Mandatory audit and financial reporting in Kazakhstan in 2026: who, what and by when

The duty to keep accounts and the duty to be audited come from different Kazakh statutes and turn on different tests. Accounting and reporting sit in Law № 234-III of 28 February 2007 “On accounting and financial reporting”; audit sits in Law № 304-I of 20 November 1998 “On auditing activity”. A company can be obliged to file with the depository and still not be subject to mandatory audit — and the reverse is equally possible.

The key risk. The most expensive mistake is to assume that mandatory audit follows the size of the business. It does not. The list in article 5 of Law № 304-I is a closed enumeration of twenty positions, and a size test appears in it only for limited liability partnerships — and even there only in combination with a second condition: the presence of a participant holding less than ten per cent. A large LLP without such a participant is not subject to mandatory audit, while a small joint-stock company always is.

Item	Value	Basis
Accounting law	№ 234-III of 28.02.2007	as amended to 12.07.2026
Audit law	№ 304-I of 20.11.1998	as amended to 12.07.2026
Reporting period	the calendar year, 1 January to 31 December	art. 18, Law № 234-III
Deadline for presenting annual accounts	no later than 30 April of the following year	art. 19(3), Law № 234-III
Depository deadline for public interest entities	no later than 31 August of the following year	para 3 of the Rules, MoF order № 94
Standard for small business	the national financial reporting standard	art. 2(3), Law № 234-III
Standard for medium business	IFRS for SMEs	art. 2(3-1), Law № 234-III
Standard for large business and public interest entities	full IFRS	art. 2(4), Law № 234-III
Size threshold for LLP audit	a participant holding less than 10 %, plus more than 250 employees and/or income above 3,000,000 MRP — the monthly calculation index, месячный расчётный показатель	art. 5, Law № 304-I
That threshold in tenge for 2026	KZT 12,975,000,000	MRP KZT 4,325
Fine for evading a mandatory audit	15 / 20 / 200 MRP by business category	art. 250, Code of Admi­nistra­tive Offences
Fine for failing to file with the depository	100 / 200 / 500 MRP by business category	art. 239, Code of Admi­nistra­tive Offences
Auditor rotation	insurance sector only: 7 years for the firm, 5 for the auditor	art. 20(2), Law № 126-II
Electronic audit report	generated in the depository, no registration required	from 12 July 2026

Two duties that are constantly conflated

Financial reporting and audit are two independent obligations in Kazakh law, with different recipients, different deadlines and different penalties. They overlap, but only partly, and it is at the overlap that most mistakes are made.

The first duty: keep accounts and prepare statements

Keeping accounting records and preparing financial statements is compulsory for every legal entity, branch, representative office and permanent establishment of a foreign legal entity registered in Kazakhstan, and for individual entrepreneurs. That is article 2(1) of Law № 234-III. An exemption exists, but it is narrow and available only to individual entrepreneurs.

The duty arises for every legal entity without exception, regardless of size, turnover, whether it trades at all, or its corporate form. What differs is not the duty but the standard under which the statements are prepared.

The second duty: be audited

A mandatory audit arises only for those expressly named in article 5(2) of Law № 304-I. The list is closed: an entity that is not named there and does not meet the size test for limited liability partnerships has no mandatory audit.

Voluntary audit is a third category. It is carried out at the initiative of the audited entity or of one of its participants, with scope, timing and objectives fixed by the engagement contract.

Where the two meet

The overlap runs through the Depository of Financial Reporting: public interest entities file their annual statements there, and those of them that are subject to mandatory audit file the audit report alongside. The mechanism is paragraph 6 of the Rules approved by order of the Minister of Finance № 94 of 28 January 2022.

The set of public interest entities under Law № 234-III and the set of entities subject to mandatory audit under Law № 304-I coincide only in part. State enterprises holding assets on the right of economic management, for instance, are public interest entities, but only those with a supervisory board operating in education or healthcare are subject to mandatory audit.

The practical consequence

Three questions have to be answered separately: which standard applies, whether the statements go to the depository, and whether an audit is required. An answer to one of them does not determine the answers to the other two.

Unlike tax filing, there is no single date and no single recipient here. The annual statements go to the founders and to the statistics authority by 30 April, to the depository by 31 August, and the audit report is registered in the depository within three working days of the date on which it is drawn up.

The legal base: what is in force in September 2026

The regime rests on two principal statutes, one subordinate instrument on the depository, and three orders of the Minister of Finance that fix the standards and the mechanics of bookkeeping. Sectoral audit duties are additionally scattered across roughly ten separate laws.

The statutes

Act	Subject matter
Law № 234-III of 28.02.2007 “On accounting and financial reporting”	Records, statements, standards, the depository
Law № 304-I of 20.11.1998 “On auditing activity”	Types of audit, mandatory audit, auditors and audit organisations
Entre­preneu­rial Code № 375-V of 29.10.2015, art. 24	Cla­ssifi­cation as small, medium or large business
Code of Admi­nistra­tive Offences № 235-V of 05.07.2014	Penalties: arts. 238, 239, 245–250
Law № 239-VIII of 08.12.2025 on the republican budget for 2026–2028	MRP for 2026 — KZT 4,325

Both principal statutes were read as amended to 12 July 2026.

The subordinate instruments

Act	What it establishes
MoF order № 94 of 28.01.2022 (MoJ № 26686 of 31.01.2022)	Rules on filing financial statements of public interest entities with the depository; the 31 August deadline
MoF order № 404 of 28.06.2017 (MoJ № 15384)	The list and forms of annual financial statements for publication
MoF order № 50 of 31.01.2013 (MoJ № 8328 of 08.02.2013)	The national financial reporting standard
MoF order № 185 of 23.05.2007 (MoJ № 4771 of 29.06.2007)	The model chart of accounts
MoF order № 241 of 31.03.2015 (MoJ № 10954 of 06.05.2015)	The rules for keeping accounting records

Government Resolution № 1173 of 14.10.2011 “On approving the Rules for presenting financial statements to the depository” was repealed by Government Resolution № 65 of 16 February 2022 and cannot be cited as current. It still appears in published material about the depository — it is the most common citation of a repealed act in this area.

What changed in 2026

•          1 January 2026 — Law № 215-VIII of 18.07.2025 restated article 2(2) of Law № 234-III: an individual entrepreneur’s exemption from bookkeeping now requires three conditions to be met at once.

•          1 January 2026 — the MRP was set at KZT 4,325, so every threshold expressed in MRP rose by roughly ten per cent without a single amendment to the sectoral statutes.

•          28 March 2026 — Law № 270-VIII of 16.03.2026 added the single operator distributing extra-budgetary money for the development of physical culture and sport to the list in article 5(2) of Law № 304-I.

•          20 April 2026 — order of the acting Minister of Finance № 206 of 30.03.2026 amended the rules for keeping accounting records: the scope was clarified, the head of the accounting function need no longer be the chief accountant, and the rules on correcting primary documents were tightened.

•          12 July 2026 — Law № 256-VIII of 09.01.2026 digitalised the regime: an audit report may now be electronic and is generated directly in the depository with no separate registration, the depository was redefined as a digital database, and audit organisations must keep the details of their auditors up to date.

•          19 March 2026 — Law № 258-VIII of 16.01.2026 on banks and banking activity in the Republic of Kazakhstan came into force, wholly replacing the 1995 law; bank audit now sits in article 82 rather than article 57 of the former act. The date follows from article 135 — sixty calendar days after first official publication on 17 January 2026 — and the same date, 19 March 2026, is named expressly in article 2(2) of Law № 352-VIII of 23.07.2026.

•          5 September 2026 — order of the Minister of Finance № 547 of 14.08.2026 (MoJ № 39667 of 24.08.2026) comes into force, amending the Rules on filing financial statements with the depository: the preamble and paragraphs 1, 3, 4 and 6 are restated. The 31 August deadline survives unchanged; in paragraph 4 “information systems” becomes “digital systems”; and in paragraph 6 the duty to file the audit report is tied expressly to article 5(2) of Law № 304-I, with the format called digital while the requirement for a scanned copy of the signed paper original is retained.

What has been passed but is not yet in force

Law № 352-VIII of 23 July 2026, on amendments to certain legislative acts concerning the improvement and digitalisation of the financial market, bankruptcy and the assessment of state bodies, comes into force on 21 October 2026 — sixty calendar days after first official publication on 21 August 2026.

For the subject of this article it does three things. First and most important: every microfinance organisation, without exception, leaves the category of public interest entities — the narrow carve-out for microfinance organisations formed as business partnerships that do not grant unsecured microcredits is deleted, and the words “microfinance organisations” are added to the general list of exclusions. Second, it amends article 20(6)(3) and article 20(7) of Law № 234-III on state regulation and control. Third, it amends article 82(9) of Law № 258-VIII, article 55-1(8) of Law № 461-II and article 20(12) of Law № 126-II.

The practical consequence is that from 21 October 2026 microfinance organisations cease to report under full IFRS by reason of public interest status and cease to file with the depository on that ground. At the date of writing the amendment is not in force, and everything set out below is given in the version effective as at 12 July 2026.

Who must keep accounts, and who is exempt

Every legal entity registered in Kazakhstan, including branches, representative offices and permanent establishments of foreign companies, and every individual entrepreneur, must keep accounting records and prepare financial statements. The perimeter is drawn by article 2(1) of Law № 234-III and contains no exception for legal entities.

The only exemption, and its three conditions

An individual entrepreneur may decline to keep accounting records and prepare financial statements only where three conditions are met simultaneously. Since 1 January 2026 article 2(2) of Law № 234-III reads as follows.

First condition: the entrepreneur applies the special tax regime based on a simplified declaration, and income for the calendar year does not exceed 135,000 MRP. In 2026 tenge that is KZT 583,875,000.

Second condition: the entrepreneur is not registered for value added tax.

Third condition: the entrepreneur is not a natural monopoly entity.

Primary documents must be drawn up and retained in every case — the exemption expressly carves them out.

