Permits and Notifications in Kazakhstan in 2026: What Is Licensed and What Is Notified under Law No. 202-V — Three Danger Levels, 81 Licences, 226 Second-Category Permits and 65 Notifications

The Law of the Republic of Kazakhstan No. 202-V of 16 May 2014 “On Permits and Notifications” is the single statute that sorts every kind of business activity in Kazakhstan into three groups by level of danger: high-danger activities require a licence (a first-category permit), medium-danger activities a second-category permit, and low-danger activities a notification of commencement or termination. Exhaustive lists of all three groups are contained in three annexes to the Law: on the consolidated text as at 9 September 2026, Annex 1 holds 81 licence entries in force, Annex 2 226 second-category permit entries and Annex 3 65 notifications. If an activity appears in none of the annexes, no permit of any kind is needed: Article 17(6) of the Law and Article 109(1) of the Entrepreneurial Code expressly prohibit introducing a permit or notification requirement other than by inclusion in these lists. A licence is, as a rule, issued no later than 15 working days and without a time limit, a licence fee is payable at the rates set by Article 616 of Tax Code No. 214-VIII (from 3 to 3,845 MRP, that is from 12,975 to 16,629,625 tenge at the 2026 MRP of 4,325 tenge), and a notification allows the business to start immediately after it is sent.

Key facts. First: the lists are closed — Article 18 of the Law and Article 109 of the Entrepreneurial Code allow a new permit to be introduced only through Annexes 1–3 (the sole exception being permit documents for the export and import of particular goods under Article 37) and only after a regulatory impact analysis, and the subordinate acts setting out the issuing procedure cannot take effect earlier than 60 calendar days after publication. Second: from 1 January 2026 the annual “payment for the use of a licence” for alcohol and gambling activities, which existed under Articles 555–558 of the previous Tax Code, is absent from Tax Code No. 214-VIII; the licence fee has become a one-off payment made before the application is filed. Third:“silence is consent” works: if the licensor has issued neither a licence nor a reasoned refusal within the time limit, the licence is deemed issued from the date the time limit expired (Article 26), but in the financial sector, digital mining, nuclear energy and a number of other Annex 1 entries the rule is expressly switched off by a note. Fourth: liability attaches to the absence of any of the three documents: Article 463 of the Code of Administrative Offences punishes both working without a licence and failing to send a notification with a fine of 15 to 150 MRP and confiscation of the objects and instruments of the offence, and working without a licence additionally with confiscation of the income earned; Article 214 of the Criminal Code moves the matter into the criminal sphere once income exceeds 10,000 MRP (43,250,000 tenge).

Key parameters of Kazakhstan’s permit and notification regime: summary table

Which legal acts govern permits and notifications in Kazakhstan in 2026?

Kazakhstan’s permit system rests on four tiers of legislation, and each tier answers its own question. The first tier is the Entrepreneurial Code of the Republic of Kazakhstan No. 375-V of 29 October 2015: its Chapter 9 (Articles 108–112) lays down the principle itself — a business entity must hold a valid permit or send a notification before starting an activity (Article 108), a permit requirement is introduced only by inclusion in the annexes to Law No. 202-V after a regulatory impact analysis (Article 109), and kandas (ethnic Kazakh returnees) and foreign legal entities obtain permits on an equal footing with citizens and legal entities of Kazakhstan unless laws or international treaties provide otherwise (Article 110(3)). The second tier is Law No. 202-V itself: it defines the terms, the danger levels, the permit classes and the procedures for issue, re-issue, suspension and termination, and its Annexes 1–3 are the only place where a new permit or notification can appear.

The third tier consists of the sectoral laws and subordinate acts that set the qualification and permit requirements.The Government determines the licensors and the bodies that issue second-category permits (Article 10(2) and (4) of the Law); the qualification and permit requirements, the lists of supporting documents and the rules of permit procedures are drafted and approved by the regulating state bodies in agreement with the authorised body for permits and notifications and the authorised body for digitalisation (Article 12(1)(1-1), (2-1) and (4)), and in the financial sector by the Agency for Regulation and Development of the Financial Market and the National Bank (Article 12(2)). Article 12(1)(7) gives the entrepreneur an unusual tool: on application, the regulating body must issue an opinion on whether a permit is or is not required for a specific activity. The authorised body for permits and notifications is the Ministry of National Economy of the RK: sub-paragraphs 156), 156-1), 156-4) and 156-6) of the Regulation on the Ministry (Government Resolution No. 1011 of 24 September 2014) assign to it the coordination of other state bodies, the implementation of state policy, regulatory and control-and-supervisory functions and the drafting of legal acts in this sphere. The fourth tier is thefinancial and punitive superstructure: Articles 612–616 of Tax Code No. 214-VIII of 18 July 2025 (the licence fee), Articles 463–465 of the Code of Administrative Offences No. 235-V of 5 July 2014 and Article 214 of the Criminal Code No. 226-V of 3 July 2014.

Law No. 202-V was adopted on 16 May 2014, published on 20 May 2014 in the newspapers Kazakhstanskaya Pravda and Egemen Qazaqstan, and came into force six months later — on 21 November 2014. By Article 53(2) it repealed the Law of 11 January 2007 “On Licensing”, so any reference to the “Licensing Law” in current commentary describes a repealed act. The “History of amendments” in the Adilet legal information system records 229 versions of the Law’s text; the latest redaction is dated 8 September 2026. In 2026 alone fourteen laws have touched the Law: those of 9 January No. 254-VIII (reference to the Construction Code No. 253-VIII of 9 January 2026 and the new title of the Law “On State and Socially Responsible Services”), 9 January No. 256-VIII (the switch to “digital” terminology, proactive re-issue, automated issue), 16 January No. 259-VIII (basic and universal banking licences), 12 February No. 263-VIII (exclusion of entry 20 of Annex 2), 7 April No. 277-VIII and 12 June No. 309-VIII (Article 28), 19 May No. 291-VIII (Articles 25 and 34, from 12 July 2026), 11 June No. 306-VIII (alignment with the Constitution, from 1 July 2026), 19 June No. 320-VIII (communications services and the notification of the commissioning of data centres, from 20 August 2026), 24 June No. 322-VIII (the electricity industry, from 1 September 2026), 24 June No. 326-VIII and 7 July No. 334-VIII (amendments to the annexes, partly deferred to 1 January 2027), 7 July No. 336-VIII (nuclear energy, September 2026) and 23 July No. 352-VIII (payment organisations, in force from 21 October 2026). Deferred amendments to Annexes 1–3 under the laws of 8 July 2024 No. 121-VIII and 30 December 2024 No. 148-VIII take effect on 1 January 2027, and those to Annex 2 under the law of 9 January 2026 No. 254-VIII on 1 July 2028.

For the reader this means that a “recent” commentary from 2024–2025 almost certainly misses at least one of the fourteen 2026 laws. The correct order of verification is the consolidated text of the Law on adilet.zan.kz with the “(in force from …)” footnotes under each article, then the rates in Article 616 of the Tax Code, then the qualification requirements of the specific licensor. The structural questions from which the need for a licence flows — the form of presence, the registration of an LLP, a branch or a representative office — are covered in the UPPERSETUP articles on registering an LLP in Kazakhstan for foreigners and on a branch and representative office of a foreign company versus an LLP.

How does a licence differ from a second-category permit and a notification: three danger levels and six classes

The level of danger of an activity is the sole criterion by which Law No. 202-V allocates activities among the three regimes. Article 16 provides that first-category permits — licences — are introduced for activities of a high level of danger; second-category permits, that is all permits that are not licences, for activities of a medium level; and notifications for activities of a low level of danger that nonetheless require the state to be informed of commencement or termination. The level of danger is determined on the basis of a regulatory impact analysis (Article 16(2), Article 83 of the Entrepreneurial Code), and the aims of regulation are listed in Article 108(3) of the Code: protection of human life and health, the environment and property, and safeguarding national security and public order.

A licence, under Article 1(6), is a first-category permit issued by a licensor to an individual or a legal entity, and also to a branch of a foreign legal entity whose business is the provision of financial services. Licensing (Article 1(10)) covers the issue and re-issue of a licence and of annexes to it, the issue of duplicates, permit control, and the suspension, resumption and termination of the licence. Within one licensed type of activity there are sub-types (Article 1(9)): the pharmaceutical licence (entry 16 of Annex 1), for example, has six sub-types and the educational licence (entry 3) nine, and the specific sub-types, objects and addresses are recorded in the annex to the licence, which forms an integral part of it (Article 24).

A second-category permit is any other confirmation of the right to carry on an activity or an action, issued by a permit-issuing body through a permit procedure (Article 1(15), (19)). It is subject not to qualification requirements but to permit requirements — quantitative and qualitative standards checked both on issue and throughout the period of validity (Article 1(20)). The procedure for issuing second-category permits, the grounds for refusal and re-issue are governed by sectoral laws and subordinate acts (Articles 38–42) rather than by the single procedure of Chapter 5, which is why the antimonopoly authority’s consent to economic concentration and the permit to attract foreign labour follow different rules although both sit in Annex 2.

A notification (Article 1(28)) is a document drawn up by the applicant in the form approved by the authorised body, the National Bank or the Agency for Regulation and Development of the Financial Market, informing a state body of the commencement or termination of an activity. The notification procedure (Article 1(29)) is the duty to notify before starting; a notification does not require the state’s consent.

The permit classes (Article 23) describe what exactly the document is issued for and directly affect its transferability. Class 1 — permits for an activity; class 2 — for objects; class 3 — one-off; class 4 — for activities with limited resources or under quotas; class 5 — for the professional activity of individuals; class 6 — for products. Under the general rule of Article 29(8) licences are non-transferable, and the sole exception is class 2 object licences for which Annex 1 expressly allows transfer: thus the licence for the storage and retail sale of alcoholic products (entry 43 of Annex 1) is marked “Transferable; class 2” and is re-issued to the purchaser of the object together with the object without a fresh check of qualification requirements (Article 1(11), Article 33(1)(5)), whereas the licence for the wholesale sale of alcohol (entry 42) belongs to class 1 and is non-transferable.

The notes to the entries in Annexes 1 and 2 are part of the rule, not reference information. Article 22(2) provides that it is in the notes that the transferability of a licence, the applicability of competitive or collegial procedures, the term of the permit and the non-application of the “silence is consent” rule (Article 25(3) first part and Article 26(1)–(2)) are stated. Permits are valid throughout the territory of Kazakhstan unless laws provide otherwise (Article 22(3)), and are issued on equal grounds and equal terms to all persons meeting the requirements (Article 22(1)).

