E-Invoices and the Virtual Warehouse in Kazakhstan in 2026: Order No. 629, Biometrics on Issuance and the New Deadlines

From 1 January 2026 the issuance of invoices in Kazakhstan is governed by the new Tax Code No. 214-VIII and by Order No. 629 of the Minister of Finance of 28 October 2025. The previous e-invoice rules — Order No. 370 of 22 April 2019 — have been repealed in full. The headline change: where a tax risk is identified, an electronic invoice must additionally be certified with the biometric data of the individual issuing it, and without passing biometric identification the invoice cannot be issued at all.

Three points that determine what has actually changed for your company.

First: biometrics on issuance is not a blanket requirement but a consequence of the risk management system firing. Paragraph 6 of article 209 and paragraph 6 of article 492 of the Tax Code impose additional certification by biometric data where a risk is identified in respect of the taxpayer on the basis of the risk management system under article 93 of the Code. The criteria for that risk are not published: paragraph 3 of article 93 classifies as confidential not only the outcome but the risk management procedure itself, and expressly prohibits disclosing it to taxpayers.

Second: the basic issuance deadline is unchanged, but the article has been renumbered. An invoice is issued no earlier than the date on which the taxable turnover arises and no later than fifteen calendar daysafter that date — now paragraph 1 of article 493 of the new Code in place of article 413 of the old one. The special deadlines — 20 calendar days on export, the 20th of the following month for utilities and communications, five calendar days on acquiring works and services from a non-resident — survive, but have been regrouped.

Third: a first failure to issue an e-invoice, and a first late issuance, carry a warning rather than a fine.Parts 1 and 3 of article 280-1 of the Code of Administrative Offences provide for a warning; a fine — 20 to 150 monthly calculation indices (MCI) depending on the offence and the size category of the business — applies only on a repeat offence within a year.

The Legal Base: What Applies and What Was Repealed on 1 January 2026

Invoice regulation in Kazakhstan in 2026 rests on one code, one set of rules and two departmental orders, and the entire previous regulatory layer was repealed in a single step.

Instrument	Ide­ntifi­cation	Key dates	Role
Tax Code of Kazakhstan	Code of the Republic of Kazakhstan of 18 July 2025 No. 214-VIII	Published 19 July 2025; in force from 1 January 2026 (art. 848), save for article 189 — from 1 July 2026 — and article 92 and chapter 90 — from 1 January 2027	The duty to issue, electronic form, deadlines, biometrics, suspension of issuance
Invoice Issuance Rules	Order of the Minister of Finance of 28 October 2025 No. 629, registered with the Ministry of Justice on 28 October 2025 under No. 37241	Order and registration both 28 October 2025; in force from 1 January 2026(para. 4 of the order)	Issuance procedure, invoice form, e-invoice statuses, the biometric procedure
Virtual Warehouse goods list	Order of the Acting Minister of Finance of 31 October 2025 No. 661	In force from 1 January 2026	353 entries by Eurasian Economic Union (EAEU) commodity nomenclature code
Rules on goods consignment notes	Order of the Acting Minister of Finance of 31 October 2025 No. 657, registered with the Ministry of Justice on 31 October 2025 under No. 37317	In force from 1 January 2026	Types of virtual warehouse, receipt and write-off of goods, the consignment note → e-invoice link
MCI for 2026	Law of 8 December 2025 No. 239-VIII “On the republican budget for 2026–2028”, art. 7	From 1 January 2026	MCI = KZT 4,325 — the basis for every admi­nistra­tive fine

Repealed with effect from 1 January 2026:

•          the Tax Code of 25 December 2017 No. 120-VI — save for paragraph 1-1 of article 68 (repealed from 1 January 2027) and paragraph 23 of article 26 (from 1 January 2029);

•          Order No. 370 of the First Deputy Prime Minister — Minister of Finance of 22 April 2019 “On approval of the Rules for issuing an invoice in electronic form in the electronic invoice information system and its form” (registration No. 18583), together with five individual paragraphs of the orders that had amended it and the whole of Order No. 1040 of the Deputy Prime Minister — Minister of Finance of 6 October 2022; Appendix 3 to Order No. 629 runs to seven items in all;

•          Order No. 1424 of 26 December 2019 on the list of goods requiring a consignment note — repealed by Order No. 657 of the Acting Minister of Finance of 31 October 2025.

Note the changed title of the rules: Order No. 629 approves the “Invoice Issuance Rules”, dropping the words “in electronic form” and “in the electronic invoice information system”. The predecessor, Order No. 370, was titled “Rules for issuing an invoice in electronic form in the electronic invoice information system and its form”. The renaming tracks a change in the Code’s architecture: electronic form has moved from being the subject of a dedicated set of rules to being the general rule in articles 209 and 492, with paper permitted only in four expressly listed situations.

Tax Code No. 214-VIII has been amended once since enactment. The amendments were made by the Law of the Republic of Kazakhstan of 11 June 2026 No. 308-VIII, in force from 1 July 2026. The invoice articles — 207, 208, 209, 491, 492, 493, 499, 500 and 501 — together with articles 88, 93 and 99 carry no amendment footnotes and stand in their original wording. The amendments are terminological and run through the whole text: every form of the word “иностранец” was replaced by “иностранный гражданин”, and “тенге” by “теңге”.

The practical consequence of that sweep: from 1 July 2026 article 88(1)(12) speaks of a “foreign citizen” rather than a “foreigner”. Quotations of the Code taken from texts dated before 1 July 2026 reproduce the earlier wording, and the difference matters when reconciling texts.

Order No. 629 was issued under paragraph 2 of article 207 of the Tax Code. Its preamble reads: “In accordance with paragraph 2 of article 207 of the Tax Code of the Republic of Kazakhstan I HEREBY ORDER”. Paragraph 2 of article 207 itself reads: “An invoice is issued in the manner and in the form determined by the authorised body, having regard to the provisions of this Code.”

As at August 2026 Order No. 629 stands in its original wording. The instrument’s amendment history in the register of normative legal acts contains a single entry, “New”, dated 28 October 2025, and the text of the Rules carries no amendment footnotes.

What Changed on 1 January 2026: Mapping the Old Code to the New

Invoice provisions in the new Tax Code are split across two locations, whereas the old Code gathered them into a single chapter 47. That is the principal structural change, and without it the new article numbers cannot be navigated.

Sub-chapter 1, “Invoice” — articles 207, 208 and 209 — governs the general obligation and the rules for taxpayers that are not value added tax (VAT) payers. Chapter 50, “Issuance of invoices by value added tax payers” — articles 491 to 501 — governs the rules for VAT payers. Issuance deadlines, by contrast, are common to both and sit in a single article, 493.

Subject matter	Old Code No. 120-VI (repealed)	New Code No. 214-VIII (in force from 01.01.2026)
Duty to issue an invoice	art. 412(1)	art. 207(1); art. 208(1) — non-VAT payers; art. 491(1) — VAT payers
Electronic form and the paper exceptions	art. 412(2)	art. 209(1) — non-VAT payers; art. 492(1) — VAT payers
Delegation of the rules to the authorised body	art. 412(3) — basis for Order No. 370	art. 207(2) — basis for Order No. 629
Virtual Warehouse goods list	art. 412(3-1)	art. 208(1)(10), second part
Cases where no invoice is required	art. 412(13)	art. 208(2) and (3); art. 491(2) and (3)
Recipient’s right to demand an invoice	art. 412(14)	art. 208(4)–(5); art. 491(4)–(5)
Issuance deadlines	art. 413	art. 493
Special cases: freight forwarders, commission, joint activity	arts. 414–418	arts. 494–498
Corrected and additional invoices, recall	arts. 419, 420, 421	arts. 499, 500, 501
Restriction / suspension of e-invoice issuance	art. 120-1 “Restriction of issuance”	art. 88 “Suspension of issuance”
Risk management system	art. 136	art. 93
Biometric certification of an e-invoice	did not exist	arts. 209(6) and 492(6) — new

The shift in terminology from “restriction” to “suspension” is not cosmetic. The old article 120-1 was headed “Restriction of the issuance of electronic invoices” and carried one ground — failure to comply with a notice issued after desk control in respect of high-risk breaches. The new article 88 is headed “Suspension of the issuance of electronic invoices” and carries fifteen grounds. The old provision stated expressly that an appeal against the decision did not suspend its effect; article 88 contains no such statement at all — and no statement that the decision is appealable either.

Risk-categorisation of taxpayers has disappeared from the risk management system. Article 136 of the old Code provided that the risk management system was “based on an assessment of the degree (level) of risks” and listed among its fields of application “the categorisation of taxpayers (tax agents) by assigning them to categories of low, medium or high degree of risk”. The new Code contains no risk-categorisation of taxpayers: the phrase “degree of risk” appears once in its text, in the article on pilot projects, referring to “the correspondence between the impact of a pilot project and the degree of risk of adverse events” — not to taxpayers.

The author’s assessment: the disappearance of the risk-degree scale from the statute, at the same moment as biometrics keyed to risk identification was introduced, is the most underestimated change in the reform. A taxpayer could previously at least locate itself against formally described categories. The practical consequence: from 2026 the fact of being flagged as risky reaches the taxpayer not as a document stating a category but as a notification inside the information system requiring biometric identification. The wider tax framework in which this sits is covered separately in our analysis of Kazakhstan’s tax system in 2026.