What happens when the exemption is lost

If any one of the three conditions ceases to be met, the duty to keep records and prepare statements arises from the month following the month in which the failure occurred. The rule is tied to a month rather than to a tax period or a year, and that is its principal practical feature: crossing the threshold in March means bookkeeping from April, not from 1 January of the following year.

An individual entrepreneur who decides voluntarily to keep records begins from the month following the month of that decision.

What changed on 1 January 2026

Before 2026 the exemption simply tracked the special tax regime for small business, with no separate income threshold and no VAT-registration condition. The new wording introduced both, and a number of individual entrepreneurs who had kept no records lost the exemption automatically, without doing anything at all.

The rule was restated by Law № 215-VIII of 18 July 2025 — the same statute that accompanied the introduction of Tax Code № 214-VIII. That is a useful marker: the change came out of the tax reform package rather than an accounting one, which is precisely why it is so easily missed. Registration for VAT and the current threshold are covered in our piece on VAT in Kazakhstan in 2026.

Branches and representative offices of foreign companies

Branches, representative offices and permanent establishments of foreign legal entities keep records and report on the ordinary basis — there is no exemption by reason of belonging to a foreign structure. A separate regime exists only for branches of non-resident banks, insurance (reinsurance) organisations and insurance brokers: under article 19-1 of Law № 234-III they report on the timetable set by the National Bank in agreement with the financial supervisory authority.

Business classification: why it decides almost everything

The category of a business under article 24 of the Entrepreneurial Code determines the financial reporting standard and the size of an administrative fine, but does not by itself determine whether an audit is mandatory.That distinction is the key to the whole subject.

Three categories — with micro business inside small business

Category	Average annual headcount	Average annual income
Micro business (inside small business)	not more than 15 people or	not more than 30,000 MRP
Small business	not more than 100 people and	not more than 300,000 MRP
Medium business	a residual category: whatever is neither small nor large	—
Large business	more than 250 people and/or	more than 3,000,000 MRP

There are three categories, not four: micro business is not a free-standing category but a subset of small business.Article 24 speaks of small businesses, “including micro businesses”, and defines a micro business as a small business with not more than fifteen employees or income of not more than 30,000 MRP. The consequence is that a company with fifteen employees and income of 500,000 MRP is not a micro business — it is not a small business at all, because it fails the income test.

Note the conjunctions: micro business joins its tests with “or”, small business with “and”, and large business with “and/or”. That is not sloppy drafting but three different logics, and one cannot be substituted for another.

The thresholds in tenge for 2026

The MRP for 2026 is set at KZT 4,325 by article 7 of Law № 239-VIII of 8 December 2025 on the republican budget for 2026–2028.

Threshold	In MRP	In tenge for 2026
Micro business, by income	30,000	129,750,000
Small business, by income	300,000	1,297,500,000
Large business, by income	3,000,000	12,975,000,000
Individual entre­pre­neur’s bookkeeping exemption	135,000	583,875,000

There is no lag in the MRP here: article 24 ties the calculation expressly to the MRP set by the budget law and in force on 1 January of the relevant financial year. That distinguishes this threshold from a number of tax thresholds computed on the previous year’s MRP.

Fourteen activities that bar small-business status

Regardless of headcount or income, a person carrying on any of fourteen listed activities is not a small business.The list in article 24(4) includes: dealing in narcotic drugs, psychotropic substances and precursors; production and wholesale of excisable goods; storing grain at grain-receiving points; lotteries; gambling; dealing in radioactive materials; banking or particular banking operations, and activity on the insurance market other than that of an insurance agent; auditing; professional activity on the securities market; credit bureaux; security services; dealing in civilian and service weapons; digital mining of the first sub-type; and commodity exchanges.

A practical consequence for readers of this article: an audit organisation itself is never a small business, however small its headcount — and therefore never reports under the national standard.

What this classification does not decide

The business category does not determine whether a mandatory audit is required. Large business and mandatory audit are overlapping but distinct sets. The size test operates inside a single position in the article 5 list of Law № 304-I — limited liability partnerships — and only in combination with a second condition.

Which standard applies: the national standard, IFRS for SMEs or full IFRS

The reporting standard follows from the business category and from public interest status, not from the company’s own choice. The rules sit in article 2, paragraphs 3, 3-1, 3-2 and 4, of Law № 234-III.

The allocation by category

Who	Standard	Basis
Small business, and entities operating exclusively through currency exchange points	The national financial reporting standard	art. 2(3)
Medium business and state enterprises on the right of operational management	The international standard for small and medium-sized entities	art. 2(3-1)
Small and medium businesses carrying on microfinance activity that are not public interest entities	IFRS for SMEs plus National Bank regulations	art. 2(3-2)
Large business and public interest entities	Full IFRS	art. 2(4)
Financial organisations	Full IFRS plus National Bank regulations	art. 2(4)
Special financial companies and Islamic special financial companies	Full IFRS	art. 2(4)
Branches of non-resident banks, insurers and insurance brokers	Full IFRS plus National Bank regulations	art. 2(4)

The right to move up voluntarily

Article 2(5) permits movement in one direction only: a small business may apply IFRS for SMEs or full IFRS, and a medium business may apply full IFRS. There is no route back: a large entity applying full IFRS cannot move to a simplified standard.

The decision is taken by the body that approved the accounting policy and must be recorded in that policy.

Where the national standard lives

The national financial reporting standard was approved by order of the Minister of Finance № 50 of 31 January 2013, registered with the Ministry of Justice on 8 February 2013 under № 8328. The same order repealed two predecessors — NSFO № 1 and NSFO № 2, approved by orders № 218 and № 217 of 21 June 2007.

Order of the Minister of Finance № 377 of 18 July 2025 (MoJ № 36489 of 22 July 2025) amended the standard: it was extended to entities operating exclusively through currency exchange points, and four annexes were replaced.

Where the international standards live

Full IFRS and IFRS for SMEs apply as issued by the IFRS Foundation. Article 16(2) of Law № 234-III adds a restriction that matters in practice: only an organisation holding the Foundation’s written permission for official translation and publication in Kazakhstan may publish the standards in Kazakh and Russian. The same rule applies to the Code of Ethics, where the permission comes from the International Federation of Accountants.

The practical consequence is that a Russian text of IFRS taken from an arbitrary source is not the official text, and relying on it in a dispute with an inspector is a weak position.

The mechanics of bookkeeping

The model chart of accounts was approved by order of the Minister of Finance № 185 of 23 May 2007 (MoJ № 4771), and the rules for keeping accounting records by order № 241 of 31 March 2015 (MoJ № 10954). Both are in force; no 2025 or 2026 order replaced either.

From 20 April 2026 the rules for keeping accounting records apply as amended by order of the acting Minister of Finance № 206 of 30 March 2026. The amendments concern the scope of the rules, the status of the head of the accounting function, and the procedure for correcting primary documents, including electronic ones.

The composition of the statements, the reporting period and consolidation

Financial statements in Kazakhstan comprise five elements, and the list is fixed by statute rather than by the standard. Article 15(2) of Law № 234-III names: the balance sheet; the profit and loss statement; the statement of cash flows; the statement of changes in equity; and the explanatory note.

The manner of preparation and any additional requirements are set by the international standards, by IFRS for SMEs and by the accounting legislation — so the list of elements comes from the statute while the content of each element comes from the standard.

The reporting period

The reporting period for annual financial statements is the calendar year from 1 January to 31 December. Article 18 of Law № 234-III admits no alternative financial year: choosing an arbitrary year-end, routine in many jurisdictions, is simply not available under Kazakh law.

The first reporting year of a newly created entity runs from its state registration to 31 December of the same year.There is no “long first year” rule allowing a first period of more than twelve months — one of the material differences from the regime of the Astana International Financial Centre.

Interim reporting

Founders and participants may set the timing of interim financial statements and adopt a different frequency, provided it is no less than once a year. Article 19(4) operates within the reporting period fixed by article 18.

Consolidation

An entity with subsidiaries must prepare and present consolidated financial statements in addition to the statements of the parent’s own activity. Article 17 of Law № 234-III consists of a single sentence and contains no exemption whatever.

This point is frequently stated incorrectly. There is no consolidation exemption in the Kazakh statute; exemptions exist only inside IFRS itself, principally IFRS 10, and apply by virtue of the statute’s reference to the standards rather than by any free-standing rule of Law № 234-III.

Subsidiary and parent are defined by reference to recognition under the international standards — sub-paragraphs 6-1) and 13-1) of article 1 define them as the controlled and the controlling entity respectively.

Who may set the rules for subsidiaries

A parent may determine how its subsidiaries apply a single accounting policy and how they take inventory of their assets, as well as the list, forms and timing of the reporting they submit to it. That is article 19(4-1) and article 19(1)(4).

The practical consequence for holding structures is that a group-wide accounting policy has a direct statutory basis, and its adoption does not require the consent of each subsidiary.

The currency of the statements

Financial statements are presented in the national currency of the Republic of Kazakhstan. Article 19(2) allows no other presentation currency, whatever the functional currency under IFRS.

To whom, and by when, the annual statements go

Annual financial statements are presented no later than 30 April of the year following the reporting year. Article 19(3) of Law № 234-III is the only provision that fixes that date, and it coincides with no tax deadline.

Four recipients

Article 19(1) names four recipients, and the duty owed to each is independent:

1.        The founders or participants — in accordance with the constitutive documents.

2.        The state statistics authority — at the place of state registration.

3.        State control and supervisory bodies — within their respective competence.

4.        The parent entity of which the reporting entity is a subsidiary — in the manner the parent determines, including the list, forms and timing.

The Depository of Financial Reporting does not appear in that list: it is introduced by a separate paragraph 7 of the same article and runs on its own deadline.

The exception for financial organisations

Financial organisations present their annual statements on the timetable set by the National Bank in agreement with the authority regulating and supervising the financial market. Article 19(3-1) removes them from the general 30 April deadline entirely.