What is licensed in Kazakhstan: 29 spheres and 81 entries of Annex 1

Article 28(1) of Law No. 202-V names 29 spheres in which licensing is permitted, and Annex 1 breaks them down into specific types and sub-types. The spheres are listed in the article itself: 1) television and radio broadcasting; 2) historical and cultural heritage; 3) education; 4) architecture, urban planning and construction; 5) hydrocarbons; 6) industry; 7) digitalisation and communications; 8) narcotic drugs, psychotropic substances and precursors; 9) healthcare; 10) nuclear energy; 11) cybersecurity; 12) special technical means for operational-search activities; 13) armaments, military equipment, weapons and explosives; 14) poisonous substances; 15) state symbols; 16) ethyl alcohol, alcoholic products and tobacco products; 17) commodity exchanges; 18) export and import; 19) the financial sphere and the concentration of financial resources; 20) outer space; 21) gambling; 22) veterinary matters; 23) agriculture; 24) transport; 25) forensic expert activity; 26) services to individuals and legal entities; 27) digital assets; 28) special social services; 29) the electricity industry — the last sphere was added by the Law of 24 June 2026 No. 322-VIII from 1 September 2026.

On the consolidated text as at 9 September 2026 Annex 1 contains 98 numbered entries, of which 17 have been excluded — 81 entries remain in force. Each entry is a separate licence with its own set of sub-types and a note on transferability, term and class. The entries of most interest to foreign business fall into the following groups. The construction block is entries 4, 5 and 6: survey, design and construction and installation works, each with its own set of sub-types; from 1 July 2026 the specifics of these licences are also determined by the Construction Code of the RK No. 253-VIII of 9 January 2026, a reference to which was inserted into Article 36 by Law No. 254-VIII: Article 55 of the Code divides designers and contractors into categories I, II and III by the responsibility level of the facilities, the licensor assigns the category on issuing the licence, and the applicant must have certified specialists on its staff. Healthcare is entry 15 (medical activity) and entry 16 (pharmaceutical activity, six sub-types). Education is entry 3 with nine sub-types, where licences for higher and postgraduate education are issued for 5 years, and the effect of columns 3 and 4 of item 9 (educational and health-improvement services) of entry 3 was suspended until 1 April 2026 under Article 53(1-1). Communications and digital technology are entry 12 (communications services: telephone services, data transmission, cellular, trunked radio, international IP telephony and satellite communications — in the wording of Law No. 320-VIII from 20 August 2026) and entry 12-1 (digital mining, 3-year term, “silence is consent” not applicable).

The financial block occupies entries 53–65 and, after the 2026 reform, looks different from any commentary of earlier years. Entry 53 in the wording of the Law of 16 January 2026 No. 259-VIII is headed “Licence (basic, universal) for banking and other operations” and lists 24 banking operations; entry 62-1 is microfinance activity; from 21 October 2026 the Law of 23 July 2026 No. 352-VIII will add entry 61-1 — the National Bank’s licence to first-category payment organisations for payment services, the opening and maintenance of bank accounts of legal entities and transfer operations, with an express exclusion of the competitive procedure and of the “silence is consent” rule. The separate National Bank and AIFC licences for digital asset activities are described in the article on digital assets and mining in Kazakhstan 2026.

The excisable and “dangerous” block is the most expensive in fees and the strictest in requirements. Entries 41–45 are the production of alcoholic products, wholesale sale (class 1), storage and retail sale (class 2, transferable), the production of ethyl alcohol and of tobacco products; entries 67–70 are gambling (slot-machine hall, casino, totalisator, bookmaker — all for 10 years, and the casino and slot-machine hall licences belong to class 2, that is they are issued for an object); entries 17–26 are nuclear energy (in the wording of Law No. 336-VIII the licence for the life-cycle stages of nuclear installations is issued for 10 years and the licence for radioactive waste management for 5 years); entries 30–37 are weapons, explosives and pyrotechnics; entry 13 is narcotic drugs; entry 38 poisons; entry 39 pesticides. The professional and services block comprises advocates (78), notaries (79), audit (80), private enforcement agents (81), forensic experts (77), security activity (86, two sub-types), tour operators (87: outbound tourism and inbound with domestic), disinfection, disinsection and deratisation (87-1), special social services (88), as well as veterinary activity and grain receipts (71–73), bus transport (75), rail freight (76), environmental protection (84), export and import of specific goods (49, 49-1, 51) and space activity (66). The audit licence and the accreditation of audit organisations are examined in the article on mandatory audit and financial reporting in Kazakhstan.

No licence is required by the persons listed in Article 28(2), even in licensed spheres. These are state bodies; autonomous education organisations and their organisations, including foreign ones; branches of foreign universities and foreign educational organisations under the Law on Education; the Development Bank of Kazakhstan; in the financial sphere — the central depository, the single operator for the accounting of state property, the credit bureau with state participation, mutual insurance societies, the payment gateway operator, the Unified Accumulative Pension Fund, the National Postal Operator, the joint-stock company of the National Bank managing the gold and foreign-currency assets, the National Fund, pension assets and the National Strategic Crypto Reserve (a paragraph added by Law No. 259-VIII); the authorised organisation for the state defence order; the Export Credit Agency of Kazakhstan; healthcare entities on a Government list during a state of emergency or a pandemic. From 21 October 2026 they will be joined by the stock exchange when organising trading in assets other than financial instruments and by the clearing organisation when clearing transactions in such assets.

Which actions require a second-category permit: the 226 entries of Annex 2

Annex 2 is the largest and most heterogeneous list in the Law: 448 numbered entries, of which 222 have been excluded over twelve years of deregulation, leaving 226 entries in force as at 9 September 2026. Unlike licences, second-category permits are not grouped by the 29 spheres of Article 28: they attach to specific actions — approvals, entries in registers, admissions, special permits — and are issued by dozens of different bodies under the rules of sectoral laws (Articles 38–42). That is why one and the same business may hold no licence at all yet need three or four second-category permits.

Several groups of Annex 2 matter in practice to a foreign investor. The first is antimonopoly consents: entries 4–8 establish the consent of the Agency for Protection and Development of Competition to economic concentration, that is to the acquisition of shares, assets and management rights above the statutory thresholds. The second is labour migration: entries 328–330 are the issue, extension and re-issue of the permit to attract foreign labour by local executive bodies, and entry 331 the certificate of conformity of qualifications enabling a foreign worker to seek employment independently; the fee for them is set by the Government under Article 616(6) of the Tax Code, and the full analysis of the quota, categories and rates is given in the article on the permit to attract foreign labour in 2026. The third is customs registers (entries 52, 53 and 55–57; entry 54 is excluded): inclusion in the registers of customs carriers, customs representatives, owners of temporary storage warehouses, customs warehouses and duty-free shops, without which the logistics activity described in the article on importing into Kazakhstan from third countries is impossible.

The fourth group is construction and land. Entry 128 is the change of designated use of a land plot; entry 140 the architectural and planning assignment; entry 327 special water use; entry 47 the environmental permit for impact, entry 49 the integrated environmental permit. The fifth is the financial market: entries 68 and 69 are the permits to open a bank and an insurance organisation; entries 242–251 are the permits of the Agency for Regulation and Development of the Financial Market for a bank to establish or acquire a subsidiary and to hold a significant participation in capital, for the voluntary liquidation of an insurance organisation and for other corporate actions of banks and insurers; entry 59 is the accreditation of a professional audit organisation; entries 84-3 and 84-4 are the registers of operators of digital financial asset platforms and digital asset trading platforms that have passed record registration with the National Bank; entry 84-1 is the record registration of payment organisations, which from 21 October 2026, in the wording of Law No. 352-VIII, becomes the register of second-category payment organisations. The sixth is transport and metrology: entries 12–14 (the certificate of admission of a vehicle to the carriage of dangerous goods in international traffic, the special permit for the carriage of dangerous goods of classes 1, 6 and 7, the international weighing certificate), entry 173 (registration of a measurement procedure in the register of the State Measurement System), entry 183 (the special permit for the passage of heavy and oversized vehicles, the fee for which is computed under Article 616(3) of the Tax Code per tonne and kilometre). The seventh is tax and housing control: entry 239 — the tax authority’s permit to break the seal of a cash register, and entry 87-10 — the local executive body’s permit to raise money from shared-construction participants.

The deregulation of Annex 2 continues in 2026. Entry 20 was excluded by the Law of 12 February 2026 No. 263-VIII, entry 87-13 by the Law of 16 January 2026 No. 259-VIII, and entry 279 by the Law of 6 April 2024 No. 71-VIII; deferred amendments were made by the laws of 9 January 2026 No. 254-VIII (from 1 July 2028), 24 June 2026 No. 326-VIII and 23 July 2026 No. 352-VIII. Abolition of a permit requirement under Article 18(6) of the Law and Article 109(6) of the Entrepreneurial Code takes place by exclusion of the entry from the annex and automatically confers the right to operate without the permit, so before filing an application it is worth checking whether the relevant entry is marked “Excluded”.

Second-category permits, like licences, are subject to the general rules of Chapters 4, 7, 9 and 10 of the Law. The 2-working-day completeness check and the approval procedure of Article 25, the “silence is consent” rule of Article 26 (unless a note in Annex 2 switches it off), the classes of Article 23, electronic issue under Article 48, suspension and revocation under Article 45 and permit control under Article 51 all apply to them. The difference is that the issue periods, the list of documents and the grounds for refusal for each second-category permit are set by the sectoral law and by rules approved by the regulating body in agreement with the Ministry of National Economy (Article 12(1)(2-1) and (4)), and the licence fee of the Tax Code does not extend to second-category permits: Article 612 provides separate, self-standing fees for some of them — for the passage of motor vehicles and for the issue or extension of the permit to attract foreign labour.

What is notified: the 65 notifications of Annex 3 and the immediate-start rule

Annex 3 to Law No. 202-V contains the exhaustive list of notifications: 76 numbered items, of which 11 have been excluded (items 19, 20, 23, 25, 29, 44, 45, 47, 50, 54 and 62) — 65 entries in force as at 9 September 2026.Article 46(1) expressly calls this list exhaustive, and Article 46(4) enshrines the defining feature of the regime: the applicant may start the activity immediately after sending the notification unless laws provide otherwise. There is no need to wait for a response from the state body, but responsibility for the accuracy of the information in the notification and the attached documents rests with the applicant (Article 46(5)).