Who Must Issue an Invoice: Two Regulatory Tracks

The duty to issue an invoice splits into two tracks, and which track a taxpayer sits in determines which articles of the Code govern it. Article 207 sets out the fork directly: “The following taxpayers are obliged to issue an invoice: those registered as a value added tax payer — in accordance with chapter 50 of this Code; those that are not value added tax payers … — in accordance with articles 208 and 209 of this Code.”

VAT payers must issue an invoice on any taxable turnover. Article 491(1): “Value added tax payers, when making a turnover on the sale of goods, works or services, are obliged to issue an invoice.” The only exception in the provision itself is the sale of personal property by an individual who is a sole trader.

Non-VAT payers must issue an invoice only in the twelve cases listed in article 208(1).

No.	Category of non-VAT payer required to issue an invoice
1)	A commission agent — in the cases set out in article 495
2)	A freight forwarder — in the cases set out in article 494
3)	The state material reserve agency
4)	A taxpayer — for international freight transport services
5)	A legal entity accredited to carry out conformity assessment activity
6)	A customs repre­senta­tive, customs carrier, owner of temporary storage warehouses, owner of customs warehouses, authorised economic operator
7)	A taxpayer under the special tax regime based on a simplified declaration
8)	A taxpayer — in cases provided for by acts adopted to implement ratified international treaties
9)	A taxpayer — on the sale of imported goods
10)	A taxpayer selling goods that were received by it and recorded on receipt in the “Virtual Warehouse” module
11)	A taxpayer — for medical services and the sale of medicines and medical devices
12)	A law office — for legal assistance rendered by an advocate

Article 208(1)(10) is the legal foundation of the Virtual Warehouse. Its second part delegates the goods list to the authorised body: “The list of goods in respect of which electronic invoices are issued through the ‘Virtual Warehouse’ module of the electronic invoice information system is approved by the authorised body and published on its internet resource.” Order No. 661 of 31 October 2025 was issued under precisely this provision.

Sub-paragraph 7) reaches everyone on the simplified declaration regime. The special tax regime based on a simplified declaration does not exempt a business from issuing invoices; it merely places it in the article 208 and 209 track rather than chapter 50. The regimes themselves changed in 2026 — six became three — and that transition is covered separately in our analysis of Kazakhstan’s special tax regimes in 2026.

Registration as a VAT payer determines the regulatory track, not whether the duty exists. The registration threshold and mechanics are covered separately in our analysis of VAT in Kazakhstan in 2026; for present purposes it is enough to record that a non-VAT payer is not free of invoices — it is free of chapter 50.

When No Invoice Is Required, and When Paper Is Permitted

No invoice is required in six situations, but the lists for VAT payers and non-payers do not coincide exactly. For non-payers this is article 208(2); for VAT payers, article 491(2).

Article 208(2) does not apply to all twelve categories but only to the first seven and to the eleventh. It opens: “In the cases provided for by sub-paragraphs 1) to 7) and 11) of paragraph 1 of this article, no invoice is required in the following cases.” Sub-paragraphs 8) to 10) — Virtual Warehouse goods among them — are dealt with by a separate paragraph 3, and sub-paragraph 12) attracts no exemption of this kind at all.

No invoice is issued on:

•          a sale where settlement is accompanied by a cash register receipt issued to the buyer and/or made through a payment terminal, or where a receipt from a special mobile application is issued;

•          a sale to individuals settled with electronic money or an electronic payment instrument;

•          settlements through second-tier banks or the postal operator for utilities and communications services supplied to an individual;

•          carriage of a passenger by rail or air documented by a travel ticket, an electronic ticket or an electronic travel document;

•          a gratuitous transfer of goods or gratuitous performance of works or services for an individual who is not a sole trader or a person in private practice;

•          financial transactions under article 477 of the Code — with article 491(2), for VAT payers, adding “and services supplied to individuals that are subject to value added tax”.

The first two exemptions do not apply to dealings with the persons listed in article 131(1). The provision states expressly: “The provisions of sub-paragraphs 1) and 2) of the first part of this paragraph do not apply where goods, works or services are sold to the persons specified in paragraph 1 of article 131 of this Code.” The practical consequence: a cash register receipt does not by itself discharge the duty to issue an invoice where the buyer falls into that category.

A separate rule applies to the goods in article 208(1)(8)–(10), which include Virtual Warehouse goods. For those, no invoice is required only on sales to individuals using the goods for final consumption, and to individuals or legal entities that are micro-business entities under the Entrepreneurial Code.

The recipient may demand an invoice within fifteen calendar days of the date the turnover arose — but not in every exempt case. Article 208(4) and article 491(4) confer that right only in the cases “provided for by: sub-paragraphs 1) and 2) of paragraph 2 of this article; paragraph 3 of this article” — that is, settlements with a cash register receipt or electronic money, and the goods in sub-paragraphs 8) to 10). No such right exists for settlements through banks and the postal operator for utilities and communications, for gratuitous transfers to an individual, or for financial transactions.

Travel tickets are dealt with by a separate paragraph 5. Article 208(5) and article 491(5) give the recipient of the services fifteen calendar days to demand “a document confirming the fact of the individual’s travel, or an invoice” — an alternative to the invoice that paragraph 4 does not offer. On such a demand the invoice is issued no later than thirty calendar days after the date the turnover arose — article 493(8).

When Is an Invoice Issued on Paper?

Electronic form is the general rule; paper is permitted in four expressly listed cases. The provision sits in article 209(1) for non-VAT payers and article 492(1) for VAT payers.

Ground for a paper invoice	Provision	Deadline for entering it into the e-invoice information system
No public teleco­mmuni­cations network at the taxpayer’s location within the admini­strative-te­rritorial unit	art. 209(1)(1), art. 492(1)(1)	no deadline set
Confirmation on the authorised body’s internet resource that issuance is impossible because of technical errors	art. 209(1)(2), art. 492(1)(2)	15 calendar days from the date the technical errors are resolved
Suspension of invoice issuance under article 88	art. 209(1)(3), art. 492(1)(3)	15 calendar days from the date the suspension is lifted
A state of emergency or a declared emergency situation	art. 209(1)(4), art. 492(1)(4)	30 calendar days from the end of that period

The lists of grounds in articles 209 and 492 are word-for-word identical, the fourth included. Article 492(1) carries the same four sub-paragraphs as article 209(1) and closes with an additional sentence: “The issuance procedure and the form of the invoice are established by the authorised body.” The practical consequence: the contingency procedure is built the same way for VAT payers and non-payers alike, but each should cite its own article — 492 or 209 respectively.

The author’s assessment: the third ground is the most common in practice and the most awkward. A suspension under article 88 does not relieve the taxpayer of documenting its turnover: invoices are issued on paper and must then be entered into the information system within fifteen calendar days of the suspension being lifted. The practical consequence: a suspension creates double work — paper documentation during the suspension, followed by bulk data entry into the system on a compressed deadline.

Issuance Deadlines: Article 493 in Full

The general deadline is no earlier than the date the taxable turnover arises and no later than fifteen calendar days after that date. Article 493(1) reads: “Unless otherwise established by this article, an invoice is issued no earlier than the date on which the turnover on sale arises and no later than fifteen calendar days after that date.”

Article 493 is common to VAT payers and non-payers alike. For non-payers this is fixed by the cross-reference in article 209(7): “An invoice is issued by non-value added tax payers within the periods established by article 493 of this Code.” The closing paragraph 8 of that article points to the special cases: “The specifics of issuing invoices in particular cases are established by articles 494 to 498 of this Code.”

Situation	Deadline	Provision
General rule	no earlier than the date of turnover and no later than 15 calendar days after it	art. 493(1)
The thirteen categories in article 493(2)(listed below the table)	monthly, no later than the 20th of the following month	art. 493(2)
Export of goods under the customs export procedure	no later than 20 calendar days after the date of turnover	art. 493(3)
Finance lease — for the interest element	quarterly, no later than the 20th of the month following the quarter	art. 493(4)
Sale of periodical print publications and other mass media products	15 calendar days after the date of turnover; issuance beforethat date is also permitted, covering the whole calendar year’s turnover	art. 493(5)
Additional invoice	no earlier than the date of the adjustment turnover and no later than 15 calendar days after it	art. 493(7)
Additional invoice by the successor of a reorganised legal entity, increasing the amount	no later than 180 calendar days after the date of turnover	art. 493(7)
Additional invoice by a lessor where article 213 is not complied with	no later than 15 calendar days from the date the event occurs	art. 493(7)
On the recipient’s demand (arts. 208(4)–(5), 491(4)–(5))	no later than 30 calendar days after the date of turnover	art. 493(8)
Acquisition of works and services from a non-re­si­dent — the buyer’s turnover	no later than 5 calendar days from the day the VAT for the non-resident is paid into the budget, including by set-off	art. 493(9)

Article 493(2) has thirteen sub-paragraphs, and three of them are routinely lost in summaries. The monthly regime applies to: 1) sales of electricity and heat, water and gas; 2) utility services; 3) communications services; 4) rail transport and the carriage of passengers, baggage and freight by air; 5) freight forwarding contracts and contracts on commission terms, and wagon and container operator services; 6) freight carriage through trunk pipeline systems and system services of the system operator; 7) the provision of credit, loans and microloans; 8) banking operations subject to VAT; 9) sales of goods, works and services under contracts concluded for one year or more with the persons specified in article 131(1) of the Code; 10) recognition of the date of turnover under article 460(2); 11) toll road services of the National Roads Operator; 12) services of the State Corporation; 13) the collection, exchange, processing and distribution of information generated in payments and money transfers.