Two categories are excluded from that exception in turn: entities operating exclusively through currency exchange points under a National Bank licence for cash foreign currency exchange operations, and entities whose exclusive activity is the collection of banknotes, coins and valuables. Both return to the general regime and present their annual statements by 30 April.

Consolidated statements

Consolidated statements are presented under the same rules as individual ones: article 19(5) expressly applies paragraphs 1, 2, 3, 3-1 and 4-1 of the same article to them. The statute sets no separate deadline for consolidated reporting.

Deadlines that must not be conflated

What	To whom	When	Basis
Annual financial statements	Founders, statistics, supervisory bodies, the parent	no later than 30 April	art. 19(3), Law № 234-III
Annual financial statements and the audit report	The Depository of Financial Reporting	no later than 31 August	para 3 of the Rules, MoF order № 94
A paper audit report	Registration in the depository	within 3 working days of the date on which it is drawn up	art. 18(2), Law № 304-I
A copy of an insurer’s audit report	The financial supervisory authority	within 30 calendar days of receipt	art. 20(8), Law № 126-II
A copy of a securities market participant’s audit report	The financial supervisory authority	within 30 calendar days of receipt	art. 55-1(1), Law № 461-II

None of these deadlines absorbs another. Filing with the depository on 31 August does not replace presenting the statements to the founders and to statistics by 30 April, and registering the audit report in the depository does not replace sending a copy to the financial regulator where a sectoral statute requires it.

Public interest entities: a definition wider than it looks

A public interest entity is a statutory category rather than a description of a business: membership turns on corporate form, activity or the presence of a state shareholding, and not on size. The definition sits in article 1(7) of Law № 234-III.

Who is inside the category

The list of public interest entities comprises:

•          financial organisations — other than entities operating exclusively through currency exchange points under a National Bank licence, credit partnerships and pawnshops formed as business partnerships, and microfinance organisations formed as business partnerships that do not grant unsecured microcredits;

•          endowment funds;

•          joint-stock companies — other than non-commercial ones;

•          subsoil user organisations — other than those extracting commonly occurring minerals;

•          grain-receiving enterprises;

•          developers in shared-participation housing construction and authorised companies;

•          state enterprises holding assets on the right of economic management;

•          state monopoly entities and holders of a special right;

•          entities with a state shareholding in their charter capital, together with their subsidiary, dependent and otherwise affiliated legal entities.

The limb that is most often underestimated

The last position catches any entity with a state share in its charter capital — with no minimum stated — and every person affiliated with it. The phrase “a share of state participation” carries no threshold: even a token holding moves the entity into the public interest category, together with its subsidiaries, dependent entities and other affiliates.

The practical consequence is that a limited liability partnership in which the state holds a small stake must report under full IFRS and file with the depository — while quite possibly not being subject to mandatory audit at all.

Three consequences of the status

First, full IFRS. Article 2(4) leaves no choice: public interest entities report under the international standards regardless of their business category.

Second, filing with the depository. Article 19(7) addresses the depository duty precisely to public interest entities.

Third, a requirement as to the chief accountant. Signature of a public interest entity’s financial statements by a chief accountant who is not a professional accountant is a free-standing administrative offence under article 239(1)(4) of the Code of Administrative Offences.

An amendment that is not yet in force

Law № 352-VIII of 23 July 2026 amends the definition of public interest entities with effect from 21 October 2026.

The amendment is wider than it first appears: it does not add a new exclusion but converts a narrow one into a blanket one. In the current version only microfinance organisations formed as business partnerships that do not grant unsecured microcredits are excluded from financial organisations. From 21 October 2026 that qualification is deleted and the words “microfinance organisations” are added to the general list of exclusions — so the entire microfinance sector leaves the category of public interest entities.

The practical consequence for a microfinance organisation is that from 21 October 2026 it stops reporting under full IFRS on the ground of public interest status and stops filing with the depository on that same ground. At the date of writing the amendment is not in force, and the definition is given here in the version in force from 12 July 2026.

The Depository of Financial Reporting: what, where and by 31 August

Public interest entities file their annual financial statements with the Depository of Financial Reporting through its website each year, no later than 31 August of the year following the reporting year. The deadline is set by paragraph 3 of the Rules approved by order of the Minister of Finance № 94 of 28 January 2022 (MoJ № 26686 of 31 January 2022).

What the depository is in law

The Depository of Financial Reporting is a digital database containing annual financial statements, valuation reports, audit reports, lists of affiliates of joint-stock companies and information about their corporate events, openly accessible to users. The definition is given by article 1(10) of Law № 234-III in the version in force from 12 July 2026.

It is that version which replaced “electronic database” with “digital database” and added valuation reports to the contents. The change was made by Law № 256-VIII of 9 January 2026.

Who is exempt from filing

Two categories are outside the duty: entities dormant throughout the reporting period, and entities declared bankrupt before 1 January of the reporting period. The Rules contain no other exemption.

What exactly is filed

Annual financial statements in the list and forms approved by order of the Minister of Finance № 404 of 28 June 2017 — that regime applies to every organisation other than financial organisations and the two exempt categories.

Annual consolidated financial statements in addition, where the entity has subsidiaries. Paragraph 5 of the Rules.

The audit report, by entities for which audit is mandatory under Law № 304-I. Paragraph 6 requires it to be filed together with the financial statements; where the entity has subsidiaries, the audit report is filed in respect of the consolidated statements.

A report on a voluntary audit is filed at the entity’s own initiative — there is no duty to file one.

Identification data go into the depository’s main sub-section, while the financial statements and the audit report go into the additional sub-section.

The composition of the filing

Paragraph 7 of the Rules lists five forms: the balance sheet; the profit and loss statement; the statement of cash flows on the direct or the indirect method; the statement of changes in equity; and the explanatory note with disclosures under the international standards.

How it works in practice

The filing is prepared in a personal account on the depository portal; the electronic report generated there comprises the financial statements, the decision approving them, the audit report and the entity’s identification data, and is signed with the electronic digital signatures of the head of the entity and the chief accountant.

The authorised organisation sends a notice of acceptance, or states the grounds for refusal, within three working days of receipt.

Financial statements and audit reports once filed with the depository are not subject to replacement or deletion.That rule, in paragraph 9, makes an error in a filed set irremediable in the way an error in a tax return is remediable: no amended form can be lodged, and the document filed stays in the database permanently.

Where an organisation fails to comply with paragraphs 5, 6, 7 and 8 of the Rules, the authorised organisation does not accept its electronic report — paragraph 11. Missing consolidated statements where there are subsidiaries, or a missing audit report where audit is mandatory, therefore produces not a comment but a refusal of the whole package.

The amendment taking effect on 5 September 2026

Order of the Minister of Finance № 547 of 14 August 2026, registered with the Ministry of Justice on 24 August 2026 under № 39667, restates the preamble and paragraphs 1, 3, 4 and 6 of the Rules and comes into force on 5 September 2026 — ten calendar days after first official publication on 25 August 2026.

The 31 August deadline survives unchanged. The restated paragraph 3 changes one formulation: “in the manner established by sectoral legislation” becomes “in the manner established by the sectoral legislation of the Republic of Kazakhstan”.

In paragraph 4 “information systems” becomes “digital systems”.

Paragraph 6 changes materially: the duty to file the audit report is now tied expressly to article 5(2) of Law № 304-I, and the format is called digital while the requirement for a scanned copy of the signed and sealed paper original is retained.

The practical consequence of that tie is that entities whose audit duty comes not from the article 5(2) list but from a sectoral statute — the single operator under Law № 486-V, say, or an Islamic special financial company under article 32-6 of Law № 461-II — fall outside the duty to file an audit report with the depository on the literal wording of paragraph 6. That is a consequence of the drafting rather than a stated regulator position, and it is worth confirming in writing.

Mandatory audit: the full list in article 5

Only the entities expressly named in article 5(2) of Law № 304-I are subject to mandatory audit. The list is closed, runs to twenty positions, and is drafted as a series of unnumbered paragraphs — the “1) … 2) …” numbering appears inside it only once, within the position on limited liability partnerships.

The list in full

№	Who is subject to mandatory audit
1	Joint-stock companies
2	State enterprises on the right of economic management with a supervisory board in education and healthcare
3	Insurance (reinsurance) orga­nisa­tions, insurance holdings and entities in which an insurer and/or an insurance holding is a major participant, and insurance brokers
4	Endowment funds
5	The unified accumulative pension fund and professional securities market participants incorporated as joint-stock companies
6	Major participants of an investment portfolio manager
7	Legal entities holding subsoil use rights for exploration and production of hydrocarbons or hard minerals — in the cases provided by the Subsoil Code
8	Banks, entities in which a bank is a major participant, and banking holdings
9	Civil aviation orga­nisa­tions, other than airlines carrying out aerial work on the list determined by the Government
10	Grai­n-recei­ving enterprises
11	The insurance payments guarantee fund
12	The social health insurance fund
13	Legal entities that have concluded an investment contract providing for investment preferences
14	Special financial companies under the Law on project financing and secu­riti­sation
15	Developers and authorised companies under the Law on shared participation in housing construction
16	The settlement and financial centre for the support of renewable energy sources
17	The single operator distributing extra­-budge­tary money for the development of physical culture and sport— added on 28 March 2026
18	Wholesale electricity consumers (industrial facilities) included in the list of those buying electricity at the investment tariff
19	Authorised economic operators under the Code on customs regulation
20	Limited liability partnerships where two conditions are met simu­lta­neously

Three carve-outs

Article 5(2) does not apply to joint-stock companies declared bankrupt by a court, or to banks and insurance (reinsurance) organisations whose licence has been withdrawn by the financial supervisory authority and/or that are in compulsory liquidation.

What was added in 2026

The only change to the list during 2026 was made by Law № 270-VIII of 16 March 2026, in force from 28 March 2026, which added the single operator distributing extra-budgetary money for the development of physical culture and sport. No other position was altered.

The two preceding changes were made by Law № 194-VIII of 12 June 2025 (in force 24 June 2025) and Law № 200-VIII of 30 June 2025 (in force 31 August 2025).