The notifications that practically every company encounters are the fiscal and registration items. Item 39 is the notification of commencement of activity as an individual entrepreneur; item 13 is the notification of the applicable tax regime, through which one of the special tax regimes described in the article on Kazakhstan’s special tax regimes 2026 is chosen; item 40 is the notification of commencement or termination of activity by a taxpayer carrying on certain types of activity; item 41 is the notification of suspension of the filing of tax returns; item 67 is the notification of the processing of personal data, mandatory for operators of personal data databases under Law No. 94-V, discussed in more detail in the article on personal data and localisation in Kazakhstan; item 63 is the notification of the placement of a signboard; item 57 of the placement of outdoor (visual) advertising; item 35 is the notification by a person that is a subject of financial monitoring under the Law on Countering the Legalisation of Proceeds (real estate agents, accounting and legal firms, jewellers, leasing companies and others).

The second group is the sectoral notifications that have replaced former licences and permits. Construction and engineering: item 3 — commencement of construction and installation works; items 10, 11 and 11-1 — geodetic, cartographic and aerial survey works; item 48 — energy expertise; item 49 — energy audit. Trade and services: item 2 — wholesale supply of petroleum products; items 22 and 24 — wholesale and retail sale of medical devices; item 32 — travel agency activity (as distinct from tour operator activity, which is licensed under entry 87 of Annex 1); item 33 — guide, tour guide, tourism instructor; item 15 — taxi carrier; item 46 — bus terminals and bus stations; item 4 — installation and maintenance of security alarm systems; item 37 — communications services; item 56 — operation of radio-electronic equipment and high-frequency devices. Education: item 12 — pre-school upbringing and education; item 12-1 — additional education for children without educational and health-improvement services; items 43 and 43-1 — driver training. Healthcare and sanitation: item 21 — hygiene training; item 30 — a facility of minor epidemic significance; item 31 — sanitary and epidemiological audit; item 44-1 — non-interventional clinical studies. Agriculture: items 5, 6, 7, 26, 42, 42-1, 42-2, 42-3 and 58 — pedigree livestock breeding, seed expertise, crop approbation, veterinary activity, breeding of animals listed in the CITES appendices, harvesting of wild plants, plant introduction, plant genetic resources under the Nagoya Protocol, issue of veterinary certificates. Environment and resources: item 1 — marine scientific research; item 9 — a zoological collection; item 59 — meteorological monitoring; item 60 — collection, sorting and transportation of waste; item 61 — the declaration of environmental impact; item 8 — transactions with electricity and heat-supply facilities.

The third group is the notifications of professional and financial participants. Item 14 — an exchange office of an authorised bank; item 53 — approval of financial products by a financial organisation or a branch of a non-resident bank; item 36 — a self-regulatory organisation; item 55 — notarial activity; item 52 — an administrator in rehabilitation and bankruptcy procedures (interim, rehabilitation and bankruptcy manager), item 52-1 — a financial manager, whose roles are described in the article on bankruptcy and rehabilitation of legal entities; item 65 — management of a condominium; item 33-1 — import and export of refined precious metals, precious stones and jewellery; item 28 — issue by foreign organisations of foreign-format conformity documents; item 34 — training of maritime transport specialists; items 16, 17, 18 and 27 — tachographs, boatmaster courses, special training of dangerous-goods drivers; items 20-1 and 51 — notifications by natural monopoly entities; item 38 — distribution of erotic publications; item 66 — the notification of the commissioning of data centres, introduced by the Law of 19 June 2026 No. 320-VIII from 20 August 2026.

Item 66 calls for a separate caveat, because in 2026 the legislature adopted two different notifications under that number. The Law of 9 January 2026 No. 256-VIII (Article 1, paragraph 82, sub-paragraph 11)) supplemented Annex 3 with item 66 “Notification of commencement or termination of the activity of a platform for the exchange and circulation of digital data products”, while the Law of 19 June 2026 No. 320-VIII (Article 1, paragraph 13, sub-paragraph 2)) added item 66 “Notification of the commissioning of data centres”. The consolidated text in the Adilet legal information system as at 9 September 2026 shows in item 66 only the wording of Law No. 320-VIII, the item on the notification by a digital data products platform is not displayed in the list, and item 64 is absent from the list altogether. Operators of data platforms should request an opinion from the regulating body under Article 12(1)(7) of the Law before relying on the consolidated text.

What falls outside Law No. 202-V: the exclusions of Article 3, the AIFC and adjacent registrations

Not every document that a business must obtain from the state is a permit under Law No. 202-V. Article 3(1) extends the Law only to permits and notifications that simultaneously show all the features: they must be obtained before the activity starts; activity without them entails criminal or administrative liability; they are issued by authorised state bodies; the obligation rests on private business entities, on individuals acquiring the right to a regulated professional activity and on other persons who need the same permits; the issuing body may check compliance with the requirements and refuse; and the permit is not a basis for obtaining benefits.

Article 3(2) removes twelve groups of procedures from the Law (sub-paragraphs 1)–11) with an additional sub-paragraph 7-1)), each governed by its own act. These are permit documents in the field of technical regulation not included in Annexes 1 and 2; state registration of legal entities and record registration of branches and representative offices (governed by the Law on State Registration of Legal Entities, with the fee under Article 615 of the Tax Code); registration of currency contracts and notifications of currency transactions under the Law on Currency Regulation and Currency Control — their regime is examined in the article on currency control in Kazakhstan 2026; state registration of securities issues; notifications by issuers and financial organisations to the Agency for Regulation and Development of the Financial Market; permits under the Law on the State Border not included in Annex 2; actions in respect of the tariffs of natural monopoly entities; the acquisition of unused armaments by foreign legal entities holding a permit of the state of registration; permits in the field of state secrets; flight-safety permits issued by the authorised organisation in civil aviation; the special regulatory regime — the regulatory sandbox — under the laws on the financial market and on the National Bank; and balance-of-payments protection measures under currency legislation.

The Astana International Financial Centre lives in its own permit system. AIFC participants obtain licences and are registered with the Astana Financial Services Authority (AFSA) under the acts of the Centre adopted on the basis of Constitutional Law No. 438-V of 7 December 2015, not under the annexes to Law No. 202-V; the choice between the Centre’s jurisdiction and an ordinary Kazakh company is analysed in the article “AIFC or LLP: choosing a jurisdiction inside Kazakhstan”. The Tax Code nonetheless touches Centre participants through fees: Article 616(7) sets a fee of 7,000 MRP (30,275,000 tenge) for the document confirming the residency of an AIFC investment resident, and treats it as a “permit document” solely for the purposes of Chapter 69.

There are mandatory registrations that are neither permits nor notifications but without which an activity is practically impossible. The most conspicuous example of 2026 is the registration of goods in the National Catalogue of Goods: according to the Dentons alert of 9 December 2025, from 1 January 2026 all trading entities, manufacturers and importers must register goods in the catalogue and obtain an identification code, without which the issue of electronic invoices is restricted, and selling through a cash register without the code entails a warning and, on repetition, a fine of 20, 30 or 40 MRP depending on the category of the entity. This regime is established by the Law on the Regulation of Trading Activity and the catalogue rules, not by Law No. 202-V, so neither Article 26 on “silence is consent” nor Article 463 of the Code of Administrative Offences applies to it. VAT registration, record registration with the state revenue authorities and registration in the Unified Register of Employment Contracts are structured in the same way: they are obligations arising from the Tax and Labour Codes, not permit procedures.

The practical conclusion: “permit” in Law No. 202-V is a term with closed content. If a document is not in Annexes 1 or 2, neither the time limits of Article 30, nor the rule of Article 26, nor the licence fee, nor the sanctions of Articles 463–464 of the Code of Administrative Offences can be applied to it; and if it is, the sectoral body cannot demand it in a manner different from that established by the Law and cannot introduce a new requirement earlier than 60 calendar days after publication of the relevant act (Article 18(4) of the Law, Article 109(4) of the Entrepreneurial Code).

How to obtain a licence in Kazakhstan: documents, time limits, the fee, refusal and “silence is consent”

The licensing procedure is set out in Chapter 5 of the Law and consists of four successive stages: filing the application, the completeness check, the check of compliance with qualification requirements together with any approvals, and issue or a reasoned refusal. Licensing and the sending of notifications are carried out only in electronic form through the state digital system of permits and notifications (Article 112(1) of the Entrepreneurial Code, Article 48 of the Law): in practice that is the elicense.kz portal, integrated with egov.kz, where services are grouped into 18 categories — from security and natural monopolies to labour migration and finance. Applications are also accepted through the State Corporation “Government for Citizens” regardless of the applicant’s location, except in the financial sphere; an electronic application is registered within 1 working day (Article 48). Article 48(7), in the wording of Law No. 256-VIII, provides for an automated mode of checking and issue for particular permits on a list determined by the authorised body for digitalisation on the basis of an act of the permit-issuing body.

The list of documents for a licence is closed by Article 29(3) and became shorter after July 2026. The applicant submits: an application; a copy of the charter — only for the financial sphere, the circulation of weapons, narcotic drugs and security activity; a document confirming payment of the licence fee, except where payment is made through the “digital government” payment gateway; and documents confirming compliance with the qualification requirements. Sub-paragraphs 3) and 4) of paragraph 3 were excluded by Law No. 256-VIII, and Article 29(4) prohibits demanding documents whose data are available to the licensor in state digital systems. A foreign legal entity, a branch of a foreign financial organisation, a foreign national or a stateless person who lack Kazakh documents submit other documents containing equivalent information. Licences are issued at the licensor’s location; where the licensor is a local executive body, at the place of registration of the applicant, and object licences at the place of activity; to a foreign legal entity without a branch — at the place where it carries on the activity (Article 29(1)–(2)).