Sub-paragraph 9) is the most consequential of the three that get lost. A long-term contract concluded for a year or more with a person specified in article 131(1) moves invoicing onto the monthly regime, due by the 20th of the following month. The practical consequence: the general fifteen-day rule does not apply to such contracts, and an accounting system configured to “15 days from the date of turnover” produces a systematic error.

The five-day deadline on acquiring works and services from a non-resident is the shortest in the article and the easiest to miss. It runs not from the date of turnover and not from the date of the acceptance certificate, but from the day the value added tax for the non-resident is paid into the budget, including payment effected by set-off under articles 122 and 123 of the Code. The practical consequence: where the VAT for a non-resident is cleared by set-off rather than by a payment, the five-day clock still runs — from the date of the set-off. The related questions of taxing payments to a non-resident are covered separately in our analyses of withholding tax and the permanent establishment of a non-resident.

A corrected invoice is issued on the occurrence of an event under article 499(1). Article 493(6) sets no independent deadline for it, referring instead to the ground for issuance.

The author’s assessment: regrouping the deadlines into article 493 did not change them in substance, but it did change the risk of error. The old article 413 carried a different number, and internal procedures, contracts and accounting-system configurations that state deadlines by reference to “article 413 of the Tax Code” have, since 1 January 2026, been referring to a repealed instrument. The practical consequence: references to articles of the old Code in contracts, accounting policies and system settings need a complete sweep — not because the deadlines changed, but because the instrument they cite has ceased to exist.

Biometrics on E-Invoice Issuance: What Was Actually Introduced

Biometric certification of an electronic invoice is a requirement that did not exist in the old Tax Code at all. It is introduced by two parallel provisions: article 209(6) for non-VAT payers and article 492(6) for VAT payers.

Article 209(6) reads: “Unless otherwise established by this paragraph, an invoice issued in electronic form is authenticated by means of an electronic digital signature. The invoice is additionally certified by the biometric data of the individual issuing the invoice, in the manner prescribed by the authorised body, where a risk is identified in respect of the taxpayer on the basis of the risk management system under article 93 of this Code.”

Article 492(6) reproduces the same construction for VAT payers, with one lexical difference: where article 209 says the invoice “is authenticated” by the digital signature, article 492 says it “is certified”. The difference is present in the official text of the Code.

How the Procedure Works Under Paragraph 27 of the Rules

Paragraph 27 of the Rules sets four parameters, all of them quantified.

“27. Where a risk is identified in respect of a taxpayer on the basis of the risk management system under article 93 of the Tax Code, the e-invoice is additionally certified by the biometric data of the individual issuing it, in accordance with the requirements established by paragraph 6 of article 209 and paragraph 6 of article 492 of the Tax Code. In that case a notification of the need to undergo biometric identification is sent to the taxpayer through the e-invoice information system. Biometric identification is carried out 1 (one) time per day on the issuance of an e-invoice. The total number of biometric identifications is 3 (three), after which the system allows further e-invoices to be issued without it. Where biometric identification is passed successfully, the system processes the e-invoice and assigns it a registration number; where it is not passed, the e-invoice cannot be issued.”

Parameter	Value under paragraph 27 of the Rules
Who undergoes ide­ntifi­cation	the individual issuing the e-invoice
How the taxpayer learns of the requirement	a notification inside the e-invoice information system
Frequency	once per day on issuance
Total number of times	three, after which issuance proceeds without biometrics
Consequence of passing	the system processes the invoice and assigns a registration number
Consequence of failing	the e-invoice cannot be issued

The detail most easily missed: biometrics is not required on every invoice but once a day, and only three times in total. After three passes the information system “allows further e-invoices to be issued without it”. The mechanism is therefore designed as a one-off check that a particular human being is present, not as continuous per-transaction control.

Note the change from the pilot regime. Under pilot Order No. 294 of the Deputy Prime Minister — Minister of Finance of 27 March 2023, in the wording in force before the reform, paragraph 4-1 capped the procedure at “no more than 3 (three) times within a calendar month”. Paragraph 27 of the current Rules says simply “3 (three) times”, with no reference to a calendar month.

After 31 December 2025 the procedure referred to by articles 209(6) and 492(6) is contained in paragraph 27 of the Rules under Order No. 629 and nowhere else. Order No. 568 of the Minister of Finance of 3 October 2025, “On approval of the rules for the use of biometric identification tools in the information systems of the state revenue authorities”, expired under its own paragraph 4 — “applies until 31 December 2025 inclusive” — and no successor instrument could be located in the register of normative legal acts. This does not create a legal gap: the Code delegates to the procedure established by the authorised body, and from 1 January 2026 that procedure is the one laid down in Order No. 629.

Certification by biometric data is defined in the Rules as a distinct stage of issuance. Paragraph 13: “certification of an e-invoice by biometric data — the procedure of certifying an e-invoice by means of biometric identification in the e-invoice information system in accordance with paragraph 6 of article 209 and paragraph 6 of article 492 of the Tax Code and these Rules.”

The author’s assessment: the economic point of the rule is not identity verification as such but tying invoice issuance to the physical presence of a particular person. An electronic digital signature can be handed over, copied to a token and physically used by anyone; a face cannot. The practical consequence: a company where the director’s digital signature in fact sits with the accountant will find, once a risk fires, that issuance stops until the individual who actually issues the invoices passes identification.

The Article 93 Risk Management System: Why the Criteria Cannot Be Known

Article 93 of the new Tax Code runs to three paragraphs and contains not a single risk criterion. It defines the tax risk management system, divides measures into preventive and control measures, and declares the risk management procedure itself confidential.

The definition in paragraph 1 reads: “The tax risk management system is a set of measures carried out by the tax authority in the course of tax administration with the aim of identifying tax risks and determining measures to minimise them. A tax risk is the probability of non-compliance with the tax legislation of the Republic of Kazakhstan and other legislation the enforcement of which is entrusted to the tax authorities.”

Control over e-invoice issuance is named expressly as a risk-minimisation control measure. Paragraph 2: “Control measures to minimise tax risk are carried out through desk control, control over the issuance of electronic invoices, tax control and other forms of control.”

Paragraph 3 closes off access to both the procedure and the outcome. It reads: “Information obtained in the course of risk management, and the procedure for organising risk management, are confidential information, access to which is restricted by the legislation of the Republic of Kazakhstan. … Providing that information to other persons, including taxpayers, is prohibited.”

What the Code says about the risk management system	Provision
The risk management procedure is determined by the authorised body	art. 93(2)
The procedure and the information obtained are co­nfide­ntial	art. 93(3)
Disclosure to taxpayers is pro­hibi­ted	art. 93(3)
Degrees, levels and categories of risk	absent from the new Code
A dedicated provision notifying a taxpayer of an assigned risk	absent
Risk ide­ntifi­cation among the appealable acts in article 36	absent

The subordinate act that used to publish part of the criteria has been repealed without replacement.Order No. 252 of the Minister of Finance of 20 February 2018 was titled “On approval of the Rules for applying the risk management system on criteria that are not confidential information”. It was repealed by Order No. 586 of 9 October 2025 with effect from 1 January 2026. No instrument publishing the risk criteria that trigger biometrics on e-invoice issuance could be located in the register of normative legal acts as at August 2026 — consistent with article 93(3), which declares the risk management procedure itself confidential.

The right of appeal in article 36 is drawn narrowly. Sub-paragraph 7) of paragraph 1 confers a right to appeal against “a notice of the results of a tax audit, a notice of the outcome of consideration of a taxpayer’s (tax agent’s) complaint against a notice of the results of a tax audit, and the acts (omissions) of an official of the tax authority”. Neither a decision identifying a risk nor the assignment of a risk appears in that list.

The author’s assessment: article 93 creates an asymmetry with no procedural exit. The biometric requirement arises from risk identification; the risk criteria are unpublished and their disclosure to the taxpayer is prohibited; and the Code provides no separate route to challenge risk identification. The practical consequence: what is worth contesting is not the risk flag itself but the specific subsequent act of the tax authority — a notice, a suspension of issuance, an audit result — which is what the statute makes appealable.

The only practical manifestation of risk for a taxpayer is a notification inside the information system. Paragraph 27 of the Rules: “a notification of the need to undergo biometric identification is sent to the taxpayer through the e-invoice information system.” The Code provides for no document stating a risk category, its grounds or its duration.

Registration in the E-Invoice System: The Director’s Biometrics and Three Signatures

Biometrics is used in the e-invoice system in three situations: on registration of a participant, on a change in its registration data, and on issuance of an invoice where a risk has fired. The first two are general and mandatory, the third conditional. Paragraph 5 of the Agreement on the use of the system, appended to the Rules, names them together: a participant passes biometric identification “on registration and/or on a change in the participant’s registration data, and where a risk is identified in respect of the taxpayer”. They should not be conflated: different grounds, different subjects, different consequences.