A drafting defect worth knowing about

Inside article 5 the numbering “1) … 2) …” is used twice in different senses: first in paragraph 1 for the types of audit, and then inside the LLP position for its two conditions. A citation to “sub-paragraph 2) of article 5” is therefore ambiguous, and in correspondence with a regulator or a counterparty it is safer to identify the position in words rather than by number.

Cross-references to paragraphs are a separate difficulty. Article 4(2) of Law № 304-I refers to “paragraphs four, five, six, eight and eleven of part one of article 5(2)”, where it imposes the duty to check the information against the requirements of IFRS and of the regulations of the National Bank and the financial supervisor.

The paragraphs are counted from the introductory line “The following are subject to mandatory audit:”, which is itself paragraph one, so the listed entities occupy paragraphs two to twenty-one. The amending statute confirms it: Law № 200-VIII of 30 June 2025 directed that “part one of article 5(2) be supplemented with paragraph five” reading “endowment funds”, and in the current text endowment funds stand fourth among the listed entities.

The second amending statute confirms the same count: Law № 270-VIII of 16 March 2026 directed that “part one of article 5(2) be supplemented with paragraph eighteen”, and the single sport operator stands seventeenth among the listed entities.

A cross-reference that no longer matches the list

Article 4(2) was last amended in 2020, and the article 5 list has been extended twice since. Before endowment funds were inserted on 31 August 2025, paragraphs four, five, six, eight and eleven pointed to insurance organisations, the pension fund and securities market participants, major participants of an investment portfolio manager, banks, and the insurance payments guarantee fund — a coherent set of financial sector entities, which is exactly what a requirement to check compliance with National Bank and financial supervisor regulations is for.

After the insertion the same numbers point to insurance organisations, endowment funds, the pension fund and securities market participants, subsoil users, and grain-receiving enterprises. Subsoil users and grain-receiving enterprises have nothing to do with National Bank regulations, and in that form the cross-reference has lost its internal logic.

The practical point is that references to the paragraphs of this article must be counted from the introductory line rather than from the first entity in the list, and that since August 2025 a literal reading of the article 4(2) cross-reference produces a set of entities that does not match its purpose.

The LLP: the only size threshold, and why it is miscalculated

A limited liability partnership is subject to mandatory audit only where two conditions are met simultaneously, and the first of them has nothing to do with the size of the business.

Two conditions joined by the word “simultaneously”

First condition: the partnership has participants (founders) holding less than ten per cent of the participatory interests in the charter capital.

Second condition: an average annual headcount of more than two hundred and fifty people and/or average annual income above three million MRP as set by the budget law and in force on 1 January of the relevant financial year.

The statute joins them with the formula “where the following conditions are met simultaneously” — a conjunction, not an alternative. The absence of either condition removes the mandatory audit.

What that means in practice

A partnership with a turnover of thirty billion tenge and a thousand employees, whose interests are held by two participants at 60 % and 40 %, is not subject to mandatory audit. The first condition fails: there is no participant below ten per cent.

A partnership with a five-per-cent participant but a turnover of one billion tenge and thirty employees is likewise not subject to mandatory audit. The second condition fails.

Mandatory audit arises only at the intersection: a minority holder below ten per cent, plus a breach of at least one of the two quantitative measures.

The threshold in tenge

Financial year	MRP at 1 January	Income threshold
2025	KZT 3,932	KZT 11,796,000,000
2026	KZT 4,325	KZT 12,975,000,000

Within the second condition the two measures are joined by “and/or” — exceeding either one is enough. A partnership with three hundred employees and a modest turnover satisfies the second condition.

A third, separate regime: audit on a minority holder’s demand

For a limited liability partnership that is a medium-sized business, an audit of the annual financial statements is carried out on the demand of a participant holding less than ten per cent of the participatory interests.

This is not a mandatory audit. The paragraph sits in the same article 5(2) but describes a different mechanism: the duty arises not by operation of law but on a minority holder’s demand, and only for medium-sized partnerships.

The practical consequence is that a medium-sized partnership with a minority holder can be required to obtain an audit at any moment on a unilateral demand, and cannot budget for it in advance.

How this compares with other regimes

The “a minority holder triggers the audit” logic also exists in the Astana International Financial Centre, but in mirror image: there, shareholders representing not less than ten per cent of the nominal share capital of a private company may require an audit. In Kazakh law the “less than ten per cent” test runs the other way — as a marker of dispersed ownership that justifies a mandatory audit. The difference between the two legal orders inside one country is examined in our piece on choosing between the AIFC and an LLP.

A third model — tying mandatory audit to revenue and to a company’s status in a free zone — operates in the United Arab Emirates, where an audit is required above a revenue threshold and also, regardless of revenue, for companies claiming preferential tax status; how that regime is built is set out in our piece on corporate audit requirements in the UAE.

Sectoral duties: where the audit obligation does not come from the audit law

Part of the audit obligation is imposed by sectoral statutes, and in several cases the sectoral rule is wider than the list in article 5 of Law № 304-I. Both layers have to be checked.

The sectoral provisions

Sector	Act and provision	What it establishes
Joint-stock companies	Law № 415-II, art. 78(1)	The company must audit its annual financial statements, other than a company declared bankrupt by a court and banks and insurers stripped of their licence or in compulsory liquidation
Joint-stock companies	Law № 415-II, art. 76(4)	A duty to publish annually in the depository the consolidated (or unco­nsoli­dated) annual statements and the audit report
Banks	Law № 258-VIII, art. 82(2)	Audit for the financial year is compulsory for banks, entities in which a bank is a major participant, and banking holdings, other than a bank stripped of its licence for all operations or in voluntary or compulsory liqui­datio­n; the bank and its holding are audited by the same audit orga­nisa­tion
Insurance	Law № 126-II, art. 20(8)	Audit for the year is compulsory; a copy of the report goes to the financial supervisor within 30 calendar days
Insurance	Law № 126-II, art. 20(6)	A compulsory internal audit function, which is not itself licensed
Securities market	Law № 461-II, art. 55-1(1)	Audit is compulsory for professional participants incorporated as joint-stock companies and for major participants of investment portfolio managers
Securities market	Law № 461-II, art. 32-6(6)	An Islamic special financial company must audit its annual statements
Shared housing construction	Law № 486-V, art. 19(8)	Developers and authorised companies must audit their annual statements
Shared housing construction	Law № 486-V, art. 28(9)	The single operator must audit its annual statements
Grain	Law № 143-II, art. 20	A grai­n-recei­ving enterprise carries out compulsory annual audits of its annual statements and of the current state of its affairs
Grain	Law № 143-II, art. 22	Publication of the annual balance sheet and profit and loss statement in the mass media
Subsoil	Code № 125-VI, art. 76(3)	Reporting under the EITI standard is confirmed by a person who is an auditor
Subsoil	Code № 125-VI, arts. 195 and 215	Expenditure on the licence area is confirmed by an auditor or disclosed in audited statements — for hard minerals only

Three cases where the sectoral statute is wider

First, the single operator in shared housing construction. Article 28(9) of Law № 486-V requires it to be audited, although it is not named in the article 5 list of Law № 304-I.

Second, the Islamic special financial company. The article 5 list names only “special financial companies under the Law on project financing and securitisation”; the Islamic special financial company takes its duty from article 32-6 of the securities market law.

Third, grain-receiving enterprises. Article 20 of the Law on grain extends the examination beyond the annual financial statements to “the current state of affairs” — a wider subject than an audit of financial statements in the sense of Law № 304-I. The same article, in paragraph 2, provides for judicial appointment of the audit: where the management body evades the audit, a court may order it on the application of any interested person. The same mechanism exists for joint-stock companies — article 78(3) of Law № 415-II: if the executive body evades the audit, a court may order it on the claim of any interested person. It is therefore not unique to the grain law, but neither is it a general rule: outside these two statutes no such mechanism exists.

Two cases where the audit law is the wider one

Civil aviation. Law № 339-IV of 15 July 2010 on the use of the airspace of the Republic of Kazakhstan and aviation activity imposes no duty to audit annual financial statements — the duty exists only in article 5 of Law № 304-I, together with its carve-out for airlines carrying out aerial work on the Government’s list.

Authorised economic operators. Code № 123-VI of 26 December 2017 on customs regulation imposes no audit duty: the articles checked — on the conditions for and procedure of inclusion in the register of authorised economic operators, on suspension and removal from it, and on the operator’s obligations — contain no audit requirement. The Code defines who an authorised economic operator is; the audit duty comes from article 5 of Law № 304-I.

Subsoil users: the duty is not where it is usually looked for

The Code on subsoil and subsoil use does not impose a mandatory audit of a subsoil user’s annual financial statements. The reference in article 5 of Law № 304-I to “the cases provided by the Code” operates through other provisions: an auditor’s confirmation of reporting under the Extractive Industries Transparency Initiative standard, the requirement for audited statements in a licence application, and an auditor’s confirmation of expenditure on the licence area.

A subsoil user’s real duty to audit its annual statements comes from the combination of two statutes: it is named in article 5 of Law № 304-I and is at the same time a public interest entity under Law № 234-III.

Auditor rotation: the only such rule in Kazakh law

Compulsory rotation of the audit organisation exists in Kazakhstan only for the insurance sector, under article 20(2) of Law № 126-II of 18 December 2000 on insurance activity. The word “rotation” does not appear in the audit law at all.

The formula

An insurance (reinsurance) organisation, an insurance broker, the organisation guaranteeing insurance payouts, an insurance holding, entities in which an insurer and/or an insurance holding is a major participant, and entities belonging to an insurance group may not have their activity audited by the same audit organisation for more than seven consecutive years, nor by the same auditor working in an audit organisation for more than five consecutive years.

The two limits run at the same time: seven years for the firm, five for the individual auditor inside it. Replacing the engagement auditor in year six preserves the firm through year seven.