The time limits are set by Article 30 and Article 25. The licensor checks the completeness of the documents within 2 working days and, if they are incomplete, gives a reasoned refusal to consider them further (Article 25(1)); that paragraph carries a proviso: it does not apply to the issue of a permit that is a state service — and under Article 17(7) the issue of any licence is one — so for licences the completeness-check period is governed by the legislation on state services. Where the issue requires the approval of another state body, the request is sent within 2 working days and the approving body replies within 10 working days; the absence of a reply within that period means approval (Article 25(3)), unless the annex carries a note to the contrary. The licence or a reasoned refusal is issued no later than 15 working days(Article 30(1)); 30 working days from the day the application with documents is filed apply in the financial sphere and activities connected with the concentration of financial resources, in education, in the hydrocarbons sphere and in the use of nuclear energy (Article 30(2)), and for the nuclear sphere Law No. 336-VIII carved out a separate paragraph 4 from September 2026: the licence for works at the life-cycle stages of facilities is issued only after the result of the safety-case expertise has been received. Licences for the export and import of specific goods are issued no later than 30 working days under Article 37(2); export and import licences are general, exclusive or one-off (Article 37(5)), a one-off and a general licence run for no more than 1 year (paragraph 7), and for specific goods only one-off licences are issued.

The “silence is consent” rule of Article 26 is not a declaration but a mechanism with a documentary trail. If the licensor has issued neither a licence nor a refusal within the time limit, the licence is deemed issued from the date the time limit expired and is simultaneously entered in the state digital register; the licensor must issue the document within 5 working days after the expiry, and if it fails to do so the licence is deemed received, and the lawfulness of the activity until the document is received is confirmed by the document of acceptance of the application issued by the licensor or the State Corporation at the moment of acceptance, or by the electronic document certified by the electronic digital signature of the authorised official. Article 26(3) switches the rule off wherever Annexes 1 and 2 carry a note; in Annex 1 such a note attaches to 32 entries: all 17 financial licences (entries 53–65 with sub-entries, including Islamic insurance and microfinance), the operation of mining and chemical production facilities (entry 9), digital mining (12-1), the circulation of narcotic drugs (13), seven nuclear-sphere entries (17, 18, 21–24, 26), weapons, pyrotechnics, explosives and the disposal of munitions (30, 33, 35, 37), poisons (38), and from 21 October 2026 the licence of a first-category payment organisation (61-1).

A licence can be refused only on the grounds in Article 32(1). There are seven: the type of activity is prohibited by law for that category of persons; the licence fee has not been paid; the applicant does not meet the qualification requirements; a negative reply has been received from the approving body; there is a court decision in force suspending or prohibiting the applicant’s activity; the court has imposed a temporary ban on issuing a licence to a debtor on the submission of the enforcement agent; and false documents or information have been submitted. For the financial sphere additional grounds are set by the laws on the National Bank and on the financial market, and for specific goods by the Law on Control of Specific Goods. A refusal is issued within the same time limits as a licence (Article 32(3)) and may be appealed under Article 110(2)(2) of the Entrepreneurial Code. The licence fee under Article 31 of the Law is charged on the issue and re-issue of a licence and of a duplicate at the rates of the Tax Code; no fee is charged for an annex to a licence (except sub-types in the hydrocarbons sphere) or for the correction of errors under Article 44. Under Article 614(1) of the Tax Code the fee is paid at the payer’s location before the documents are filed or before the permit document is received, and the rate is a multiple of the MRP in force on the date of payment (Article 616(1)).

How much does a licence cost in Kazakhstan in 2026: numeric table of fees, time limits and fines

All the monetary and time parameters of the regime are expressed in two units — the monthly calculation index and working days — and in 2026 the MRP equals 4,325 tenge under Article 9 of the Law on the Republican Budget for 2026–2028 No. 239-VIII of 8 December 2025. The licence fee rates are set by Article 616(4) of Tax Code No. 214-VIII as multiples of the MRP on the date of payment; the table below gives the rates for the entries businesses most often apply for, with the conversion into tenge.

Three conclusions from the table. First: for the overwhelming majority of “ordinary” licences — construction, medicine, education, audit, tourism — the fee is nominal (43,250 tenge), and the main cost of entry lies not in the fee but in proving the qualification requirements: staff, equipment, premises, experience. Second: in the excisable and financial spheres the real price of a mistake is the fee itself: an alcohol producer pays 12,975,000 tenge, a casino 16,629,625 tenge, a bank 3,460,000 tenge for each banking operation in its licence, so an error in the list of operations or in the address of an object that requires a new licence instead of a re-issue costs a large fraction of those sums. Third: the administrative fine under Article 463 of the Code of Administrative Offences is in 2026 comparable to the fee itself, but is supplemented by confiscation of the income earned without a licence — and it is that confiscation, not the fine, that makes working “until the licence arrives” economically senseless.

Licence, second-category permit or notification: comparative table of the three regimes

The three regimes of Law No. 202-V differ not only in the level of danger but in their entire mechanics — from who approves the requirements to what happens when the authority stays silent. The table brings the differences together on the criteria that determine a project’s budget and launch timeline.

The main difference for planning is not the fee but the moment from which the activity becomes lawful. For a notification it is the moment the form is sent; for a licence and a second-category permit it is the moment the document is issued or the date from which it is deemed issued under Article 26; for an activity whose permit requirement has been introduced for the first time, Article 18(5) of the Law allows operation without a permit after the application is filed and until issue or refusal, except in the financial sphere. The second line of difference is transferability: a notification and a second-category permit are tied to the applicant, a licence is as a rule non-transferable, and only an object licence marked “transferable” passes with the object, which is critical when buying a shop holding a licence for the retail sale of alcoholic products.

The life cycle of a permit: re-issue, suspension, revocation and termination

A licence in Kazakhstan is as a rule unlimited in time, but its validity depends on four events, each with its own time limit and procedure. Article 1(12) defines a valid permit as a permit that has been issued, extended or re-issued and whose effect has not been suspended or terminated; it is the holding of a valid permit, not the fact of having once obtained one, that Article 108(1) of the Entrepreneurial Code requires.

Re-issue (Article 33) is required in seven cases. These are a change of name of an individual licensee; the re-registration, change of name or of legal address of an individual entrepreneur; the reorganisation of a legal entity under Article 34; a change of name or location of a legal entity, where the address is stated in the licence; the transfer of an object licence together with the object where Annex 1 allows transfer; a change of the object’s address without physical relocation; and other requirements of laws. Changes of address caused by the renaming of settlements and streets do not require re-issue and are entered through the integration of digital systems; on the first two grounds, from July 2026, re-issue is possible through a proactive service without an application — the day of the consent to the service counts as the day of application. The application is filed within 30 calendar days of the change (paragraph 4), the licensor does not check the qualification requirements, save for spin-off and division under Article 34, and re-issues the licence within 3 working days (paragraph 8); the fee for re-issue is 10 % of the issue rate. On reorganisation by merger, transformation or accession the licence is re-issued without a qualification check, whereas on spin-off or division it is re-issued to only one of the resulting entities and only after confirmation of compliance with the requirements, with an application within 30 calendar days and a period of 15 working days (30 in the nuclear, financial and educational spheres, for specific goods and hydrocarbons).

Suspension and revocation (Article 45) is a two-stage mechanism in which the Law gives the licensee two opportunities to put things right. Suspension is carried out on the grounds and in the manner established by laws — above all under Article 464 of the Code of Administrative Offences, whose sanction provides for the suspension of a licence or second-category permit; since 2026 paragraph 2-1 expressly states the purpose of suspension: removal of the causes and conditions of the breach. Before the suspension period expires the licensee may file an application on the removal of the breaches with copies of supporting documents; the permit-issuing body checks them within 10 working days by way of permit control and, on confirmation, resumes the permit from the date of its decision (paragraph 3). If no application is filed, the body initiates revocation within 10 working days after the suspension period expires, but even during that procedure the licensee may prove that the breaches have been removed (paragraph 4). A separate tool is voluntary suspension under paragraph 1-1: the licensee itself applies to the body, from that moment the obligations to pay the annual licence fee or payment provided for by laws cease, and resumption is effected on application within 3 working days (paragraphs 6–8).

Termination of a licence (Article 35) occurs on eight grounds. Expiry of the term; full performance of the actions for which a one-off licence was issued; revocation; cessation of an individual’s activity, liquidation of a legal entity or closure of the branch of a financial organisation; the licensee’s voluntary application; exclusion of the type of activity from Annex 1; exclusion of the licensee from the circle of persons subject to licensing; and other cases under laws. The licensee returns a paper licence within 10 working days unless it exists only in electronic form (paragraph 2), and from the moment of termination may not carry on the activity, except where the type of activity has been excluded from the annex or the licensee from the circle of obliged persons (paragraph 3). Paragraph 5, inserted by Law No. 259-VIII, prohibits terminating a licence before the National Bank has completed its inspection and taken decisions on the breaches found. Termination of a licence on the liquidation of a company is one of the steps described in the article on liquidating an LLP in Kazakhstan in 2026.

Duplicates, errors and the register. A duplicate permit is issued within 2 working days (Article 43); errors made by the permit-issuing body are corrected within 2 working days without a fee (Article 44); an extract from the state digital register of permits and notifications is provided within 3 working days (Article 47). Under Article 49 the register serves as the basis for risk assessment and inspection schedules, and permit control under Article 51 is conducted in the form of an inspection under the Entrepreneurial Code (in the financial sphere under the Law on State Regulation of the Financial Market, in industrial safety under the Law on Civil Protection) and, where the applicant is visited, ends with a conclusion on compliance or non-compliance (paragraph 2-1); the current wording of Article 51 has applied since 1 January 2026 under the Law of 24 June 2025 No. 196-VIII. Article 52(5) (in the wording of the Law of 17 November 2025 No. 231-VIII) sets a transitional rule for the cybersecurity sphere: licences issued without a time limit for the detection of technical channels of information leakage and special technical means, for activity in the sphere of special technical means for operational-search activities and for the development of cryptographic information protection tools are subject to re-issue as fixed-term licences (5 and 3 years under entries 27–29 of Annex 1) within six months starting from 1 January 2026.

The notification procedure in detail: how to send a notification and what must not be forgotten afterwards

The notification procedure is the duty to notify a state body before starting an activity in the manner established by the Law (Article 1(29)), and Article 46 describes it in full in seven paragraphs. The notification is sent to the state body receiving notifications through the state digital system of permits and notifications, and also on other digital objects in accordance with legislation (paragraph 2). The forms of notifications, the rules for their receipt and the list of receiving bodies are approved by the authorised body for permits and notifications (Article 11(4)), and for the financial sphere by the National Bank and the Agency for Regulation and Development of the Financial Market (Article 12(2)).