A participant in the system is defined by reference to having passed biometrics. Paragraph 4 of the Rules: “a participant in the e-invoice information system — a person who has passed biometric identification and signed the Agreement on the use of the electronic invoice information system … and who is registered in the system.”

Registration is carried out separately for each status. Paragraph 8 identifies three participant statuses: an individual; a sole trader or person in private practice; and a legal entity or a structural subdivision of a legal entity. Registration of a legal entity “is carried out exclusively by the head of the legal entity”.

The Agreement on behalf of a legal entity is authenticated by three simultaneous acts. Paragraph 11 of the Rules:

What is required	Paragraph 11 of the Rules
The director’s digital signature as an individual	sub-para. 1)
The legal entity’s digital signature, containing the director’s individual ide­ntifi­cation number	sub-para. 2)
Biometric ide­ntifi­cation passed by the director	sub-para. 3)

Paragraph 10 of the Rules creates two exemptions from the biometric requirement on registration. It reads that biometric identification is carried out in the manner set out in paragraph 11, “save for persons with disabilities whose bodily impairments do not permit biometric identification, and persons for whom no biometric data exists in the National Register of Individual Identification Numbers”.

The Rules name the exemptions but do not describe an alternative procedure. Order No. 629 contains no provision explaining how a participant covered by the paragraph 10 exemption actually registers — no attendance at a state revenue office, no registration on a single digital signature, no application route. The practical consequence: an organisation whose director has no biometric data in the National Register will find no answer in the Rules and must resolve the matter case by case with the state revenue authority.

The Code frames the requirement more strictly than the Rules do, and does so in the article on VAT registration.Article 99(6) in full: “After registration of the taxpayer, the director and/or the person responsible for settlements with the budget must attend a briefing at the tax authorities on the electronic invoice information system and the procedure for issuing electronic invoices. On registration and/or on a change in the registration data of a legal entity, and on a change of director, biometric identification of the director is carried out in the electronic invoice information system.” That provision contains no exemptions at all — they appear only at the level of paragraph 10 of the Rules.

A participant registered with the status “individual” does not issue invoices. Paragraph 9 makes an exception where the individual “is an authorised representative or employee of a participant that is a legal entity … a sole trader or a person in private practice”.

The author’s assessment: the combination of the director’s personal signature, the entity’s signature carrying the director’s identification number, and the director’s biometrics makes registration impossible without the first director in person. This matters for foreign structures: the director must hold a Kazakh individual identification number, because it has to be embedded in the entity’s digital signature. The practical consequence: on a change of director in a Kazakh company, the e-invoice system registration steps become a separate task with their own timeline rather than an automatic consequence of the corporate resolution. The corporate side of this is covered in our analysis of the Kazakh LLP for foreign owners.

E-Invoice Statuses and What Happens If Biometrics Is Not Passed

Paragraph 14 of the Rules lists sixteen statuses for an electronic invoice, and the first three arrived together with biometrics. The previous Rules knew no such statuses.

E-invoice status	Meaning
“Awaiting biometric identi­fica­tion”	an e-invoice awaiting biometric ide­ntifi­cation
“Biometric ide­ntifi­cation not passed in time”	an e-invoice that did not pass ide­ntifi­cation within the set period
“Deleted, biometric ide­ntifi­cation not passed”	an e-invoice deleted from the system because ide­ntifi­cation was not passed
“Not viewed”	the issued invoice has not been viewed by the recipient
“Delivered”	the issued invoice has been viewed by the recipient
“Annulled”	annulled because a corrected invoice was issued
“Annulled on rejection of the consignment note”	the recipient rejected the supplier’s goods consignment note
“Annulled on recall of the consignment note”	the supplier recalled a previously issued consignment note
“Annulled on crediting and deduction”	the cou­nterpa­rty’s registration or re-re­gistra­tion was declared invalid by a court act
“Recalled”	recalled by the supplier
“Draft”	a partially or fully completed draft invoice
“Imported”	uploaded from the participant’s accounting system, processed but not sent to the recipient
“Erroneous”	failed processing and was not sent to the recipient
“Confirmed”	a corrected, additional or recalled invoice confirmed by the recipient
“Rejected”	a corrected, additional or recalled invoice rejected by the recipient
“Blocked by the e-invoice information system”	sent to the authorised body for the purposes of state support measures

Paragraph 30 lists four confirmation statuses, two of which are new. Alongside the repeated “Not viewed” and “Delivered” it introduces “Awaiting recipient confirmation” and “Awaiting recipient confirmation of recall”. The Rules therefore work with eighteen distinct statuses in all.

Recipient Confirmation: Two Different Regimes

How a corrected, additional or recalled invoice is confirmed depends on whether the recipient is a VAT payer, and the difference is fundamental. Paragraph 29 of the Rules refers to articles 499, 500 and 501 of the Code, which establish two distinct regimes.

Recipient	What it does	Deadline	When the invoice counts as issued
VAT payer	must confirm the issuance or reject it if it disagrees	no statutory deadline	only where the recipient has confirmed
Non-VAT payer	may reject the issuance	10 calendar days from receipt	absent rejection in time, it counts as confirmed

The provision for VAT payers (art. 499(4)(1)) reads: “is obliged to confirm the issuance of such an invoice, or to reject it in case of disagreement — where the recipient of the corrected invoice is a value added tax payer. The invoice is regarded as issued where confirmation has been given by the recipient of that invoice.” Identical constructions appear in article 500(4) for additional invoices and article 501(2) for recalls.

The provision for non-VAT payers (art. 499(4)(2)) reads: “is entitled, within ten calendar days of receiving the corrected invoice, to reject its issuance… If no such rejection is made within the period specified in this sub-paragraph, the invoice is regarded as confirmed by the recipient.”

The practical consequence of that asymmetry: silence from a VAT-registered buyer works against the supplier, whereas silence from a non-registered buyer works in its favour. For a non-payer, ten days of inaction means agreement; for a VAT payer, inaction means the corrected invoice is not treated as issued at all. The operational conclusion: corrections and adjustments addressed to VAT payers need their own confirmation-tracking, because the statute sets no deadline for them and provides for no deemed agreement.

Paragraph 31 does not create the ten-day period; it extends it. It applies where “within 10 (ten) calendar days of the issuance of an additional or corrected e-invoice or of a recall, a technical failure occurred in the information system, confirmed by the authorised body”, and extends the period “by the number of calendar days left unused”.

The Rules set no numerical deadline for passing biometric identification. The status “Biometric identification not passed in time” is defined as an invoice that failed identification “within the period established in accordance with the requirements set by these Rules” — yet the Rules never set that period anywhere. The only figures in paragraph 27 — “1 (one) time per day” and “3 (three) times” — describe frequency and total count, not how long an invoice survives in the waiting status. This figure is not confirmed by any official source and appears to be a configuration parameter of the information system.

The moment of transition from “not passed in time” to “Deleted” is likewise not regulated. The Rules describe neither the conditions for deletion, nor whether a deleted invoice can be re-issued, nor what becomes of the underlying duty to issue.

In legal terms a deleted invoice was never issued. That follows from two provisions read together: paragraph 27 — “where it is not passed, the e-invoice cannot be issued”, meaning no registration number is assigned; and paragraph 28 — an invoice counts as sent where it has been certified in accordance with paragraphs 25, 26 and 27 “and a registration number has been assigned to it”.

The duty to issue an invoice does not lapse in the meantime. It arises from articles 207, 209 and 492 of the Code, and the Rules do not displace it. The article 493 deadlines keep running and liability under article 280-1 of the Code of Administrative Offences continues to apply. The practical consequence: failing biometrics is neither an extension nor a lawful excuse — it exposes the taxpayer to the offence of “failure to issue an invoice in electronic form” at a moment when issuing one is technically impossible.

The author’s assessment: this is the weakest joint in the whole construction. The statute imposes a duty, the subordinate act makes performance conditional on a procedure whose deadline is published nowhere, and non-performance is punishable. The practical consequence: on receiving a notification requiring biometric identification, pass it immediately and record the fact and the time — a screenshot of the invoice status at minimum — because the burden of showing timeliness will fall on the taxpayer.

The Virtual Warehouse: What It Is and How It Works

The Virtual Warehouse is a module of the electronic invoice information system, designed to operate the goods traceability mechanism within Kazakhstan automatically. That definition is set out verbatim in sub-paragraph 2) of paragraph 3 of the Rules on goods consignment notes and their document flow, approved by Order No. 657.

Movement of goods in the Module is monitored automatically. Paragraph 7 of the Rules: “Control over the movement of goods in the ‘Virtual Warehouse’ module of the e-invoice information system (the Module) is carried out automatically, by populating it with the names of goods declared by the participant or an authorised person within the rights granted, and by writing those goods off.”

Types of Virtual Warehouse

Order No. 657 identifies four types of virtual warehouse.

Type	Purpose
“Wa­rehou­se”	the taxpayer’s main warehouse; several may be created
“U­nallo­cated warehouse”	created automatically for system users and for recipients selling goods at retail, including those not registered in the system
“Point of sale”	the place of sale within a shop’s trading floor
“Archive”	storage for a taxpayer’s goods marked “Small retail outlet” that were written off automatically

Seven warehouse attributes are defined separately: “Priority warehouse” — for automatic receipt and write-off; “Warehouse for receipt of goods under customs declarations”; “Public warehouse”; “Warehouse of joint activity participants”; “Leasing warehouse”; “Tolling processing warehouse”; and “Warehouse of a reorganised entity”.