The carve-out

The rotation requirement does not apply to an insurance (reinsurance) organisation that belongs to a banking conglomerate. It is the only exception, and it exists because of a competing rule at the same level: a bank and its holding are audited by the same audit organisation, and a rotation requirement would collide with it.

The single-auditor rule within a group

Entities belonging to an insurance group as parent and as Kazakh-resident subsidiaries are audited by one and the same audit organisation. Article 20(3) of Law № 126-II.

An equivalent rule operates in banking: under article 82(2) of Law № 258-VIII a bank and its banking holding are audited by the same audit organisation, and the same applies to resident entities in which the bank is a major participant.

What Kazakh law does not contain

There is no rotation requirement for joint-stock companies outside the financial sector. Neither the Law on joint-stock companies nor the Law on auditing activity limits how long one audit organisation may serve.

There is no rotation requirement in banking. The new banking law № 258-VIII, in force since March 2026, contains the single-auditor rule for a conglomerate but sets no maximum term of engagement.

There is no rotation requirement on the securities market. Article 55-1 of Law № 461-II sets requirements for the audit organisation and a deadline for sending the report to the regulator, but does not limit the length of the relationship.

The practical consequence: where a counterparty, a bank or an investor asks a Kazakh non-financial company to evidence auditor rotation, it cannot point to a statute — such a requirement can only be contractual or a group policy.

Who may audit: licence, certification, membership

Only audit organisations holding a licence for auditing activity may carry on that activity. Article 3(1) of Law № 304-I does not permit audit services to be supplied by an individual or by an unlicensed organisation.

Requirements for an audit organisation

An audit organisation is incorporated as a limited liability partnership. Any other form — a joint-stock company, sole trader status — is excluded by article 9.

An audit organisation must be a member of a professional organisation and must join one within one month of receiving its licence or of voluntarily leaving or being expelled from a previous one. Where the professional organisation it belongs to loses its accreditation, the audit organisation has three months to join another.

Audit organisations are prohibited from carrying on any other entrepreneurial activity. Article 3(3) is a direct prohibition; the list of permitted related services is closed and appears in article 3(2).

A foreign organisation is recognised as an audit organisation if its status is confirmed by the professional organisation of its state of residence, which must be a member of the International Federation of Accountants, or by the competent authority of that state.

Requirements for an auditor

An auditor is an individual certified by the Qualification Commission for the certification of candidate auditors and holding a qualification certificate conferring the qualification “auditor”.

Candidates must hold higher education and at least three years’ experience in economics, finance, internal control and inspection, or law, or in academic teaching of accounting and audit at a higher education institution.

A candidate who fails the examination may re-sit it three months after the Qualification Commission’s decision.

An auditor practises in one audit organisation only and may be a participant in only one audit organisation. Article 8 forbids combining the two.

Since 12 July 2026 the decision conferring the qualification “auditor” is published on the internet resources of the professional council and of the authorised body and is also posted in the Depository of Financial Reporting.

Minimum requirements for auditors of mandatory audits

An audit organisation that does not meet the minimum requirements for organisations carrying out mandatory audits is prohibited from carrying one out. The requirements are developed and approved by the authorised body in agreement with the financial supervisor — article 7(1-2) of Law № 304-I.

A stronger version of the same rule applies to financial organisations: a bank, an insurer or a professional securities market participant must engage an audit organisation meeting the minimum requirements for auditors of financial organisations.

The authorised body and licensing

The authorised body is the Ministry of Finance of the Republic of Kazakhstan, acting through its Department of Accounting, Audit and Valuation Methodology. It licenses auditing activity and maintains the register of audit organisations, maintains the register of auditors, accredits professional organisations and maintains their register, and exercises state control.

Auditing activity is licensed under the legislation on permits and notifications. An application from an organisation that has been deprived of its licence is not considered for one year.

Where a licence ceases to have effect the organisation must return it to the authorised body within ten working days, unless the licence was issued in electronic form.

Notifying the regulator of the auditor chosen

A bank notifies the financial supervisor of its choice of audit organisation no later than ten working days after signing the contract for an audit or for an audit of other information. That rule, in article 82(10) of Law № 258-VIII, has no counterpart in the non-financial sector.

The registers: what exists and what does not

A register of audit organisations is maintained and is current: its most recently published version is dated 13 July 2026 and includes licences issued as late as the end of June 2026. The register is reproduced by the legal databases; no free official address at which it can be opened in full could be found, and the Ministry of Finance’s open-data set “Register of audit organisations” on data.egov.kz is archived with an update date of 18 April 2023 and cannot be used as current.

The total number of licensed audit organisations could not be confirmed from open sources and is not stated in this article.

The register of accredited professional audit organisations as at 13 July 2026 contains six bodies: the Collegium of Auditors, the Chamber of Auditors of the Republic of Kazakhstan, the Union of Auditors of Kazakhstan, the Institute of Audit Organisations and Auditors of Kazakhstan, the League of Auditors, and the Commonwealth of Auditors of the Republic of Kazakhstan.

The status of a particular audit organisation should be checked in the permits register at elicense.kz — by business identification number or licence number — or requested from the authorised body; that register offers no browsable list by type of activity.

Independence: the seven prohibitions of article 24 and the three-year quarantine

Article 24 of Law № 304-I forbids an audit organisation to act in seven situations, and two of them create a three-year quarantine that is the most frequently breached rule in practice.

The seven prohibitions

First: a client of which the audit organisation, or the employees carrying out the audit, is a participant or a creditor.

Second: entities with which a civil liability insurance contract has been concluded within the last three years.

Third: entities to which, within the last three years, services of restoring and keeping accounting records, preparing financial statements or internal audit have been supplied — so far as accounting and/or financial reporting is concerned.

Fourth: clients whose engagement staff are in an employment relationship with, or are close relatives or in-laws of, officers of the audited entity or of a shareholder or participant holding ten per cent or more of the shares or participatory interests.

Fifth: clients whose engagement staff have personal property interests in the audited entity.

Sixth: where the audit organisation owes money to the audited entity or the audited entity owes money to it, other than obligations arising from the audit engagement.

Seventh: circumstances that give rise to a conflict of interest or create a threat of one, other than obligations arising from public contracts.

Why the three-year quarantine is the main practical problem

The second and third prohibitions look back “over the last three years”, not to the date of the engagement. An audit organisation that restored a company’s books in 2024 may not audit that company in 2025, 2026 or 2027.

The practical consequence for a company is that the sequence “let the auditor tidy the books first and then audit us” is unlawful. It is one of the most common and most expensive mistakes in preparing for a first mandatory audit, because it usually surfaces when the deadline is already close.

The third prohibition is drafted by reference to sub-paragraphs 2) and 3) of article 3(2) — so it catches both the restoration of accounting records and internal audit so far as accounting and financial reporting are concerned.

Conflict of interest as a free-standing ground

Conflict of interest is defined in article 1(15) as a situation in which the audit organisation’s own interest may influence its opinion on the reliability of the audited entity’s financial statements. The seventh prohibition catches not only an actual conflict but the threat of one — a construction wider than the six specific cases, operating as a general clause.

An eighth prohibition, standing apart

An audit organisation that does not meet the minimum requirements for organisations carrying out mandatory audits is prohibited from carrying one out. That prohibition sits in a separate paragraph of article 24 and applies to mandatory audits only.

The penalty

Carrying out an audit in a case prohibited by the Law attracts a fine on the legal entity of one hundred and twenty monthly calculation indices (MRP) with suspension of the licence — article 247(3) of the Code of Administrative Offences. In 2026 tenge that is KZT 519,000 plus suspension. That part covers the seven prohibitions set out above.

The eighth prohibition — carrying out a mandatory audit while not meeting the minimum requirements — has its own provision: article 247(10), a fine of one hundred MRP, that is KZT 432,500, with no suspension of the licence.

For the audited company the consequence is heavier than the fine: an audit report obtained in breach of article 24 is exposed, and a report that does not comply with the legislation is declared invalid by a court — article 18(3) of Law № 304-I.

The audit report: form, signature, registration and the 2026 digitalisation

An audit report is a written or electronic official document that is the result of an audit. The definition in article 1(6) of Law № 304-I has applied in this form since 12 July 2026: the word “electronic” was inserted by Law № 256-VIII of 9 January 2026.

Requirements for a paper report

A report in written form is signed by the engagement auditor, stating the number and date of issue of the qualification certificate, is sealed with the auditor’s personal seal, is approved by the signature of the head of the audit organisation and is sealed with the organisation’s seal.

The report also states the number and date of issue of the audit organisation’s licence.

A paper report must be registered in the Depository of Financial Reporting within three working days of the date on which it is drawn up. The clock runs from the date of the report, not from the date it reaches the client.

The electronic report: what changed on 12 July 2026

An audit report in electronic form is generated directly inside the Depository of Financial Reporting, and no registration of such a report in the depository is required.

That is the key practical change of 2026: the three-day registration deadline does not apply to an electronic report, because the report comes into existence inside the depository. For paper reports the former regime is preserved in full.

The two regimes coexist, and that matters for the 2026 reporting year. Paragraph 6 of the depository filing Rules — including as restated by order № 547 with effect from 5 September 2026 — still requires the audit report to be filed in PDF as a scanned copy of the signed and sealed paper original. The ability to generate an electronic report in the depository under article 18 of Law № 304-I does not automatically displace that requirement in the Rules, and the filing route for a given year is worth confirming with the depository operator.

Types of audit opinion

The types of audit opinion — unmodified, qualified, adverse, and a disclaimer — are not fixed in Law № 304-I.Article 18 speaks only of “the independent opinion of the engagement auditor and of the audit organisation on the financial statements”.

The classification of opinions applies by force of the international standards on auditing, which article 4 makes binding and which article 1(23) defines as the standards and documents issued by the International Federation of Accountants. Attributing the classification of opinions to the Kazakh statute is a common error in secondary material.

Unreliable and knowingly unreliable reports

An unreliable audit report is one drawn up in breach of the auditing legislation, containing unreliable and/or incomplete information that misleads users.