A notification is a declaration, not an application. Article 46(3) provides that by submitting the form of information applicants declare their compliance with the requirements that legal acts impose on the activity; paragraph 5 allows laws to require documents to be attached but prohibits demanding documents and information that can be obtained from state digital resources. The state body does not approve the notification and does not issue a permit: it receives the information, enters it in the register and later checks compliance with the requirements by way of permit control (Article 1(1-2), Article 51). Responsibility for accuracy rests with the applicant, and it is this paragraph that turns the notification from a formality into a legally significant representation: an inaccurate declaration of compliance entails, on a subsequent inspection, the consequences set by the sectoral laws, and the non-compliance itself the measures that follow permit control.

The moment the activity may start is set by Article 46(4): the applicant may start, or must stop, the activity immediately after sending the notification unless laws provide otherwise. The second part of paragraph 4 allows laws to set time limits for sending a notification with regard to the specifics of the activity — the notification of commencement of construction and installation works (item 3 of Annex 3), for instance, is sent under construction legislation before the works begin, and the notification of a change of data within 10 working days under Article 46(7). Paragraph 7 requires notification of a change of the legal address of an individual, the location of a legal entity, the address where the activity is carried on and the registration data that must be completed in the form — and it is this rule that companies most often breach after moving to another office or changing their director.

Article 46(6) protects existing licensees on deregulation. If a notification procedure is introduced for a particular type of activity in place of a permit procedure, persons who held a valid permit at that moment are deemed to have sent a notification and are automatically entered in the state digital register; no repeat notification is needed. The reverse situation — the introduction of a permit requirement for an activity previously carried on under a notification — is governed by Article 18(3)–(5): the duty to obtain a permit arises from the date the legal act on the issuing procedure takes effect, such an act cannot take effect earlier than 60 calendar days after publication, and applicants who file no later than 5 working days before it takes effect may operate without a permit until the document is issued or refused.

Two notifications deserve separate attention because of their tax consequences. The notification of commencement of activity as an individual entrepreneur (item 39 of Annex 3) is at the same time the method of state registration of an individual entrepreneur: under Article 36 of the Entrepreneurial Code the individual submits the notification through the state digital system of permits and notifications, no other documents may be demanded, and the state revenue authority registers the entrepreneur within 1 working day; the choice of tax regime under item 13 of Annex 3 is linked to the same notification. The notification of the applicable tax regime determines whether a company or an entrepreneur works under the general regime or one of the special ones, and the right to a special regime depends on the timeliness and correctness of that notification — the mechanics of these regimes are analysed in the article on Kazakhstan’s tax system 2026. The note to Article 463 of the Code of Administrative Offences excludes from administrative liability only notifications of currency transactions and the record registration of currency contracts (which are in any case outside Law No. 202-V under Article 3(2)), and notifications under the Law on Natural Monopolies — items 20-1 and 51 of Annex 3; the other 63 notifications of Annex 3 are backed by a sanction.

Can foreign companies obtain licences and send notifications in Kazakhstan on the same footing as Kazakh companies?

Yes: Article 20(2) of Law No. 202-V and Article 110(3) of the Entrepreneurial Code provide that foreign nationals, stateless persons, kandas and foreign legal entities obtain permits and send notifications on an equal footing with citizens and legal entities of the Republic of Kazakhstan unless laws and international treaties provide otherwise.The proviso “unless laws provide otherwise” matters: sectoral laws impose restrictions in particular spheres — for example on foreign participation in broadcasting and in security activity — but Law No. 202-V itself does not limit national treatment, as the Baker McKenzie handbook “Doing Business in Kazakhstan 2026” confirms: “Generally, foreign entities are subject to the same licensing requirements as local entities”.

The key practical question is who exactly will be the licensee: the foreign company directly, its branch, or a Kazakh LLP. Article 1(6) allows a licence to be issued to a branch of a foreign legal entity in one case only — where its business is the provision of financial services (branches of non-resident banks, insurance organisations and insurance brokers — entries 53, 56, 58 and 59 of Annex 1). In all other spheres the licensee is an individual or a legal entity; Article 29(2)(2) expressly provides for the issue of a licence to a foreign legal entity that has no branch or representative office in Kazakhstan, at the place where it carries on the activity, and sub-paragraph 1) at the place of registration of the branch or representative office of a foreign legal entity where the licensor is a local executive body. Article 27 settles the question of payment: a foreign legal entity pays the licence fee itself using its own business identification number, or through its registered branch or representative office using their BIN and bank details. In practice most licensors and the digital system are geared to an applicant with a Kazakh BIN, so obtaining a licence by a foreign company without a presence in the country remains a rare scenario, and the standard route is to set up an LLP or register a branch; ready-made options are collected in the UPPERSETUP company registration catalogue. The differences between these forms for licensing, tax and employment purposes are examined in the article on a branch and representative office of a foreign company versus an LLP, and the incorporation procedure in the article on registering an LLP in Kazakhstan for foreigners.

The foreign applicant’s documents. Article 29(4) allows a foreign legal entity, a branch of a foreign financial organisation, a foreign national and a stateless person who lack the documents prescribed for Kazakh applicants to submit other documents containing equivalent information. The qualification requirements apply in full, and it is they, not the founder’s nationality, that become the barrier: requirements on the experience of specialists, on owning or leasing equipment and premises in Kazakhstan, on staff certification. Foreign specialists whom the company brings in to meet the qualification requirements additionally need a permit to attract foreign labour — a second-category permit under entries 328–331 of Annex 2 — or a ground for exemption under Government Resolution No. 1041, as described in detail in the article on the permit to attract foreign labour.

Three spheres where foreign status affects the regime directly. The first is finance: the basic and universal banking licences under entry 53 in the wording of Law No. 259-VIII are issued to banks and to branches of non-resident banks, the permit to open such a branch is a separate second-category permit under entry 68 of Annex 2, and the fee is 800 MRP for each banking operation. The second is digital assets and mining: the digital mining licence (entry 12-1) is issued for 3 years without the “silence is consent” rule, and operators of digital asset platforms pass record registration with the National Bank under entries 84-3 and 84-4 of Annex 2; the current rules are set out in the article on digital assets and mining. The third is special economic zones: the status of an SEZ participant gives tax and customs preferences but replaces neither a licence nor a notification, as discussed in the article on Kazakhstan’s SEZs and industrial zones. Opening an account to pay the fee and run the business is a separate procedure, described in the article on opening a bank account in Kazakhstan for a foreign company.

What liability arises for operating without a licence, a permit or a notification?

Liability is built in three tiers: an administrative fine with confiscation under Article 463 of the Code of Administrative Offences, sanctions for breaching the terms of an existing licence under Article 464, and criminal liability under Article 214 of the Criminal Code where the income or damage is large. The general rule is Article 50 of Law No. 202-V: a breach of the legislation on permits and notifications entails the liability established by laws.

Article 463 of the Code of Administrative Offences, “Engaging in entrepreneurial or other activity, and performing actions (operations), without the requisite registration, permit or notification”. Part 1 punishes activity without registration or a permit, and equally failure to send a notification where they are mandatory, with a fine on individuals of 15 MRP (64,875 tenge), on officials, small business entities and non-profit organisations of 25 MRP (108,125 tenge), on medium-sized business entities of 40 MRP (173,000 tenge), and on large business entities and branches of non-resident banks, insurance organisations and insurance brokers of 150 MRP (648,750 tenge), with or without confiscation of the objects and instruments of the offence. The crucial addition: activity without a licence additionally entails confiscation of the income (dividends), money and securities obtained as a result of the offence — no confiscation of income is provided for second-category permits and notifications. Part 2, for a repeat offence within a year, raises the fines to 30, 50, 80 and 500 MRP (2,162,500 tenge for large business) with mandatory confiscation. The note to the article removes from its scope notifications of currency transactions, the record registration of currency contracts and notifications under the Law on Natural Monopolies; the current wording of the article dates from the Law of 10 January 2025 No. 155-VIII.

Article 464 of the Code of Administrative Offences, “Breach of licensing rules or permit procedures” (heading in the wording of the Law of 17 November 2025 No. 232-VIII), applies to those who do hold a licence or permit. Part 1 — a breach of licensing rules or permit procedures, including non-compliance with permit requirements: a fine of 15 MRP on individuals, 45 MRP on officials, small business and non-profit organisations, 80 MRP on medium-sized business and 150 MRP on large business, with or without suspension of the licence or second-category permit. Part 2 — knowingly submitting false information when obtaining a licence or permit, a repeat breach within a year, and failure to remedy breaches of qualification or permit requirements after the suspension period has expired: a fine of 40, 100, 150 and 300 MRP (1,297,500 tenge for large business), with or without revocation of the licence or permit. It is the pairing “Article 464 of the Code of Administrative Offences — Article 45 of the Law” that forms the full cycle: the court suspends the licence, the licensee remedies the breaches and files an application, the body checks within 10 working days, and in the event of inaction initiates revocation.

Article 465 of the Code of Administrative Offences punishes the state itself. Breach of the time limit for issuing a permit entails a fine on officials of 20 MRP; issuing a permit in breach of the procedure or an unjustified refusal — 30 MRP; on repetition — 50 MRP. This provision is a procedural argument for the applicant alongside the right of appeal under Article 20(1)(2) of the Law and Article 110(2)(2) of the Entrepreneurial Code and the “silence is consent” rule.

Article 214 of the Criminal Code, “Illegal entrepreneurship”, in the wording of the Law of 16 July 2025 No. 210-VIII. Part 1: carrying on entrepreneurial activity without registration or without a licence mandatory for that activity, or in breach of the legislation on permits and notifications, and equally engaging in prohibited types of activity, where this has caused large damage to a citizen, an organisation or the state or is connected with the extraction of income on a large scale or with the production, storage, transportation or sale of excisable goods in significant quantities — a fine of up to 2,000 MRP (8,650,000 tenge), or correctional labour in the same amount, or community service of up to 600 hours, or restriction or deprivation of liberty for up to 2 years, with or without confiscation of property. Part 2 — the same act committed by a criminal group, connected with income on an especially large scale or committed repeatedly — up to 5,000 MRP or imprisonment for up to 5 years with confiscation. The thresholds are set by Article 3 of the Code: for Article 214 a large scale is income above 10,000 MRP (43,250,000 tenge), large damage is damage to a citizen above 2,000 MRP and to an organisation or the state above 10,000 MRP, an especially large scale is income above 20,000 MRP(86,500,000 tenge), and a significant quantity of excisable goods is above 2,000 MRP. The note to the article releases a person who has committed the act under part 1 for the first time from criminal liability upon voluntary compensation of the damage; the constitutionality of the note was confirmed by Normative Resolution of the Constitutional Court No. 31-NP of 3 October 2023. The same Law No. 210-VIII introduced Articles 214-1 (illegal banking and microfinance activity) and 214-2 (illegal debt-collection activity) with similar sanctions.