How Goods Enter the Module and How They Are Written Off

Order No. 629 describes three routes for entering goods into the Module.

•          Balances. “On the sale of stock balances, information on the goods is entered into the Module using the ‘Balances’ form, in a quantity corresponding to the quantity of goods being sold” (para. 73 of the Explanatory Note).

•          Production. “On the sale of goods produced in Kazakhstan, information on the goods is entered into the Module using the ‘Production’ form” (para. 74).

•          Imports — automatically. “On the sale of imported goods, information on the goods enters the Module automatically from the data in customs declarations and applications for the import of goods and payment of indirect taxes” (para. 75).

The “Balances” and “Production” routes apply when working in the web application. Paragraph 76: “The procedure for the sale of goods set out in paragraphs 73, 74 and 75 of this Explanatory Note applies when working in the web application of the e-invoice information system.” Accounting systems use an integration route instead: paragraph 11 of the Rules under Order No. 657 provides for external accounting systems to interact with the Module “by means of API mechanisms enabling external accounting systems to perform in the e-invoice information system all the operations provided for by the business processes in the Web application”.

Data entered on the “Balances” and “Production” forms must correspond to the actual quantity of stock held.Paragraph 6 of the Rules under Order No. 657 states this requirement twice — once for each form.

Goods may be written off without a sales consignment note in five situations. Paragraph 26 of the Rules under Order No. 657 provides for write-off: on the basis of a cash register receipt with data recording and transmission capability containing the goods ID — automatically on the sixteenth calendar day after the sale; on use for the taxpayer’s own needs, in production, in performing works or supplying services; on damage, loss, theft or disposal; on cessation of traceability; and on receipt of goods under a consignment note issued to a retail entity meeting the criteria in paragraph 18(3) of the Rules — automatically on the expiry of thirty calendar days from the date the note was issued.

The author’s assessment: the Virtual Warehouse is a traceability register rather than a stock ledger, and confusing the two is expensive. The Module does not replace inventory accounting and need not match it methodologically, but for the quantity of a given item it must match reality. The practical consequence: a divergence between Module balances and actual stock is not a technical imprecision but a breach of paragraph 6 of the Rules under Order No. 657 — and it surfaces automatically, because movement is monitored by the system rather than by an inspector.

The Virtual Warehouse Goods List: What It Actually Contains

The list of goods for which electronic invoices are issued through the “Virtual Warehouse” module runs to 353 entries and was approved by Order No. 661 of the Acting Minister of Finance of 31 October 2025. The order came into force on 1 January 2026 and was made “in accordance with sub-paragraph 10) of paragraph 1 of article 208 of the Tax Code of the Republic of Kazakhstan”.

The list has two columns: the name of the goods and the EAEU commodity nomenclature code. Codes are ten digits. Entry 1 is cognac (Cognac), code 2208201200; entry 353, the last, is lysergic acid and its salts within the ergot alkaloid group, code 2939630000.

Nomenclature chapter	Entries	Contents
22 — alcohol and beverages	247	2208 — spirits under 80% strength, liqueurs, spirituous beverages (60 entries); 2204 — natural grape wines including fortified wines, and grape must (170); 2206 — other fermented beverages (9); 2205 — vermouths (4); 2203 — beer (3); 2207 — ethyl alcohol of 80% strength or higher, denatured (1)
27 — petroleum products and gases	38	2710 — petroleum and petroleum products other than crude (28); 2711 — petroleum gases and gaseous hydrocarbons including liquefied propane (9); 2713 — petroleum coke and petroleum bitumen (1)
29 — organic chemistry and precursors	53	headings 2902 to 2939: cyclic hydrocarbons including toluene, alcohols (benzyl alcohol among them), acids, esters, amines and alkaloids
84 — equipment	11	8418 — refri­gera­tors, freezers and other refrigerating equipment, heat pumps, other than air conditioning machines of heading 8415
28 — inorganic chemistry	4	2806 — hydrochloric acid; 2807; 2812; 2841
Total	353

In substance the 2026 list is identical to its predecessor. Order No. 661 reproduces the list approved by Order No. 384 of 23 April 2019 as amended by Order No. 312 of 20 June 2025, in force from 1 September 2025: the sets of nomenclature codes match exactly, nothing was added or removed, and the ordering is identical. The differences are editorial and confined to the name column: minor variations in the Russian grammatical forms, for example in the wording for “less than 80 per cent by volume” and “227 litres”.

What changed is the legal basis, not the content. Order No. 384 was made under paragraph 3-1 of article 412 of the old Tax Code; Order No. 661 under sub-paragraph 10) of paragraph 1 of article 208 of the new one.

Note the legal status of Order No. 661: it is a departmental act without state registration with the justice authorities. Unlike Orders No. 629 and No. 657 it carries no Ministry of Justice registration number. The Code permits this: article 208(1)(10) provides for the list to be approved by the authorised body and published “on its internet resource”, not for state registration.

As at August 2026 the predecessor, Order No. 384, is not marked as repealed in the register of normative legal acts.Appendix 3 to Order No. 629, which lists seven repealed instruments, does not include Order No. 384, and Order No. 661 contains no repealing clause. The repeal of Order No. 384 is not confirmed by an official source — even though its enabling provision, paragraph 3-1 of article 412 of the old Code, lapsed on 1 January 2026 and Order No. 661 has covered the same subject matter since that date.

The author’s assessment: the overlap has no practical consequence, but it does have a methodological one. For 2026 purposes the operative instrument is Order No. 661, because it was made under a live provision of a live Code, whereas Order No. 384 rests on a lapsed provision of a repealed Code. The practical consequence: internal procedures and accounting-system configurations should cite Order No. 661 in place of Order No. 384 — the goods themselves need no change.

Module Mechanics in the Invoice Form: Which Fields Fill Themselves

Where goods are sold through the Virtual Warehouse, six fields in section G of the invoice are populated automatically and are not filled in by hand. These are fields 4, 5, 6, 18, 19 and 20, each carrying an express reference to the Module in the Explanatory Note to the invoice form.

Field	Field name	Provision of the Explanatory Note
4	Name of goods as per the customs declaration or the application for import of goods and payment of indirect taxes	para. 40
5	EAEU commodity nomenclature code	para. 41
6	Unit of measurement	para. 42
18	Number of the customs declaration, import application, goods consignment note, ST-1 or ST-KZ certificate	para. 54
19	Item number from the customs declaration or import application	para. 55
20	Identifier of the goods, works or services	para. 56

The wording is uniform across all six provisions. Paragraph 42, for example: “For goods sold through the Module, this field is completed automatically.” Paragraph 41 adds a rule for reclassification: “Where the nomenclature code changes or is withdrawn, this field states the code in force on the date the invoice is issued.”

The specifics of issuing through the Module sit in a dedicated chapter of the Explanatory Note. Paragraph 23 of the Rules: “chapters 2, 3 and 4 of the Explanatory Note set out the specifics of issuing an e-invoice on the sale of goods: to individuals; through the Module; and on the transfer of property under a finance lease.”

The words “Virtual Warehouse” and “Module” appear nowhere in the invoice form itself. Whether a transaction runs through the Module is signalled not by a dedicated field but by the system of origin markers in field 2 and by the content of fields 4, 5 and 18. The practical consequence: it is not possible to tell from the face of an invoice whether it was issued through the Module; that is determined from system data.

Origin Markers in Field 2

Paragraph 38 of the Explanatory Note establishes six markers. Marker “1” — goods included in the List of Goods and imported from third countries or from EAEU member states; marker “2” — goods not on the List, imported likewise; marker “3” — goods produced in Kazakhstan and included in the List; marker “4” — goods produced in Kazakhstan and not on the List; marker “5” — goods outside markers 1 to 4, and buildings, structures and land plots; marker “6” — works performed and services supplied.

An important terminological warning: the “List of Goods” referred to in the Explanatory Note is not the Virtual Warehouse list. In the Explanatory Note, the List of Goods means the list of goods imported from non-EAEU states to which reduced duty rates may apply — the EAEU exemptions list. The Virtual Warehouse list is approved by a separate instrument, Order No. 661, and plays no part in the origin marker system. Conflating the two lists is a common source of error when configuring accounting systems.

Order No. 629 does not set out the content requirements for the “Balances” and “Production” forms. Paragraphs 73 and 74 name the forms only; the required fields appear nowhere in the order. Paragraph 13 of the Rules under Order No. 657 refers to the technical description of the consignment note structure published on the State Revenue Committee’s internet resource, but says nothing about the “Balances” and “Production” forms. The field composition of those forms is not established by any normative legal act that could be located, and neither Order No. 629 nor Order No. 657 contains a provision delegating it.

The author’s assessment: automatic completion of six fields is a control mechanism rather than a convenience. A taxpayer working through the Module cannot state the name of the goods, their code, the unit of measurement or the customs document number for itself — those values are pulled from data recorded when the goods were received. The practical consequence: an error made when goods are entered into the Module is reproduced in every subsequent invoice for those goods, and must be corrected at the point of entry rather than at the point of issue.