A knowingly unreliable audit report is one drawn up without an audit having been carried out, or containing an opinion deliberately intended to mislead users.

The distinction determines both the size and the character of the penalty: an unreliable report costs the auditor 80 MRP, a knowingly unreliable one 110 MRP with loss of the qualification certificate.

Declaring a report invalid

Where an audit report does not comply with the legislation of the Republic of Kazakhstan or with the facts, it is declared invalid by a court. Article 18(3) is the only mechanism for annulling a report, and it is judicial.

Commercial secrecy and its limits

Information obtained by the auditor in performing the engagement constitutes a commercial secret — with three exceptions: information supplied to the state revenue authorities; information disclosed to the asset recovery authority under the Law on the return of unlawfully acquired assets to the state; and, in relation to an audit of other information, information supplied with the clients’ consent to the financial supervisor.

The banking sector has the opposite rule: an audit report on the financial statements of a bank or of another entity in a banking conglomerate does not constitute a commercial secret — article 82(5) of Law № 258-VIII.

Publication: where exactly, and why the newspaper is no longer needed

Annual financial statements and the audit report are published on the internet resource of the Depository of Financial Reporting, not in the mass media. For joint-stock companies that is expressly provided by article 76(4) of Law № 415-II.

The joint-stock company’s duty

The company must publish annually on the internet resource of the Depository of Financial Reporting its consolidated annual financial statements — or, where it has no subsidiaries, its unconsolidated annual financial statements — together with the audit report, in the manner and within the periods established by the authorised body.

The requirement to publish in the mass media was replaced by publication on the depository’s internet resource by Law № 166-VI of 2 July 2018, in force from 1 January 2019. Material stating that a joint-stock company must publish its accounts in a newspaper describes a regime abolished more than seven years ago.

Where media publication survives

The duty to publish in the mass media survives in specific places — above all for grain-receiving enterprises.Article 22 of the Law on grain requires the annual balance sheet and the profit and loss statement to be published in the mass media within one calendar month after the date on which they fall due to the state revenue authorities.

It is that provision which activates the rule in the audit law: entities for which audit is mandatory and which publish their annual financial statements in the mass media under the legislation must publish the audit report alongside them. Since 2019 the rule effectively bites only for grain-receiving enterprises.

Disclosure by a joint-stock company

A company must disclose information on the internet resource of the Depository of Financial Reporting and on the internet resource of the stock exchange, in the manner established by the Law on the securities market and by the authorised body’s regulation. Article 79 of Law № 415-II is a duty separate from the publication of accounts, with its own list of disclosable events.

How a joint-stock company approves its accounts

The executive body presents the audited annual financial statements for the past year to the annual general meeting of shareholders each year and, alongside the statements, presents the audit report.

The annual financial statements are subject to preliminary approval by the board of directors no later than thirty days before the date of the annual general meeting; final approval is given at the meeting itself.

The practical consequence is that a joint-stock company’s countdown starts long before 31 August. To respect the thirty-day preliminary approval period and hold the meeting, the audit must be finished well ahead of the depository deadline.

Summary of publication and filing deadlines

Action	Who	Deadline
Preliminary approval of the accounts by the board	Joint-stock company	no later than 30 days before the annual general meeting
Final approval of the accounts	Joint-stock company	at the annual general meeting of shareholders
Presenting the accounts to founders, statistics and supervisory bodies	All organisations	no later than 30 April
Publishing the accounts and the audit report in the depository	Public interest entities	no later than 31 August
Registering a paper audit report in the depository	Audit organisation	3 working days from the date on which it is drawn up
Publishing the balance sheet and profit and loss statement in the media	Grai­n-recei­ving enterprises	1 calendar month after they fall due to the state revenue authorities

The AIFC: a different legal order inside one country

For participants of the Astana International Financial Centre, accounting, audit and filing are governed by the acts of the Centre rather than by Law № 234-III and Law № 304-I. The basis is article 4 of Constitutional Law № 438-V of 7 December 2015: the law of the Republic of Kazakhstan applies in the Centre only “so far as not regulated by this Constitutional Law and by the acts of the Centre”.

What of the Kazakh regime does not reach AIFC participants

Inside the Centre the mandatory audit list in article 5 of Law № 304-I, the Depository of Financial Reporting, the 31 August deadline and the Ministry of Finance audit licence do not apply.

Administrative liability is a harder question. Article 4(3) of the Constitutional Law lists the relations the Centre’s acts may regulate: civil, civil procedure, financial, administrative procedure and procurement. Administrative liability is not on that list, so the conclusion that the audit offences in the Code of Administrative Offences do not reach the Centre is a construction rather than an express rule, and it is offered here as a construction.

How the Centre’s regime works

Accounting, reporting and audit for AIFC companies sit in Part 10 of the AIFC Companies Regulations, “Accounts, Reports and Audit”.

The directors must ensure that, within six months after the end of each financial year, the accounts are prepared and approved by the directors, examined and reported on by an auditor, laid before a general meeting together with the auditor’s report and the directors’ report if the company is a public company, and sent to every shareholder.

A copy of the accounts and the auditor’s report is filed with the Registrar of Companies within fourteen days after they are sent to shareholders.

A private company and its directors are exempt from the audit requirement and from filing the accounts together with the auditor’s report with the Registrar where the company’s annual turnover does not exceed US$5,000,000— unless its articles of association provide otherwise. The exemption removes both duties — examination by an auditor and filing with the Registrar — so most private companies in the Centre file nothing at all.

Shareholders representing not less than ten per cent of the nominal value of such a private company’s share capital may, by written notice, require an audit for a financial year. The notice is given no earlier than the start of the financial year and no later than one month before its end.

The two regimes compared

Parameter	Kazakh regime	AIFC regime
Who must be audited	the closed list in article 5 of Law № 304-I	every company, except private companies with turnover up to US$5,000,000
Size threshold	more than 250 employees and/or 3,000,000 MRP— for LLPs only	U­S$5,000,000 of annual turnover
The minority holder’s role	a participant below 10 % makes the audit mandatory	shareholders of not less than 10 % may require an audit
Deadline for the audit	not fixed by statute	6 months after the financial year end
Where the accounts are filed	the Depository of Financial Reporting	the Registrar of Companies — but exempt private companies file nothing
Filing deadline	31 August of the following year	14 days after they are sent to shareholders
Financial year	strictly the calendar year, 1 January to 31 December	first year up to 18 months, thereafter 12 months ± 7 days
Admission of the auditor	Ministry of Finance licence, qualification certificate, membership of a professional organisation	re­gistra­tion with the Registrar
Retention of accounting records	under the rules of Law № 234-III	at least 6 years from creation

The practical conclusion

The logic of the two regimes is mirror-imaged: in Kazakh law a small minority holder triggers a mandatory audit automatically, while in the AIFC a holder of at least ten per cent must actively demand one, failing which the turnover exemption stands. The choice between the two legal orders inside one country is examined in our piece on the AIFC and the LLP.

One important reservation: the carve-out works only “so far as not regulated” by the Centre’s acts. Where those acts are silent, general Kazakh law applies, and it cannot be assumed that an AIFC participant is removed from Kazakh obligations altogether.

Liability: what each breach costs

Penalties in accounting, reporting and audit are spread across nine articles of the Code of Administrative Offences — 238, 239, 245, 246, 246-1, 247, 248, 249 and 250 — and they are addressed to different people: the entity, the officer, the auditor and the audit organisation each answer under a different provision.

Article 247 has twelve parts: eleven numbered ones plus part 7-1. That is not a typographical slip in the Code but the result of inserting a new offence without renumbering the rest.

Every amount below is computed on the 2026 MRP of KZT 4,325.

Liability of the audited entity

Provision	Offence	Penalty	In tenge
Art. 250	Evading a mandatory audit or obstructing it	15 / 20 / 200 MRP	64,875 / 86,500 / 865,000
Art. 249	Supplying the audit organisation with untimely, unreliable or incomplete information that leads to an unreliable report	20 / 25 / 100 MRP	86,500 / 108,125 / 432,500
Art. 239(1)	Failing to keep records; failing to file with the depository; distorting the statements; a public interest entity’s statements signed by a chief accountant who is not a professional accountant	100 / 200 / 500 MRP	432,500 / 865,000 / 2,162,500
Art. 239(2)	The same offences repeated within a year	200 / 400 / 1,000 MRP	865,000 / 1,730,000 / 4,325,000
Art. 238(1)	Substantially the same conduct by individuals and officers	100 MRP	432,500
Art. 238(2)	Repeated within a year	200 MRP	865,000

In each set of three figures the amounts are those for small business and non-commercial organisations, for medium business and for large business respectively.

Liability of the auditor and the audit organisation

Provision	Offence	Penalty
Art. 246(1)	An unreliable audit report	80 MRP on the auditor, 180 MRP on the organisation, with or without suspension of the licence
Art. 246(2)	A knowingly unreliable report	110 MRP on the auditor with loss of the qualification certificate, 220 MRP on the organisation with suspension of the licence
Art. 246(3) and (4)	Repeated within a year	loss of the auditor’s qualification certi­fica­te, loss of the orga­nisa­tion’s licence
Art. 245	An auditor concealing from the client a breach of accounting legislation found during the audit	50 MRP with loss of the qualification certificate
Art. 246(5)	An unreliable audit opinion on taxes	200 % of the engagement fee, minimum 500 MRP
Art. 246(6)	The same repeated within a year	250 % of the engagement fee, minimum 600 MRP
Art. 246-1	Breaching the procedure for a tax audit or a specia­l-pu­rpose audit	150 MRP
Art. 247(3)	Auditing in a prohibited case	120 MRP with suspension of the licence
Art. 247(8)	Failing to submit an audit report to the financial supervisor	170 MRP
Art. 247(10)	Carrying out a mandatory audit while not meeting the minimum requirements	100 MRP
Art. 247(11)	Failing, or failing in time, to join a professional organisation	200 MRP with loss of the licence
Art. 248	Offences concerning the auditor’s personal seal	100 MRP, 200 MRP on repeat

Two provisions worth knowing separately

Note 1 to article 238: an officer is not held liable where the breaches found on a desk audit are remedied independently within ten working days from the day following service of the notice. It is a working release mechanism, and missing it costs 100 MRP.