How these provisions work together. The wording “or in breach of the legislation on permits and notifications” in Article 214 of the Criminal Code means that the offence covers not only working without a licence but also, for example, operating under a suspended licence or without a mandatory notification, once income exceeds 43,250,000 tenge: for a trading company with a turnover of several hundred million tenge a year the threshold is reached within months. The administrative fine under Article 463 does not apply in that case (part 1 operates “if these actions do not contain the elements of a criminal offence”), but the sanction of Article 214 of the Criminal Code likewise provides for confiscation of property — optional under part 1, mandatory under part 2. For foreign business there is an additional reputational risk: information on the suspension and revocation of a licence is entered in the state digital register (Article 1(21)) and is available to any counterparty through the permit document search on elicense.kz.

What changed in 2025–2026 and what takes effect later

In the first nine months of 2026 fourteen laws touched Law No. 202-V, and the Tax Code that sets the price of a licence was replaced in its entirety. The table gathers the changes that affect business, with the exact dates of entry into force taken from the consolidated text in the Adilet legal information system and the official publication data.

The most important change of 2026 is financial, and it is hidden not in Law No. 202-V but in the Tax Code. The previous Code No. 120-VI of 25 December 2017, repealed from 1 January 2026 (except Article 68(1-1), which applies until 1 January 2027, and Article 26(23), until 1 January 2029), contained paragraph 1 of Chapter 69, “Payment for the use of licences for certain types of activity” (Articles 555–558): holders of licences for gambling and for the storage and wholesale or retail sale of alcoholic products paid an annual payment of 3,845 / 640 / 200 / 100 / 60 / 20 MRP in equal instalments no later than 25 March, 25 June, 25 September and 25 December, starting from the year following the year the licence was obtained. Code No. 214-VIII has no such paragraph, Article 201 does not list a payment for the use of licences among payments to the budget, and Article 612 defines fees as one-off payments. The abolition was announced as early as autumn 2024, at the presentation of the draft new Code, as part of the President’s instruction to cut the number of taxes and payments by 20 per cent, and the State Revenue Department for Abai Region, in an explanation reproduced by the Uchet.kz portal on 1 April 2026, confirms that the payment has been abolished and the licence fee is paid once, on obtaining the licence, to budget classification code 105402. At the same time the one-off fee for the retail sale of alcohol (100 / 70 / 30 MRP) has replaced the annual payment (100 / 60 / 20 MRP a year): for district towns, settlements and villages the nominal one-off rate is higher than the former annual one, but it is paid once, so from the second year of holding the licence the burden is lower.

Where the sources diverge: six discrepancies to know about

First — the “annual licence fee” in the Law itself. Article 35(4) and Article 45(6) and (8) of Law No. 202-V still speak of the cessation and resumption of obligations to pay “the annual licence fee or payment provided for by laws”, although Tax Code No. 214-VIII contains no annual payment. The provisions of the Law retain meaning only for cases in which other laws introduce such a payment; as at September 2026 the authors are aware of no such laws.

Second — item 66 of Annex 3. Laws No. 256-VIII and No. 320-VIII each supplemented Annex 3 with a different item under the same number 66; the consolidated text shows only the wording of Law No. 320-VIII (data centres). The notification by a platform for the exchange and circulation of digital data products has been legally introduced but is not visible in the list.

Third — the date of entry into force of laws “upon expiry of sixty calendar days”. The Adilet system dates the redactions under Law No. 320-VIII (published 20 June) as 20 August 2026, which corresponds to counting “day of publication plus 61 days”; by the same logic Law No. 336-VIII (published 8 July) applies from 7 September and Law No. 352-VIII (published 21 August) from 21 October 2026, whereas in the “History of amendments” the redactions under the July laws are dated 6 September. This article uses the dates on the Adilet formula; the one-day discrepancy matters only for an activity started on that day.

Fourth — the number of licensed types of activity. Commentaries give different figures because they count either the entries of Annex 1, or the sub-types, or the spheres of Article 28. This article uses the count on the consolidated text as at 9 September 2026: 29 spheres, 81 entries of Annex 1 in force, 226 entries of Annex 2, 65 items of Annex 3, and a single entry may contain anything from one sub-type to several dozen operations (entry 53 lists 24 banking operations).

Fifth — the Budget Code. The Budget Code No. 171-VIII of 15 March 2025, in force since 1 January 2026, still names the “payment for the use of licences for certain types of activity” among the revenues of the budgets of cities of republican significance and the capital (Article 24(25)) and of district budgets (Article 26(17)); according to the Adilet editorial note these sub-paragraphs are to be excluded by the Law of 14 July 2026 No. 350-VIII only from 1 January 2027. A line in the Budget Code creates no obligation to pay — the object, the payers and the rates of the payment could exist only in the Tax Code, where they are absent — but it explains why the payment still surfaces in 2026 in the budget classification and in some explanations.

Sixth — the licence issue period. The Baker McKenzie handbook “Doing Business in Kazakhstan 2026” speaks of 15 working days with an extension “up to 30 business days or longer in certain limited cases”; under the text of Article 30 in its September 2026 wording, 30 working days apply to four spheres (finance, education, hydrocarbons, nuclear energy), and “longer” only to licences for the life-cycle stages of nuclear energy facilities issued after the safety-case expertise and to specific goods under Article 37. Second-category permits are not covered by Article 30: their time limits are set by sectoral acts.

Step-by-step algorithm: how to identify the applicable regime and obtain a licence or permit, or send a notification

The algorithm has nine steps; the first four are taken before any documents are filed and determine whether a document is needed at all.

Step 1. Describe the activity in the Law’s own terms

Break the business model down into specific actions and operations — not “IT company” or “distribution” but “data transmission services”, “wholesale supply of petroleum products”, “retail sale of medical devices”. Law No. 202-V operates with precisely such wording in the annex entries, and a single company may simultaneously fall under a licence (communications services under entry 12, for example), a second-category permit (special water use under entry 327) and a notification (processing of personal data under item 67).

Step 2. Check the three annexes against the consolidated text

Open Annexes 1, 2 and 3 of the Law on adilet.zan.kz in the redaction current on the date of the check and find each operation from Step 1. Entries and items marked “Excluded” mean that the regime has been abolished (Article 18(6)); the notes to the entries determine the term, the class, transferability and whether “silence is consent” applies. If the operation is found nowhere, no permit is required by virtue of Article 17(6) of the Law and Article 108(4) of the Entrepreneurial Code.

Step 3. Check the exclusions of Article 3 and adjacent registrations

Make sure that the document in question is not in the list of Article 3(2) (registration of legal entities, currency contracts, securities, the regulatory sandbox) and is not a separate registration outside the Law (the National Catalogue of Goods, VAT registration, the register of employment contracts). Those procedures have their own time limits and sanctions.

Step 4. If in doubt, request an opinion from the regulating body

Article 12(1)(7) obliges the regulating state body to issue, on application, an opinion on whether a permit is or is not required for a specific activity. Such an opinion is documentary protection in a dispute with inspectors and with counterparties who demand a “licence” where none exists.

Step 5. Find the qualification requirements and the licensor

For a licence — find the regulating body’s order approving the qualification requirements and the list of supporting documents (Article 12(1)(1-1)) and the Government resolution on licensors (Article 10(2)); for a second-category permit — the sectoral body’s rules of the permit procedure; for a notification — the form and the rules of receipt approved by the Ministry of National Economy. This step reveals the real cost of entry: staff, specialists’ experience, premises, equipment, certificates.

Step 6. Put the applicant in place

Decide who files the application: an LLP, a branch (only in the financial sphere), an individual entrepreneur or a foreign legal entity at the place of activity — and obtain a business identification number, an electronic digital signature and an account from which to pay the fee. Foreign specialists engaged to meet the qualification requirements must hold a permit to attract foreign labour or a ground for exemption.

Step 7. Pay the fee and file the application

Compute the fee under Article 616(4) of the Tax Code at the MRP on the date of payment, pay it before filing or before receiving the permit document (Article 614(1)) — on payment through the “digital government” payment gateway no payment document is attached — and file the application with the documents under Article 29(3) through elicense.kz or the State Corporation. Keep the dated document of acceptance of the application: it confirms the lawfulness of the activity if the body is late under Article 26(2).

Step 8. Monitor the time limits

Count 15 working days (30 for the four spheres) for the issue of a licence and 10 working days for the approving body’s reply where approval is needed; for second-category permits, the periods of the sectoral act. Once the period has expired without a decision the licence is deemed issued (except entries with a note), and a breach of the time limit by an official is a 20 MRP fine under Article 465 of the Code of Administrative Offences. A refusal on the grounds of Article 32 may be appealed to the superior body and to court.

Step 9. Keep the permit valid

Enter in the calendar: 30 calendar days for the re-issue application after any change under Article 33(1); 10 working days for the notification of a change of data under Article 46(7); the licence term, where Annex 1 sets one; the reporting deadlines for export-import licences (quarterly, by the 15th). Check the status of the licence in the state digital register after every inspection, because suspension under Article 464 of the Code of Administrative Offences makes the activity unlawful from the date of the ruling. Support for these steps — from choosing the form of presence to obtaining the licence and permits — is part of UPPERSETUP’s legal services.

Typical mistakes and what they cost

Mistake 1. Starting work “while the application is being considered”

The right to operate without a permit before it is issued exists in one case only — Article 18(5): where a permit requirement is introduced for the first time and the application is filed before the rules take effect — and it does not apply in the financial sphere. In all other cases the activity is lawful from the date of issue or from the date on which the licence is deemed issued under Article 26.

Cost of the mistake: a fine under Article 463(1) of the Code of Administrative Offences — 108,125 tenge for small business, 173,000 tenge for medium-sized and 648,750 tenge for large business — and confiscation of all income earned without the licence. Once income exceeds 43,250,000 tenge the matter becomes criminal under Article 214 of the Criminal Code, with a fine of up to 8,650,000 tenge or imprisonment for up to 2 years.

Mistake 2. Treating the “term” and “class” notes as reference information

Under Article 22(2) the notes to the entries of Annexes 1 and 2 determine the term, transferability, the applicability of a competitive procedure and the switching-off of the “silence is consent” rule. The digital mining licence runs for 3 years, the higher education licence for 5, the licence for the life-cycle stages of nuclear installations for 10; on expiry the licence terminates automatically under Article 35(1)(1).