Consignment Notes and E-Invoices: A Chain, Not Two Independent Documents

For goods whose movement requires a consignment note, the electronic invoice is issued on the basis of that note.The rule sits in article 180(3) of the Tax Code — an article headed “Traceability of the circulation of goods imported into the customs territory of the EAEU”, whose paragraph 3 is addressed to taxpayers dealing in goods subject to traceability: “The supporting document of the national traceability system is the electronic invoice. An electronic invoice for goods whose movement requires a goods consignment note is issued on the basis of the goods consignment note.”

For the remaining goods that require a note, the same sequence is imposed at the subordinate level. Paragraph 28 of the Rules under Order No. 657 extends the “invoice on the basis of the note” rule to all goods “subject to the consignment note requirement”, without confining it to traceable goods.

The link is implemented technically through line 32 of the invoice. Paragraph 28 of the Rules under Order No. 657: “An e-invoice for goods subject to the consignment note requirement is issued on the basis of the consignment note, stating in line 32, ‘Document confirming the supply of goods, works and services’, the registration number of the consignment note. The data on the goods in the consignment note and in the e-invoice are identical, save for the value figures.”

The duty to issue a consignment note arises at four moments. Article 179(2) of the Code: on movement, sale or shipment of goods within Kazakhstan — no later than the start of movement; on import from EAEU member states — before crossing the State border; on export — no later than the start of movement; and on international road transport transiting Kazakhstan — at the road checkpoint on crossing the border.

The list of goods requiring a consignment note contains nine entries.

No.	Category of goods requiring a consignment note	Issued through the Module
1	Biofuel	yes
2	Ethyl alcohol and alcoholic products	yes
3	Certain types of petroleum products	yes
4	Gasohol, benzanol, nefras, light hydrocarbon blends, environmental fuel	yes
5	Liquefied petroleum gas	yes
6	Narcotic drugs, psychotropic substances, their analogues and precursors	yes
7	Goods subject to traceability under the Traceability Mechanism Agreement	yes
8	Goods imported from EAEU member states	no
9	Goods exported to EAEU member states	no

Entries 8 and 9 are taken outside the Module by an express provision. Paragraph 7 of the Rules under Order No. 657: “For goods listed at entries 8 and 9 of the List of Goods, the consignment note is issued without using the ‘Virtual Warehouse’ module.”

Where the two lists intersect, the regimes stack. Alcohol, petroleum products, liquefied gases and precursors appear both in the consignment note list (entries 1 to 6) and in the Virtual Warehouse list (nomenclature chapters 22, 27, 28 and 29). Those goods need both a consignment note and an invoice, both through the Module, with the invoice coming second and based on the note. Refrigeration equipment of heading 8418 is on the Virtual Warehouse list but is not named as a separate entry in the consignment note list; how it relates to entry 7 is determined by the annexes to the Traceability Mechanism Agreement and is not stated expressly in either Order No. 657 or Order No. 661.

The goods data in the note and in the invoice must be identical. There are two exceptions: value figures, and goods whose qualitative and quantitative characteristics have changed and whose nomenclature code appears in Appendix 2 to the Rules. The second exception is not open-ended — it applies only to a closed list of codes annexed to the Rules themselves.

The author’s assessment: the document sequence is rigid, and breaking it means missing both deadlines at once. The consignment note is issued no later than the start of the movement of goods; the invoice is issued on its basis, within the article 493 period. The practical consequence: a company that habitually starts its document flow with the invoice will find, for goods in entries 1 to 7, that it cannot issue one — line 32 requires the registration number of a note that does not yet exist — while having already missed the deadline for the note itself, which carries its own separate administrative offence.

Suspension of E-Invoice Issuance: The Fifteen Grounds in Article 88

Suspension of e-invoice issuance is a means of securing performance of a tax obligation, classified as such by article 84(3)(4) of the Tax Code. The grounds are listed in article 88(1), and there are fifteen of them against one in the old article 120-1.

Suspension is imposed by the tax authority within one working day following the day the ground arises.

No.	Ground for suspension under article 88(1)	Lifted under para. 2
1)	Failure to comply with, or a decision treating as unfulfilled, a notice confirming that turnover actually occurred	yes — on removal of the cause
2)	Failure to comply with a notice confirming the taxpayer’s location	yes — on removal of the cause
3)	Expiry of the VAT reporting deadline for a payer that has not filed such reporting itself for the preceding six months	yes — on removal of the cause
4)	Suspension by a VAT payer of the filing of VAT reporting	yes — on removal of the cause
5)	A court act declaring the registration of a sole trader or legal entity invalid	not listed in para. 2
6)	A court act declaring the re-re­gistra­tion of a legal entity invalid	not listed in para. 2
7)	A court act declaring the first director legally incapable or of limited capacity	yes — on the condition ceasing
8)	A court act declaring the first director missing	yes — on the condition ceasing
9)	Information on the death of the first director, or a declaration of death	yes — on the condition ceasing
10)	A court act convicting the first director or sole founder under articles 216, 238 or 245 of the Criminal Code	yes — on the condition ceasing
11)	A decision placing the first director on a wanted list	yes — on the condition ceasing
12)	Information that a foreign director’s purpose of stay is unrelated to employment, or that the permitted period of stay has expired	yes — under both sub-pa­ra­graphs
13)	Inclusion of a sole trader in the register of dormant taxpayers	yes — on removal of the cause
14)	Inclusion in the register of dormant taxpayers of a taxpayer whose director or sole founder holds the same role in a VAT-re­gi­stered entity	yes — on removal of the cause
15)	Failure to comply with a notice of presumed discrepancies identified by desk control	not listed in para. 2

Three grounds — 5), 6) and 15) — appear in neither sub-paragraph of article 88(2). This is a statement about the text, not a conclusion that suspension on those grounds can never be lifted: paragraph 2 lists the cases for lifting by cross-reference to specific sub-paragraphs of paragraph 1, and these three are not among them. Sub-paragraph 15) matters most in practice — failure to comply with a desk-control notice is the commonest trigger of all.

The decision is taken and communicated inside the information system. Article 88(3): decisions to suspend and to lift suspension “are taken by the tax authority in the electronic invoice information system within one working day following the day the ground arises” and “are provided to the taxpayer within one working day following the day the decision is taken”.

Suspension is a matter of public record. Article 88(4): the information is published on the authorised body’s internet resource within one working day of the decision and removed within one working day of its cancellation. A separate counterparty-notification mechanism sits in article 81(3), but it is narrower in scope. Notices go to the recipient counterparty within one working day following the suspension, but the provision refers to the notices in article 81(1)(2) and (3), which concern taxpayers that failed to comply with a notice confirming that turnover actually occurred — that is, ground 1) of article 88(1), not any suspension.

Securing measures are stayed only where the notice of tax audit results is appealed. Article 84(5) stays the application of securing measures, suspension of e-invoice issuance included, where such a notice is appealed to the authorised body — until the complaint is decided plus a further fifteen working days — or to a court, until the judicial act takes effect.

The author’s assessment: expanding from one ground to fifteen turns suspension from a sanction for a specific breach into an instrument of general application. Seven of the fifteen grounds — sub-paragraphs 7) to 12) and 14) — have nothing to do with the company’s conduct as a taxpayer at all: they attach to the status and circumstances of the first director or sole founder. The practical consequence: a change of director, the expiry of his permitted stay in the country or a court act against him stops invoice issuance for the entire company, and the fact becomes public within one working day. For structures with a foreign director this makes tracking the period of stay a question of operational continuity rather than immigration compliance alone. The reverse situation deserves attention too — winding a company down: the settlement and de-restriction sequence is covered in our analysis of liquidating a Kazakh LLP.

Liability: The Offences, the 2026 MCI and the Figures in Tenge

Administrative liability for invoice and consignment note breaches sits in three articles of the Code of Administrative Offences: 280, 280-1 and 283-1. The words “virtual warehouse” appear nowhere in that Code.

The monthly calculation index for 2026 is KZT 4,325. It is set by sub-paragraph 4) of article 7 of the Law of 8 December 2025 No. 239-VIII “On the republican budget for 2026–2028”.

The applicable index is not the one in force when the offence occurred but the one in force when proceedings are commenced. Part 1 of article 44 of the Code of Administrative Offences sets fines “in an amount corresponding to a specified number of monthly calculation indices established in accordance with the law in force at the moment proceedings in the administrative offence case are commenced”. The practical consequence: a 2026 offence prosecuted in 2027 is calculated on the 2027 index, not on KZT 4,325. Part 1 of article 44 is itself due to be amended by the Law of 12 June 2026 No. 312-VIII with effect from 1 January 2027, so the “moment proceedings commence” rule should be re-checked for offences prosecuted after that date.

Article 280-1: Failure to Issue, and Late Issuance

A first offence carries a warning rather than a fine. Parts 1 and 3 of article 280-1 provide for a warning; a fine follows only on a repeat offence within a year of the first penalty being imposed.