Note 2 to article 238 and the note to article 239 set a materiality threshold for distortion: more than twenty MRP for article 238, and more than one hundred MRP for parts 1, 2 and 4 of article 239. Distortion below the threshold is not an offence.

The director’s liability

A director who evades a mandatory audit, obstructs it, or fails to procure it is liable under the laws of the Republic of Kazakhstan. Article 27(2) of Law № 304-I is a referring provision, given effect through article 250 of the Code.

None of these articles changed in 2026

The most recent amendments: article 238 by Law № 114-VIII of 05.07.2024; articles 239 and 247 by Law № 155-VIII of 10.01.2025; articles 245 and 246 in 2017; article 246-1 in 2022; articles 248, 249 and 250 have not been amended. No deferred amendment commencing in 2026 or 2027 was found for any of them.

How the penalties compare

The fine for evading a mandatory audit is 15 MRP for a small business — KZT 64,875 — while the fine for failing to file with the depository is 100 MRP for the same category, KZT 432,500. The formal penalty for having no audit is almost seven times lower than the penalty for a reporting breach.

The real cost of having no audit, however, does not lie in the fine. Without an audit report a public interest entity cannot properly complete its depository filing, a joint-stock company cannot approve its accounts at the annual meeting in the manner required by article 76 of Law № 415-II, and a bank, insurer or securities market participant breaches a separate sectoral duty owed to the financial regulator.

A step-by-step sequence for the reporting year

The sequence for a Kazakh company runs to nine steps, and the first three belong at the start of the year rather than at its end.

Step 1. Determine the business category

The test is article 24 of the Entrepreneurial Code: average annual headcount and average annual income measured against the MRP in force on 1 January of the relevant financial year. Check separately whether the activity is one of the fourteen that bar small-business status.

Step 2. Check public interest status

The test is article 1(7) of Law № 234-III, and the position needing most care is the last one: any state share in the charter capital, or affiliation with an entity that has one.

Step 3. Fix the applicable standard in the accounting policy

The standard follows from steps 1 and 2: the national standard, IFRS for SMEs or full IFRS. A decision to apply a higher standard voluntarily is taken by the body that approved the accounting policy.

Step 4. Test the audit duty at both levels

The first level is the list in article 5(2) of Law № 304-I. The second is the sectoral statutes, which in several cases go wider. For a limited liability partnership both conditions are tested together, and for a medium-sized partnership there is the further question whether a minority holder able to demand an audit exists.

Step 5. Choose the audit organisation and test its independence

What to check	Provision
A licence for auditing activity	art. 3(1), Law № 304-I
Membership of a professional organisation	art. 21(2), Law № 304-I
Compliance with the minimum requirements for auditors of mandatory audits	art. 24, Law № 304-I
No bookkeeping or financial statement preparation services in the last three years	art. 24, Law № 304-I
No civil liability insurance contract in the last three years	art. 24, Law № 304-I
For the insurance sector, compliance with the 7-year / 5-year rotation	art. 20(2), Law № 126-II

Step 5 belongs well before signature: the three-year quarantine rules out an auditor who has recently kept the company’s books.

Step 6. Carry out the audit and obtain the report

The engagement must set out the subject matter, timing, fee and payment terms, the parties’ rights, duties and liability, confidentiality, and the audit organisation’s membership of a professional organisation. Those are the requirements of article 17(2) of Law № 304-I.

A paper report is registered in the depository within three working days of the date on which it is drawn up; an electronic one is generated in the depository and requires no registration.

Step 7. Approve and present the accounts by 30 April

The annual statements go to the founders, to statistics, to state supervisory bodies and to the parent no later than 30 April. A joint-stock company must additionally observe the thirty-day preliminary approval period before the annual general meeting.

Step 8. File the accounts and the audit report with the depository by 31 August

Public interest entities file an electronic report through the personal account on the depository portal, signed with the electronic digital signatures of the head of the entity and the chief accountant. The authorised organisation responds within three working days.

An error cannot be corrected: filed documents are not subject to replacement or deletion.

Step 9. Close out the sectoral and tax obligations

Separate duties survive outside the general regime: a copy of the audit report to the financial supervisor within thirty calendar days for insurers and securities market participants, notification of the regulator of the auditor chosen within ten working days for banks, and publication in the mass media for grain-receiving enterprises.

The tax side of paying the auditor is a separate check. Where the audit is carried out by a foreign organisation, the fee for audit services is subject to corporate income tax withheld at source regardless of where the services are physically performed — the mechanics are covered in our piece on withholding tax in Kazakhstan.

Common mistakes, and what each of them costs

The eight mistakes below recur constantly, and each has a measurable price — from 15 MRP to the loss of any ability to rely on the audit report obtained.

Mistake 1. Assuming that mandatory audit follows the size of the business

The size test applies only to limited liability partnerships, and only together with the condition that a participant holds less than ten per cent. A company with a turnover of thirty billion tenge and two equal participants is not subject to mandatory audit; a joint-stock company with a turnover of ten million tenge is.

The error costs in both directions: either an unnecessary audit fee, or a fine under article 250 of the Code plus an inability to complete the depository filing.

Mistake 2. Having the books restored by the same firm that will then audit them

Article 24 of Law № 304-I prohibits auditing an entity to which bookkeeping or financial statement preparation services have been supplied in the last three years. The quarantine looks back three years, not to the date of signature.

The cost: a fine of 120 MRP on the audit organisation with suspension of its licence and, for the company, an audit report exposed to being declared invalid by a court and the need to re-run the audit against a short deadline.

Mistake 3. Conflating the 30 April and 31 August deadlines

30 April is for presenting the statements to founders, statistics and supervisory bodies. 31 August is for filing with the depository by public interest entities. They are different duties owed to different recipients.

The cost: a fine under article 239(1) of between KZT 432,500 and KZT 2,162,500 depending on category, and double that on a repeat within a year.

Mistake 4. Assuming the state shareholding must be significant

The definition of a public interest entity catches entities with a share of state participation in their charter capital, with no minimum stated, together with every affiliated legal entity.

The cost: statements prepared under the national standard instead of full IFRS, and statements not filed with the depository — two separate offences at once.

Mistake 5. Publishing a joint-stock company’s accounts in a newspaper

The requirement to publish in the mass media was replaced by publication on the depository’s internet resource from 1 January 2019. Publishing in a newspaper does not discharge the duty.

The cost: the price of the publication plus an undischarged duty under article 76(4) of Law № 415-II.

Mistake 6. Planning the audit around the 31 August deadline

A joint-stock company’s accounts must be preliminarily approved by the board no later than thirty days before the annual general meeting, and finally approved at the meeting itself; both steps require a finished audit report.

The cost: a failure of the corporate timetable rather than of the depository deadline, and the need to convene an extraordinary meeting.

Mistake 7. Counting on correcting a filing already made

Financial statements and audit reports filed with the depository are not subject to replacement or deletion. There is no amended-return mechanism of the kind familiar from tax filing.

The cost: the incorrect figures stay in an openly accessible database indefinitely, visible to counterparties, banks and regulators.

Mistake 8. Citing the repealed resolution on the depository

Government Resolution № 1173 of 14 October 2011 was repealed by Government Resolution № 65 of 16 February 2022. The instrument in force is order of the Minister of Finance № 94 of 28 January 2022.

The cost: a position built on a repealed act collapses at the first check, and takes with it the credibility of every other conclusion in the same document. Checking the regulatory status of a counterparty and of one’s own structure is part of the same discipline as evidencing eligibility for a tax relief; how that works in practice is shown in our piece on Astana Hub and the auditor-confirmed report.

Who the Kazakh regime suits, who it does not, and when professional review is needed

Who it suits

•          Limited liability partnerships with concentrated ownership: with no participant below ten per cent there is no mandatory audit, whatever the turnover.

•          Small businesses: the national financial reporting standard is materially simpler than full IFRS, and as a rule they have no depository filing duty.

•          Companies that need a predictable calendar: the reporting period is tied to the calendar year, and the 30 April and 31 August deadlines do not move from year to year.

•          Groups running a single accounting policy: the parent’s right to determine how subsidiaries apply that policy is expressly conferred by statute.

Who it does not suit

•          Companies with dispersed ownership: a participant below ten per cent, combined with a breach of one quantitative measure, makes the audit mandatory every year.

•          Structures with any state shareholding: public interest status brings full IFRS and depository filing regardless of the size of the holding or of the business.

•          Companies used to a non-calendar financial year: article 18 of Law № 234-III admits no alternative.

•          Anyone expecting to correct a filing already made: replacement and deletion of documents filed with the depository are not provided for.

•          Companies planning to give bookkeeping and audit to the same firm: the three-year quarantine in article 24 closes that route.

When professional review is needed

•          When a state shareholding, or affiliation with an entity that has one, enters the structure — public interest status arises automatically and changes the reporting standard.

•          When a partnership approaches more than 250 employees and/or 3,000,000 MRP and has a minority holder— the duty crystallises on the year’s results, while preparation takes months.

•          When the company belongs to a banking conglomerate or an insurance group — the single-auditor and rotation rules interact in non-obvious ways.

•          When the duty comes from a sectoral statute rather than the article 5 list — there are several such cases and none of them is self-evident.

•          When registration in the Astana International Financial Centre is on the table — a different legal order applies there, with different thresholds and deadlines.

If the Kazakh company is only now being formed, start with the structure — the options and the registration procedure are set out on the UPPERSETUP Kazakhstan page.

Frequently asked questions

Who must have a mandatory audit in Kazakhstan in 2026?

The entities expressly named in article 5(2) of Law № 304-I: joint-stock companies, banks, insurers, securities market participants incorporated as joint-stock companies, subsoil users, grain-receiving enterprises, developers, authorised economic operators and a number of further categories, twenty positions in all. Limited liability partnerships only where two conditions are met at once.