Cost of the mistake: working under a licence that has expired is treated as activity without a licence with all the consequences of Article 463 of the Code of Administrative Offences, and a new licence is paid for at the full rate — 8,650,000 tenge for a sub-type I miner — since expiry of the term is not among the grounds for re-issue under Article 33.

Mistake 3. Not re-issuing the licence after a change of address or name or the purchase of an object

Article 33(4) gives 30 calendar days for the re-issue application; on the transfer of an object licence together with the object the purchaser does not acquire the right to operate until the licence has been re-issued in its name.

Cost of the mistake: a mismatch between the licence data and the facts is detected during permit control and treated under Article 464(1) of the Code of Administrative Offences — up to 648,750 tenge with suspension of the licence, and on repetition up to 1,297,500 tenge with revocation. For a retail shop with an alcohol licence a month’s suspension means losing the revenue of the entire excisable range.

Mistake 4. Forgetting the notification of changes and the second-order notifications

Article 46(7) requires notification of a change of address, place of activity and mandatory registration data within 10 working days, and the Annex 3 list includes notifications that companies rarely associate with their business: the processing of personal data (item 67), the placement of a signboard (item 63), outdoor advertising (item 57), the status of a subject of financial monitoring (item 35).

Cost of the mistake: failure to send a notification is a self-standing offence under Article 463(1) of the Code of Administrative Offences with the same fines of 25 / 40 / 150 MRP, and a repeat within a year is 50 / 80 / 500 MRP with mandatory confiscation of the objects of the offence.

Mistake 5. Budgeting for an annual payment that no longer exists, or not budgeting for a fee that has grown

From 1 January 2026 Tax Code No. 214-VIII contains no annual payment for the use of licences; the one-off fee for the retail sale of alcohol in district towns and villages (70 and 30 MRP) is nominally higher than the former annual payment (60 and 20 MRP), and the MRP has risen to 4,325 tenge.

Cost of the mistake: in the financial model of a retail chain — an overpayment of 865,000 tenge a year for each wholesale object — a payment that is no longer due — or, conversely, an underestimate of the one-off fee on opening each new outlet — 432,500 tenge in a regional centre.

Mistake 6. Relying on “silence is consent” where it is switched off

Article 26(3) and the notes to 32 entries of Annex 1 switch the rule off for all financial licences, mining and chemical production facilities, digital mining, narcotic drugs, the nuclear sphere, weapons, explosives and poisons, and from 21 October 2026 for the licence of a first-category payment organisation.

Cost of the mistake: starting a financial activity on the strength of the body’s “silence” is treated under Article 214-1 of the Criminal Code (illegal banking and microfinance activity) once income exceeds 43,250,000 tenge, and below that threshold under Article 463 of the Code of Administrative Offences with confiscation of income.

Mistake 7. Applying for a licence in the name of a branch outside the financial sphere

Article 1(6) admits a branch of a foreign legal entity as a licensee only for financial services; in all other spheres the applicant must be the foreign legal entity itself, a Kazakh LLP or an individual entrepreneur.

Cost of the mistake: a rejected application after the fee has been paid and the qualification package prepared, the loss of 15–30 working days, the question of refund of the fee under the general Tax Code rules on offset and refund, and the need to register an LLP, which adds several weeks to the project launch.

Which regime suits whom, and when a professional check is needed

For whom a notification is enough

•          Service and trading companies with no excisable, financial or dangerous activity — individual entrepreneurs, travel agents, taxi carriers, distributors of medical devices, installers of security alarms: their obligations are limited to the notifications of Annex 3 and the notifications common to all on the tax regime, personal data and a signboard.

•          Companies starting construction of their own facility: the notification of commencement of construction and installation works under item 3 of Annex 3 is sent by the customer (Article 117(1)(5) of the Construction Code), whereas the licence under entry 6 of Annex 1 is needed by the contractor.

Who needs a licence

•          Contractors and designers — licences under entries 4–6 of Annex 1 with sub-types; fee 43,250 tenge, period 15 working days, the key barrier being the qualification requirements on engineering staff.

•          Medical, pharmaceutical, educational, audit and tour operator companies — licences under entries 15, 16, 3, 80 and 87; fee 43,250 tenge; for education a 5-year term for particular sub-types and 30 working days for issue.

•          Producers and sellers of alcohol and tobacco, gambling operators, miners — the licences with the highest fees (from 21,625 to 16,629,625 tenge) and special requirements on objects; for retail, a transferable class 2 object licence.

•          Financial organisations — licences of the National Bank and the Agency for Regulation and Development of the Financial Market under entries 53–65, with “silence is consent” switched off, 30 working days and a fee of up to 800 MRP per operation.

Who needs second-category permits

•          Investors acquiring Kazakh companies or assets — consent to economic concentration under entries 4–8 of Annex 2.

•          Employers of foreign specialists — the permit to attract foreign labour under entries 328–331.

•          Logistics and foreign-trade companies — inclusion in the customs registers under entries 52, 53 and 55–57.

•          Industrial and construction projects — environmental permits (entries 47, 49), change of designated use of land (128), the architectural and planning assignment (140), special water use (327).

When a professional check is needed

•          If the activity is described by several entries at once — communications services plus a data centre plus personal data processing, for instance: three regimes with different bodies.

•          If a business is bought together with its licence — only a transferable object licence passes; the others must be obtained afresh by the new licensee.

•          If the plan is to work in the financial sphere, with digital assets or with excisable goods — the switched-off “silence is consent” rule, separate refusal grounds and the criminal thresholds make the cost of a mistake incomparable with the cost of a check.

•          If the project starts between the date of publication and the date of entry into force of amendments — as with Law No. 352-VIII, in force from 21 October 2026, or the deferred amendments to the annexes from 1 January 2027.

Identifying the applicable regime, assembling the qualification package and taking a company through licensing or permit procedures is what the UPPERSETUP team in Kazakhstan does.

Frequently asked questions about permits and notifications in Kazakhstan

How do I find out whether my activity needs a licence in Kazakhstan?

Check the three annexes to Law No. 202-V “On Permits and Notifications” in the consolidated redaction on adilet.zan.kz: Annex 1 — licences (81 entries in force), Annex 2 — second-category permits (226 entries), Annex 3 — notifications (65 entries). The lists are exhaustive under Article 17(6) of the Law, so an activity named in none of them requires no permit; in case of doubt the regulating body must issue an opinion on whether a permit is or is not required under Article 12(1)(7).

How much does a licence cost in Kazakhstan in 2026?

The licence fee is set by Article 616(4) of Tax Code No. 214-VIII in MRP on the date of payment: for most types — construction, medicine, education, audit, tour operators — 10 MRP (43,250 tenge at an MRP of 4,325 tenge); communications services, advocates, notaries, security — 6 MRP (25,950 tenge); alcohol production — 3,000 MRP (12,975,000 tenge); a casino — 3,845 MRP (16,629,625 tenge); banking operations — 800 MRP each (3,460,000 tenge). The fee is paid once, before the documents are filed; no annual payment for the use of a licence has been charged since 1 January 2026.

How many days does it take to get a licence in Kazakhstan?

Under Article 30 of Law No. 202-V a licence or a reasoned refusal is issued no later than 15 working days, and in the financial sphere, education, hydrocarbons and nuclear energy within 30 working days; approval by another state body takes up to 10 working days. If the period expires without a decision, the licence is deemed issued under Article 26, except for entries with a note switching that rule off.

Can I start the activity immediately after submitting a notification?

Yes: Article 46(4) of Law No. 202-V gives the right to start the activity immediately after sending the notification through the state digital system of permits and notifications, unless laws provide otherwise. No consent of the state body is required, but the applicant is responsible for the accuracy of the information and must notify any change of address or registration data within 10 working days.

What is the fine for operating without a licence in Kazakhstan?

Article 463(1) of the Code of Administrative Offences: 15 MRP for individuals, 25 MRP for small business, 40 MRP for medium-sized and 150 MRP for large business (64,875 / 108,125 / 173,000 / 648,750 tenge in 2026) with confiscation of the income earned without the licence; a repeat within a year — 30 / 50 / 80 / 500 MRP. Once income exceeds 10,000 MRP (43,250,000 tenge) or damage to an organisation exceeds 10,000 MRP, criminal liability under Article 214 of the Criminal Code follows — up to 2 years’ imprisonment, and up to 5 years where income exceeds 20,000 MRP.

How does a second-category permit differ from a licence?

A licence is issued for a high-danger activity under the uniform procedure of Chapter 5 of Law No. 202-V, with qualification requirements and a licence fee; a second-category permit is issued for a medium-danger activity or action (consent to economic concentration, the permit to attract foreign labour, an environmental permit, the architectural and planning assignment) under the rules of sectoral laws, with permit requirements that apply throughout its life and, as a rule, without a licence fee.

Can a foreign company obtain a licence in Kazakhstan without registering an LLP?

Formally yes: Article 20(2) of Law No. 202-V puts foreign legal entities on the same footing as Kazakh ones, Article 29(2)(2) provides for the issue of a licence to a foreign legal entity without a branch at the place where it carries on the activity, and Article 27 for payment of the fee under its own BIN. In practice, however, the qualification requirements (staff, premises, equipment in Kazakhstan) and the set-up of the digital system make incorporating an LLP the standard route, and a branch can be a licensee only in the financial services sphere.

Do I need to re-issue the licence when the address or the director changes?

A change of chief executive is not among the re-issue grounds in Article 33(1), so it does not require re-issue. A change of name or location of the legal entity (where the address is stated in the licence), of the object’s address, a reorganisation and the transfer of an object licence require a re-issue application within 30 calendar days under Article 33(4); the licensor re-issues the licence within 3 working days, and the fee is 10 % of the issue rate. Address changes caused by the renaming of streets and settlements are entered automatically through the integration of digital systems.

What changed in licensing in Kazakhstan in 2026?

Tax Code No. 214-VIII has applied since 1 January 2026 without the annual payment for the use of licences; from July 2026 Law No. 256-VIII shortened the list of documents and introduced proactive re-issue and automated issue; basic and universal banking licences have applied since March 2026; from 20 August 2026 the communications services licence has a new wording and a notification of the commissioning of data centres applies; from 1 September 2026 licensing in the electricity industry applies; and from 21 October 2026 the licence of a first-category payment organisation takes effect.