Part of art. 280-1	Offence	Small business	Medium business	Large business
1	Failure to issue an invoice in electronic form	warning	warning	warning
2	Repeat of part 1 within a year	40 MCI = KZT 173,000	100 MCI = KZT 432,500	150 MCI = KZT 648,750
3	Issuing an e-invoice late	warning	warning	warning
4	Repeat of part 3 within a year	20 MCI = KZT 86,500	50 MCI = KZT 216,250	100 MCI = KZT 432,500
5	Absence of shipping documents stamped by the state revenue authorities on the export from Kazakhstan of listed goods, in breach of the goods movement accounting system	50 MCI = KZT 216,250 (no size diffe­rentia­tion)
6	Repeat of part 5 within a year	100 MCI = KZT 432,500 (no size diffe­rentia­tion)

The category “individuals” is absent from parts 1 to 4 of article 280-1 altogether. The sanctions are addressed only to small, medium and large business entities. Parts 5 and 6 draw no size distinction at all.

The “list” in parts 5 and 6 of article 280-1 is not the Virtual Warehouse list. The note to the article defines it by reference to the protocol on certain questions of the import and circulation of goods in the customs territory of the Eurasian Economic Union, ratified by the Law of 9 December 2015. The Code of Administrative Offences contains no offence directed specifically at breaches in the Virtual Warehouse module.

Article 283-1: Consignment Notes

There is no warning for a first offence here — the fine applies immediately.

Part of art. 283-1	Individuals	Small business / NPOs	Medium business	Large business
1 — failure to submit, or late submission of, a consignment note	5 MCI = KZT 21,625	10 MCI = KZT 43,250	20 MCI = KZT 86,500	30 MCI = KZT 129,750
2 — repeat of part 1	10 MCI = KZT 43,250	20 MCI = KZT 86,500	40 MCI = KZT 173,000	60 MCI = KZT 259,500
3 — mismatched name, inaccurate quantity, inaccurate PIN code	10 MCI = KZT 43,250	20 MCI = KZT 86,500	40 MCI = KZT 173,000	50 MCI = KZT 216,250
4 — repeat of part 3	20 MCI = KZT 86,500	40 MCI = KZT 173,000	60 MCI = KZT 259,500	100 MCI = KZT 432,500
5 — no consignment note issued; circulation without one (with confiscation)	20 MCI = KZT 86,500	50 MCI = KZT 216,250 (no NPOs)	100 MCI = KZT 432,500	200 MCI = KZT 865,000
6 — repeat of part 5 (with confiscation)	40 MCI = KZT 173,000	100 MCI = KZT 432,500 (no NPOs)	200 MCI = KZT 865,000	400 MCI = KZT 1,730,000

The non-commercial organisation category appears only in parts 1 to 4. Parts 5 and 6 are addressed to “small business entities” without the addition of non-commercial organisations.

Parts 5 and 6 carry confiscation of the ethyl alcohol, alcoholic products, certain types of petroleum products and biofuel that were the direct subject of the offence, “and/or the income and money obtained as a result of the administrative offence”.

Article 280: The Fictitious Invoice

The sanction is calculated as a percentage of the VAT rather than in MCI. Issuing a fictitious invoice attracts a fine of 100 per cent for small business entities, 200 per cent for medium and 300 per cent for large — of the value added tax included in the invoice. An invoice is fictitious where it is issued by a person not registered for VAT, or by a person who did not in fact ship the goods, perform the works or supply the services, and includes an amount of VAT.

The 2025 tax reform did not touch the Code of Administrative Offences. Article 280-1 stands as enacted by the Law of 28 December 2017 No. 127-VI, and article 283-1 as amended by the Law of 6 April 2024 No. 71-VIII. The reform’s companion statute, the Law of 18 July 2025 No. 215-VIII, amends other legislative acts and does not mention the Code of Administrative Offences at all.

The author’s assessment: the disproportion between articles 280-1 and 283-1 pushes attention to the wrong place. A first failure to issue an invoice draws a warning; a first failure to submit a consignment note draws a fine of KZT 21,625 to KZT 129,750, and failing to issue one at all draws KZT 86,500 to KZT 865,000 with confiscation of the goods. The practical consequence: for goods requiring a consignment note, the exposure sits on the note — which comes first in the sequence and is punished more heavily — not on the invoice.

A Step-by-Step Algorithm

Step 1. Identify your regulatory track. A VAT payer works from chapter 50 — articles 491 to 501. A non-payer checks whether it falls into one of the twelve cases in article 208(1); if not, no duty to issue an invoice arises at all.

Step 2. Check whether the goods sold appear in the Order No. 661 list. 353 entries by nomenclature code: alcohol and beverages, petroleum products and gases, organic and inorganic chemistry, and refrigeration equipment of heading 8418. If the goods are on the list, the invoice is issued through the Virtual Warehouse module.

Step 3. Check the consignment note list under Order No. 657 separately. Nine entries. Entries 1 to 7 are documented through the Module; entries 8 and 9 outside it. Remember that for such goods the invoice is issued on the basis of the note, stating its registration number in line 32.

Step 4. Replace references to repealed instruments. Article 413 → article 493 (deadlines); article 412 → articles 207, 208, 209, 491, 492; article 120-1 → article 88; article 136 → article 93; Order No. 370 → Order No. 629; Order No. 384 → Order No. 661; Order No. 1424 → Order No. 657. Contracts, accounting policies, internal procedures and system configurations all need reviewing.

Step 5. Register the participant in the e-invoice system under the correct status. For a legal entity this requires three simultaneous acts: the director’s digital signature as an individual, the entity’s digital signature carrying the director’s identification number, and the director passing biometric identification.

Step 6. Establish who actually issues the invoices, and confirm that person can pass biometrics. Articles 209(6) and 492(6) require the biometric data of the individual who issues the invoice, not of the director.

Step 7. Build a response to the biometric notification. The notification arrives inside the e-invoice system. The Rules set no numerical deadline for passing, so pass it immediately and record the fact and the time.

Step 8. Build the issuance calendar. Fifteen calendar days as the general rule; twenty calendar days for export; the 20th of the following month for utilities, communications, transport and forwarding; thirty calendar days on the recipient’s demand; and five calendar days from the date the VAT for a non-resident is paid on acquiring works and services from a non-resident.

Step 9. Review the suspension grounds that attach to the director. Seven of the fifteen grounds in article 88 — sub-paragraphs 7) to 12) and 14) — turn on the status of the first director or sole founder, including the expiry of a foreign national’s permitted period of stay.

Step 10. Reconcile Module balances against physical stock. Paragraph 6 of the Rules under Order No. 657 requires the “Balances” and “Production” data to match the actual quantity of stock held.

Common Mistakes and What They Cost

Mistake 1. Treating biometrics as a one-off step at registration. Participant registration and certification of an invoice on risk are two different grounds. The first concerns the director and happens once; the second concerns whoever issues the invoice and is triggered by the risk management system. Cost: when a risk fires, issuance stops because the person who physically holds the digital signature is not the one who passed biometrics at registration and is not ready to pass it now.

Mistake 2. Waiting for an explanation of why the risk fired. Article 93(3) declares the risk management procedure itself confidential and prohibits providing the information to taxpayers. The Code offers no separate route to challenge risk identification. Cost: time. While the company pursues an explanation, the article 493 deadline keeps running, and missing it is an offence under part 3 of article 280-1.

Mistake 3. Starting the document flow with the invoice for goods that require a consignment note. For entries 1 to 7 of the Order No. 657 list the invoice is issued on the basis of the note, and the note must be issued no later than the start of the movement of goods. Cost: two breaches at once — under article 283-1 the fine applies from the first offence, KZT 21,625 to KZT 129,750 for failing to submit the note and KZT 86,500 to KZT 865,000 with confiscation for failing to issue one — plus the practical impossibility of issuing the invoice, since line 32 requires the note’s registration number.

Mistake 4. Counting the five-day non-resident deadline from the date of the acceptance certificate. Article 493(9) ties the period to the day the VAT for the non-resident is paid into the budget, set-off included. Cost: on a repeat within a year, KZT 86,500 to KZT 432,500 under part 4 of article 280-1 — and because the first offence passed with only a warning, it often goes unnoticed inside the company.

Mistake 5. Leaving references to the old Code’s articles in contracts and accounting policies. Articles 412, 413, 120-1 and 136 lapsed with Code No. 120-VI. Cost: not a fine but procedures that no longer work — an internal rule pointing at a non-existent provision gives staff no deadline to work to, and evidences nothing in a dispute.

Mistake 6. Confusing the Virtual Warehouse list with the “List of Goods” in the Explanatory Note to the invoice form. The first is approved by Order No. 661 and determines the mechanism through which an invoice is issued. The second — the EAEU reduced-duty exemptions list — determines the origin marker in field 2. Cost: a wrong origin marker produces wrong entries in fields 4, 5, 18 and 19 and discrepancies that desk control picks up — and failure to comply with a desk-control notice is itself a ground for suspension under article 88(1)(15).

Mistake 7. Treating a Module balance discrepancy as a technical imprecision. Paragraph 6 of the Rules under Order No. 657 requires correspondence with actual quantities, and movement is monitored automatically. Cost: discrepancies surface without an inspector being involved and become material for desk control, with everything that follows up to and including suspension of issuance.

Mistake 8. Not tracking the status and permitted stay of a foreign director. Article 88(1)(12) makes the expiry of a permitted period of stay a free-standing ground for suspending e-invoice issuance for the whole company. Cost: invoicing stops across the entire business, and the suspension is published on the authorised body’s internet resource within one working day — an event visible to counterparties from a public source.