Must an LLP be audited?

Only where two conditions are met simultaneously: it has a participant holding less than ten per cent, and its average annual headcount exceeds 250 people and/or its average annual income exceeds 3,000,000 MRP, which is KZT 12,975,000,000 in 2026. The absence of either condition removes the duty.

By what date must financial statements be filed with the depository?

No later than 31 August of the year following the reporting year. The deadline is set by paragraph 3 of the Rules approved by order of the Minister of Finance № 94 of 28 January 2022.

How does 30 April differ from 31 August?

30 April is the deadline for presenting the annual statements to founders, the statistics authority, state supervisory bodies and the parent, under article 19(3) of Law № 234-III. 31 August is the deadline for public interest entities to file the statements and the audit report with the depository. They are different duties, and one does not replace the other.

Which reporting standard does an LLP apply?

A small business applies the national standard; a medium business applies the international standard for small and medium-sized entities; a large business and a public interest entity apply full IFRS. Moving up voluntarily is allowed; moving back down is not.

What is the penalty for not having a mandatory audit?

A fine under article 250 of the Code of Administrative Offences: 15 monthly calculation indices (MRP) for small businesses and non-commercial organisations, 20 for medium businesses and 200 for large businesses. In 2026 tenge that is KZT 64,875, KZT 86,500 and KZT 865,000 respectively.

Must the auditor be changed after a certain time?

Compulsory rotation exists only in the insurance sector, under article 20(2) of Law № 126-II: no more than seven consecutive years with one audit organisation and no more than five consecutive years with one auditor. No rotation requirement applies in other sectors.

Can the firm that kept the company’s books also audit them?

No. Article 24 of Law № 304-I prohibits auditing an entity to which bookkeeping or financial statement preparation services have been supplied in the last three years. The prohibition looks back three years from the audit.

Must a joint-stock company publish its accounts in a newspaper?

No. Since 1 January 2019 publication in the mass media has been replaced by publication on the internet resource of the Depository of Financial Reporting — article 76(4) of Law № 415-II. Media publication survives in specific places, principally for grain-receiving enterprises.

Is an individual entrepreneur exempt from bookkeeping?

Only where three conditions are met at once: the special tax regime based on a simplified declaration with income for the calendar year of no more than 135,000 MRP; no VAT registration; and no natural monopoly status. Primary documents must be drawn up and kept in every case.

What changed in audit on 12 July 2026?

An audit report may now be electronic and is generated directly in the Depository of Financial Reporting, requiring no registration. The three-day registration deadline is preserved for paper reports. At the same time the depository was redefined as a digital database.

Do these rules apply to AIFC companies?

Not beyond what the Centre’s own acts leave unregulated. Accounting, audit and filing for participants of the Astana International Financial Centre are governed by Part 10 of the AIFC Companies Regulations: audit is required of every company except private companies with turnover up to US$5,000,000, and the accounts are filed with the Registrar of Companies within fourteen days of being sent to shareholders.

Key takeaways

1.        Every legal entity must keep accounts; only those named in article 5(2) of Law № 304-I must be audited.

2.        The size test for mandatory audit exists only for LLPs and works only together with the condition of a participant holding less than ten per cent.

3.        The LLP income threshold for 2026 is KZT 12,975,000,000; the 2026 MRP is KZT 4,325, and no lag applies.

4.        The reporting standard follows from the business category and public interest status, not from the company’s choice.

5.        Any structure with a state share in its charter capital — with no minimum stated — becomes a public interest entity, as does every affiliate of it.

6.        The reporting period is strictly the calendar year; Kazakh law permits no non-calendar financial year.

7.        30 April and 31 August are two different deadlines owed to different recipients, and neither replaces the other.

8.        Statements and audit reports filed with the depository cannot be replaced or deleted.

9.        Auditor rotation is compulsory only in the insurance sector: seven years for the firm, five for the auditor.

10.    The three-year quarantine in article 24 bars an audit by the firm that kept the company’s books or prepared its statements.

11.    From 12 July 2026 an electronic audit report is generated in the depository and needs no separate registration.

12.    Government Resolution № 1173 of 14 October 2011 was repealed in 2022; the instrument in force is MoF order № 94 of 28 January 2022.

13.    Order of the Minister of Finance № 547 of 14 August 2026 restates paragraphs 1, 3, 4 and 6 of the Rules from 5 September 2026: the 31 August deadline survives, and the duty to file the audit report is tied expressly to article 5(2) of Law № 304-I.

14.    From 21 October 2026 Law № 352-VIII removes the entire microfinance sector from the category of public interest entities — the amendment is not yet in force at the date of writing.

Summary 

The duty to keep accounting records and prepare financial statements in Kazakhstan is imposed by Law № 234-III of 28 February 2007 and extends to every legal entity, branch, representative office and permanent establishment of a foreign legal entity, and to individual entrepreneurs; the only exemption is available to an individual entrepreneur meeting three conditions simultaneously, including income of no more than 135,000 MRP. The standard follows from the business category under article 24 of the Entrepreneurial Code and from public interest status: the national standard for small business, the international standard for small and medium-sized entities for medium business, and full IFRS for large business and public interest entities. The reporting period is the calendar year, and the annual statements go to founders, the statistics authority and supervisory bodies no later than 30 April of the following year. Public interest entities additionally file the annual statements and, where audit is mandatory, the audit report with the Depository of Financial Reporting no later than 31 August, under the Rules approved by order of the Minister of Finance № 94 of 28 January 2022. Mandatory audit is governed by Law № 304-I of 20 November 1998: article 5(2) contains a closed list of twenty positions including joint-stock companies, banks, insurers, subsoil users, grain-receiving enterprises, developers and authorised economic operators; a limited liability partnership falls within mandatory audit only where it has a participant holding less than ten per cent and exceeds 250 employees and/or 3,000,000 MRP, which is KZT 12,975,000,000 in 2026 at an MRP of KZT 4,325. Rotation of the audit organisation is compulsory only in the insurance sector — no more than seven consecutive years with one organisation and five with one auditor, under article 20(2) of Law № 126-II. Article 24 of Law № 304-I prohibits auditing an entity to which bookkeeping services were supplied in the last three years. From 12 July 2026 an electronic audit report is generated in the depository and requires no registration, while a paper report is registered within three working days. Evading a mandatory audit is punished under article 250 of the Code of Administrative Offences by a fine of 15, 20 or 200 MRP, and failing to file with the depository under article 239(1) by a fine of 100, 200 or 500 MRP. For participants of the Astana International Financial Centre, Part 10 of the AIFC Companies Regulations applies: audit is required of every company except private companies with turnover up to US$5,000,000, and the accounts are filed with the Registrar of Companies within fourteen days of being sent to shareholders.

Sources

1.        Law № 234-III of 28.02.2007 on accounting and financial reporting, as amended to 12.07.2026 — Paragraph legal database

2.        The same law on a mirror carrying article text and amendment footnotes — zakon.uchet.kz

3.        Law № 304-I of 20.11.1998 on auditing activity, as amended to 12.07.2026 — Paragraph legal database

4.        Law № 415-II of 13.05.2003 on joint-stock companies, as amended to 13.08.2026 — Paragraph legal database

5.        Law № 258-VIII of 16.01.2026 on banks and banking activity in the Republic of Kazakhstan — Paragraph legal database

6.        Law № 126-II of 18.12.2000 on insurance activity, as amended to 12.07.2026 — Paragraph legal database

7.        Law № 461-II of 02.07.2003 on the securities market — Ädilet legal information system

8.        Code № 125-VI of 27.12.2017 on subsoil and subsoil use — Ädilet legal information system

9.        Law № 486-V of 07.04.2016 on shared participation in housing construction — Ädilet legal information system

10.    Law № 143-II of 19.01.2001 on grain — Ädilet legal information system

11.    Entrepreneurial Code № 375-V of 29.10.2015, as amended to 07.09.2026 — Paragraph legal database

12.    Code of Administrative Offences № 235-V of 05.07.2014, as amended to 20.08.2026 — Paragraph legal database

13.    Law № 239-VIII of 08.12.2025 on the republican budget for 2026–2028 — MRP KZT 4,325 — Ädilet legal information system

14.    Order of the Minister of Finance № 94 of 28.01.2022 approving the Rules on filing financial statements of public interest entities with the depository — Ädilet legal information system

15.    Constitutional Law № 438-V of 07.12.2015 on the Astana International Financial Centre — Ädilet legal information system

16.    AIFC Companies Regulations, Part 10: Accounts, Reports and Audit — AFSA legal framework

17.    The Depository of Financial Reporting portal — Information and Accounting Centre JSC

18.    Order of the Minister of Finance № 547 of 14.08.2026 amending the depository filing Rules — Ädilet legal information system

19.    Law № 352-VIII of 23.07.2026 — amendments commencing on 21 October 2026 — Ädilet legal information system

20.    Law № 141-VIII of 04.12.2024 on the republican budget for 2025–2027 — MRP KZT 3,932 — Ädilet legal information system

21.    Law № 258-VIII of 16.01.2026 — the act record with publication dates — Ädilet legal information system

The versions used are dated 12 July 2026 (Laws № 234-III and № 304-I), 13 August 2026 (Law № 415-II), 20 August 2026 (the Code of Administrative Offences) and 7 September 2026 (the Entrepreneurial Code). Some databases show 23 July 2026 for Law № 234-III — that is the date of Law № 352-VIII, whose amendments are printed as notes and come into force only on 21 October 2026; the version in force at the date of writing is that of 12 July 2026. The Ädilet portal is closed to automated reading, so verbatim wording was taken from mirrors that carry amendment footnotes; the Ädilet links are given as links to the official source of publication.

Disclaimer

This material is provided for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision, individual professional advice should be obtained that takes account of the specific situation, jurisdiction, company status and the current requirements of the regulators.

Date of publication: September 2026.