Key takeaways on permits and notifications in Kazakhstan in 2026

Over twelve years Law No. 202-V has turned Kazakhstan’s permit system from a set of departmental rules into a closed catalogue: three annexes, 81 licences, 226 second-category permits and 65 notifications, and no authority can demand a document that is not in the catalogue. The three regimes differ in the moment from which the activity is lawful: a notification — from the moment the form is sent; a licence and a permit — from the moment of issue or from the date on which the document is deemed issued under the “silence is consent” rule, which is switched off in the financial, nuclear and mining spheres. The cost of entry for most “ordinary” licences is a 43,250 tenge fee and 15 working days’ wait, the real barrier being the qualification requirements; in the excisable and financial spheres the fee runs to millions of tenge, but the annual payment for the use of a licence was abolished on 1 January 2026 together with the old Tax Code. The year 2026 brought fourteen laws touching the Law itself — from “digital” terminology and automated issue to new licences in the electricity industry, the nuclear sector and the payments market — and two discrepancies to bear in mind when reading the consolidated text: the clash of two items 66 in Annex 3 and the reference to an “annual fee” that no longer exists in the Tax Code. Liability is symmetrical to the regimes: the fine under Article 463 of the Code of Administrative Offences attaches both to the absence of a licence and to a notification not sent, confiscation of income only to working without a licence, and the criminal threshold of 43,250,000 tenge of income makes working “until the document arrives” an unacceptable risk for any operating business. A foreign company obtains permits on the same footing as a Kazakh one, but outside the financial sphere the licensee can only be the legal entity itself or a Kazakh LLP, not a branch. Identifying the applicable regime, assembling the qualification package and getting through the procedure without losing time is what the UPPERSETUP team helps with.

Summary 

The Law of the Republic of Kazakhstan No. 202-V of 16 May 2014 “On Permits and Notifications” (in force since 21 November 2014, latest redaction 8 September 2026) divides activities into three danger levels: high — licences (first-category permits, Annex 1, 81 entries in force across the 29 spheres of Article 28), medium — second-category permits (Annex 2, 226 entries), low — notifications (Annex 3, 65 entries); the lists are exhaustive (Article 17(6); Article 109 of Entrepreneurial Code No. 375-V). A licence is issued no later than 15 working days (30 — finance, education, hydrocarbons, nuclear energy; Article 30), as a rule without a time limit (Article 29(7)), and is non-transferable except class 2 object licences marked “transferable” (Articles 23, 29(8)); where the authority is late it is deemed issued (Article 26), except entries with a note. The licence fee is Article 616(4) of Tax Code No. 214-VIII: 10 MRP (43,250 tenge at an MRP of 4,325 tenge) for construction, medicine, education, audit, tour operators; 6 MRP for communications, advocates, notaries, security; 3,000 MRP for alcohol production; 3,845 MRP for a casino; 800 MRP for each banking operation; re-issue 10 %; there has been no annual payment for the use of licences since 1 January 2026. A notification is sent through the state digital system of permits and notifications (in practice the elicense.kz portal), the activity is permitted immediately after sending (Article 46(4)), changes of data within 10 working days. Re-issue — application within 30 calendar days, issue within 3 working days (Article 33); suspension and revocation — Article 45 and Article 464 of the Code of Administrative Offences. Liability: Article 463 of the Code of Administrative Offences — 15 / 25 / 40 / 150 MRP with confiscation of income for working without a licence, repeat 30 / 50 / 80 / 500 MRP; Article 214 of the Criminal Code — for income above 10,000 MRP up to 2 years, above 20,000 MRP up to 5 years’ imprisonment. Foreign legal entities obtain permits on an equal footing with Kazakh ones (Article 20(2)); a branch can be a licensee only in the financial sphere (Article 1(6)). 2026 amendments: Laws No. 254-VIII, 256-VIII, 259-VIII, 263-VIII, 277-VIII, 291-VIII, 306-VIII, 309-VIII, 320-VIII, 322-VIII, 326-VIII, 334-VIII, 336-VIII; Law No. 352-VIII takes effect on 21 October 2026 (licence of a first-category payment organisation). Current as at September 2026.

Sources

Primary sources (legal acts and official resources)

1.        Law of the Republic of Kazakhstan No. 202-V of 16 May 2014 “On Permits and Notifications” (consolidated text as amended to 8 September 2026, Annexes 1–3) — Adilet legal information system

2.        Official publication data and history of amendments of Law No. 202-V — Adilet

3.        Entrepreneurial Code of the Republic of Kazakhstan No. 375-V of 29 October 2015, Articles 81-1, 82, 83, 108–112— Adilet

4.        Tax Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025, Articles 201, 612–616 — Adilet

5.        Code of the Republic of Kazakhstan on Administrative Offences No. 235-V of 5 July 2014, Articles 463–466 — Adilet

6.        Criminal Code of the Republic of Kazakhstan No. 226-V of 3 July 2014, Articles 3, 214, 214-1, 214-2 — Adilet

7.        Law of the Republic of Kazakhstan No. 239-VIII of 8 December 2025 “On the Republican Budget for 2026–2028”, Article 9 (MRP 4,325 tenge) — Adilet

8.        Law of the Republic of Kazakhstan No. 256-VIII of 9 January 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Digitalisation, Transport and Entrepreneurship” — Adilet

9.        Law of the Republic of Kazakhstan No. 259-VIII of 16 January 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on the Regulation and Development of the Financial Market, Communications and Bankruptcy” — Adilet

10.    Law of the Republic of Kazakhstan No. 306-VIII of 11 June 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Bringing Them into Line with the Constitution of the Republic of Kazakhstan…” — Adilet

11.    Law of the Republic of Kazakhstan No. 320-VIII of 19 June 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on the Development of the Telecommunications Market and Data Centres” — Adilet

12.    Law of the Republic of Kazakhstan No. 322-VIII of 24 June 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Gas Supply and the Electricity Industry” — Adilet

13.    Law of the Republic of Kazakhstan No. 336-VIII of 7 July 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Radioactive Waste Management, Energy and the Development of the Nuclear Industry” — Adilet

14.    Law of the Republic of Kazakhstan No. 352-VIII of 23 July 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on the Improvement and Digitalisation of the Financial Market, Bankruptcy…” — Adilet

15.    Law of the Republic of Kazakhstan No. 71-VIII of 6 April 2024 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Doing Business” — Adilet

16.    Law of the Republic of Kazakhstan No. 254-VIII of 9 January 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Architecture, Urban Planning and Construction” — Adilet

17.    Law of the Republic of Kazakhstan No. 263-VIII of 12 February 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Security Activity, Housing Relations and Law-Enforcement Service” — Adilet

18.    Law of the Republic of Kazakhstan No. 277-VIII of 7 April 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Improving Safe Working Conditions, Protecting Employees’ Labour Rights and Social Security” — Adilet

19.    Law of the Republic of Kazakhstan No. 291-VIII of 19 May 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on the Civil Service” — Adilet

20.    Law of the Republic of Kazakhstan No. 309-VIII of 12 June 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on the Status of Teachers, Education, Healthcare and Protection of Children’s Rights” — Adilet

21.    Law of the Republic of Kazakhstan No. 326-VIII of 24 June 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Digitalisation, Personal Data Protection, Road Traffic and the Regulation of Advanced Technologies in Transport” — Adilet

22.    Law of the Republic of Kazakhstan No. 334-VIII of 7 July 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Improving Social Legislation” — Adilet

23.    Law of the Republic of Kazakhstan No. 231-VIII of 17 November 2025 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Artificial Intelligence and Digitalisation” — Adilet

24.    Law of the Republic of Kazakhstan No. 196-VIII of 24 June 2025 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Civil Protection, the Electricity Industry and State Property Management” — Adilet

25.    Law of the Republic of Kazakhstan No. 210-VIII of 16 July 2025 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Optimising the Criminal Legislation of the Republic of Kazakhstan” — Adilet

26.    Law of the Republic of Kazakhstan No. 155-VIII of 10 January 2025 “On Amendments and Additions to the Code of the Republic of Kazakhstan on Administrative Offences” — Adilet

27.    Law of the Republic of Kazakhstan No. 232-VIII of 17 November 2025 “On Amendments and Additions to the Code of the Republic of Kazakhstan on Administrative Offences” — Adilet

28.    Law of the Republic of Kazakhstan No. 121-VIII of 8 July 2024 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Heat Power, the Electricity Industry and Regulated Services” — Adilet

29.    Law of the Republic of Kazakhstan No. 148-VIII of 30 December 2024 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on State Awards, Education and Protection of Children’s Rights”— Adilet

30.    Construction Code of the Republic of Kazakhstan No. 253-VIII of 9 January 2026, Articles 55 and 117 — Adilet

31.    Budget Code of the Republic of Kazakhstan No. 171-VIII of 15 March 2025, Articles 24 and 26 — Adilet

32.    Law of the Republic of Kazakhstan No. 94-V of 21 May 2013 “On Personal Data and Their Protection” — Adilet

33.    Constitutional Law of the Republic of Kazakhstan No. 438-V of 7 December 2015 “On the Astana International Financial Centre” — Adilet

34.    Government Resolution of the Republic of Kazakhstan No. 1041 of 24 November 2023 “On Determining the List of Persons for Whom Permits of Local Executive Bodies to Attract Foreign Labour Are Not Required” — Adilet

35.    Government Resolution of the Republic of Kazakhstan No. 1011 of 24 September 2014 “Issues of the Ministry of National Economy of the Republic of Kazakhstan” — Adilet

36.    State digital system of permits and notifications “Electronic Licensing of the Republic of Kazakhstan” — elicense.kz

37.    Search of permit documents in the state digital register of permits and notifications — elicense.kz

Secondary sources

38.    Baker McKenzie, “Doing Business in Kazakhstan 2026”, section on permits and licensing — Baker McKenzie

39.    Dentons, “Regulation on trading of goods will significantly change in Kazakhstan from 1 January 2026”, 9 December 2025 — Dentons

40.    Uchet.kz, “How to obtain a licence to sell alcohol in 2026?”, 1 April 2026 (citing the explanation of the State Revenue Department for Abai Region) — Uchet.kz

41.    Uchet.kz, “The licence payment for certain types of activity will be abolished from 2026”, 29 September 2024 (presentation of the draft new Tax Code by the Vice-Minister of National Economy) — Uchet.kz

Disclaimer

This material is for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before making any decisions, individual professional advice must be obtained that takes into account the specific situation, jurisdiction, company status and current regulatory requirements.

Publication date: September 2026.