What substance and staffing does AFSA require?
Physical office in the Astana Hub is mandatory. SEO, Compliance Officer and MLRO must be resident in Kazakhstan. AFSA expects real decision-making, books and records, and technology operations on the ground, not a letterbox. Capital is maintained continuously with monthly prudential reporting.
Can directors and shareholders be foreign?
Yes, the AIFC is an international financial centre and foreign shareholders and directors are the norm. Residency attaches only to the SEO, Compliance Officer and MLRO. All controllers and senior managers must pass AFSA fit-and-proper review regardless of nationality.
What annual reporting and supervision apply?
Annual audited financial statements, quarterly regulatory returns, continuous capital maintenance with monthly prudential reporting, and annual AML audit. AFSA conducts ongoing supervision, thematic reviews, onsite inspections and ad-hoc information requests under AIFC General Rules (GEN) and the DAA Rules.