Who Is Affected, Who Is Not, and When Professional Review Is Needed

The changes reach any taxpayer with a duty to issue an invoice, whether or not it is registered for VAT.

Directly within scope:

•          VAT payers — on any turnover from the sale of goods, works or services;

•          non-VAT payers in the twelve categories of article 208(1), including taxpayers on the simplified declaration regime, commission agents, freight forwarders and customs representatives;

•          any company selling goods on the Order No. 661 list — 353 entries by nomenclature code;

•          companies moving goods that require a consignment note under the Order No. 657 list;

•          companies with a foreign first director — through the suspension grounds tied to his status.

A company is not outside scope merely because it:

•          operates under a special tax regime — the regime determines the regulatory track, not an exemption;

•          is not registered for VAT — exemption from chapter 50 is not exemption from articles 208 and 209;

•          has never received a biometric notification — the requirement arises on risk identification, not on a schedule;

•          is registered in the Astana International Financial Centre — the AIFC legal regime and the extent to which these tax rules apply to it require separate analysis beyond the scope of this article; the question is addressed in our comparison of the AIFC and the LLP.

Professional review is warranted in the following situations.

On a change of first director. Biometric identification of the new director is required under article 99(6) of the Code, together with re-registration of the participant under paragraph 11 of the Rules under Order No. 629 and monitoring of the suspension grounds in article 88(1)(7)–(12).

Where the director is a foreign national. A Kazakh individual identification number is needed for the entity’s digital signature, biometric data must exist in the National Register, and the permitted period of stay must be tracked continuously. Related questions are covered in our analyses of Kazakhstan residence permits and permits to attract foreign labour.

Where goods fall on both lists at once. Alcohol, petroleum products, liquefied gases and precursors require both a consignment note and an invoice, both through the Module, in a strictly determined sequence.

When integrating an accounting system with the Module. The field composition of the “Balances” and “Production” forms is not fixed by any normative legal act, and neither Order No. 629 nor Order No. 657 delegates it; the API route is provided for by paragraph 11 of the Rules under Order No. 657.

On acquiring works and services from a non-resident. The five-day period under article 493(9) runs from payment of the VAT for the non-resident, and the buyer’s-turnover construction overlaps with permanent establishment and withholding questions, covered in our analysis of withholding tax in Kazakhstan.

Frequently Asked Questions

What is Order No. 629 and from what date does it apply?

Order No. 629 of the Minister of Finance of the Republic of Kazakhstan of 28 October 2025, “On approval of the Invoice Issuance Rules and its form”, registered with the Ministry of Justice on 28 October 2025 under No. 37241. Paragraph 4 of the order: “This order comes into force from 1 January 2026 and is subject to official publication.” It was made under paragraph 2 of article 207 of the Tax Code and repealed Order No. 370 of 22 April 2019.

Is Order No. 370 on e-invoice issuance still in force?

No. Order No. 370 of the First Deputy Prime Minister — Minister of Finance of 22 April 2019 was repealed with effect from 1 January 2026 by paragraph 2 of the Rules under Order No. 629 and paragraph 1 of Appendix 3 to it. Five individual paragraphs of the amending orders were repealed at the same time, together with the whole of Order No. 1040 of 6 October 2022 — seven items in all.

Who exactly passes biometrics when an e-invoice is issued?

The individual who issues the electronic invoice. Articles 209(6) and 492(6) refer to that person, not to the director. The director’s biometrics is a separate requirement attaching to participant registration and to a change of director under article 99(6).

Is biometrics always required to issue an invoice?

No. Biometric certification is required only where a risk is identified in respect of the taxpayer on the basis of the risk management system under article 93 of the Code. Even then, identification is carried out once a day and three times in total, after which the system, under paragraph 27 of the Rules, “allows further e-invoices to be issued without it”.

Can a company find out why a risk fired against it?

No. Article 93(3) of the Tax Code classifies as confidential both the information obtained in risk management and the risk management procedure itself, and states expressly: “Providing that information to other persons, including taxpayers, is prohibited.” The previous Order No. 252, which published the non-confidential criteria, was repealed with effect from 1 January 2026 without replacement.

How long is allowed for passing biometric identification?

No numerical deadline is set in Order No. 629. The status “Biometric identification not passed in time” refers to “the period established in accordance with the requirements set by these Rules”, yet the Rules contain no such period. This figure is not confirmed by any official source. The only quantified parameters are once a day and three times in total.

What happens if biometrics is not passed?

The invoice cannot be issued. Paragraph 27 of the Rules: “where it is not passed, the e-invoice cannot be issued.” The invoice takes the status “Awaiting biometric identification”, then “Biometric identification not passed in time”, then “Deleted, biometric identification not passed”. No registration number is assigned, and without one the invoice does not count as sent under paragraph 28. The duty to issue an invoice does not lapse in the meantime.

What is the basic issuance deadline in 2026?

No earlier than the date the taxable turnover arises and no later than fifteen calendar days after that date — article 493(1) of the Tax Code. In the old Code this was article 413. Export carries twenty calendar days, utilities and communications the 20th of the following month, and the acquisition of works and services from a non-resident five calendar days from the date the VAT for the non-resident is paid.

What is the “Virtual Warehouse” module and which goods does it cover?

The Virtual Warehouse is a module of the electronic invoice information system designed to operate the goods traceability mechanism within Kazakhstan automatically. It applies to the 353 entries on the list approved by Order No. 661 of the Acting Minister of Finance of 31 October 2025: alcohol and beverages (247 entries), petroleum products and gases (38), organic chemistry and precursors (53), refrigeration equipment (11) and inorganic chemistry (4).

Did the Virtual Warehouse goods list change in 2026?

Not in substance. Order No. 661 reproduces the Order No. 384 list as it stood from 1 September 2025: the sets of nomenclature codes match exactly, with nothing added or removed. What changed is the legal basis — article 208(1)(10) of the new Code in place of article 412(3-1) of the old.

What is the fine for failing to issue an e-invoice in 2026?

A warning for a first offence, under part 1 of article 280-1 of the Code of Administrative Offences. On a repeat within a year of the first penalty — 40 MCI (KZT 173,000) for small business entities, 100 MCI (KZT 432,500) for medium and 150 MCI (KZT 648,750) for large. The MCI for 2026 is KZT 4,325.

On what grounds can the tax authority suspend e-invoice issuance?

Fifteen grounds are listed in article 88(1) of the Tax Code, among them failure to comply with a desk-control notice, failure to file VAT reporting, inclusion in the register of dormant taxpayers, and seven grounds tied to the status of the first director or sole founder, including the expiry of a foreign national’s permitted period of stay. Suspensions are published on the authorised body’s internet resource within one working day.

Must a buyer confirm a corrected or additional e-invoice?

It depends on whether it is a VAT payer. A VAT-registered recipient must confirm the issuance or reject it in case of disagreement, and the invoice “is regarded as issued where confirmation has been given by the recipient” (arts. 499(4)(1), 500(4)(1), 501(2)(1)). A recipient that is not a VAT payer may reject the issuance within ten calendar days, and if it does not, the invoice counts as confirmed.

Has the new Tax Code been amended since it was adopted?

Yes, once — by the Law of the Republic of Kazakhstan of 11 June 2026 No. 308-VIII, in force from 1 July 2026.The amendments are terminological and run through the whole text: “иностранец” was replaced by “иностранный гражданин” and “тенге” by “теңге” throughout. The invoice articles (207, 208, 209, 491, 492, 493, 499, 500, 501) and articles 88, 93 and 99 carry no amendment footnotes and stand in their original wording.

Key Takeaways

•          From 1 January 2026 the governing instruments are the new Tax Code No. 214-VIII of 18 July 2025 and the Invoice Issuance Rules approved by Order No. 629 of the Minister of Finance of 28 October 2025. The old Code No. 120-VI and Order No. 370 of 22 April 2019 have been repealed.

•          The Code has been amended once — by the Law of 11 June 2026 No. 308-VIII with effect from 1 July 2026— and the amendments are terminological and run through the whole text; the invoice articles and articles 88, 93 and 99 carry no amendment footnotes.

•          Confirmation of corrected, additional and recalled invoices is asymmetric: a VAT-registered recipient mustconfirm, and without confirmation the invoice does not count as issued, whereas a non-registered recipient mayreject within ten calendar days, and inaction means the invoice counts as confirmed.

•          The invoice provisions are split across two parts of the Code: articles 207 to 209 for non-VAT payers, chapter 50 (articles 491 to 501) for VAT payers; deadlines are common to both and sit in article 493.

•          The basic deadline is no earlier than the date of turnover and no later than fifteen calendar days after it. The shortest is five calendar days on acquiring works and services from a non-resident, running from the date the VAT for the non-resident is paid, set-off included.

•          Biometric certification of an e-invoice is the reform’s genuine novelty. It arises only where a risk is identified under article 93, is carried out once a day and three times in total, and without it the invoice cannot be issued.

•          The risk criteria are not published. Article 93(3) declares the risk management procedure itself confidential and prohibits providing that information to taxpayers; the previous Order No. 252 was repealed on 1 January 2026 without replacement.

•          The Rules set no numerical deadline for passing biometric identification, and no official source confirms one.Failure to pass does not, however, extinguish the duty to issue the invoice.

•          Registration of a legal entity in the system requires three simultaneous acts: the director’s digital signature as an individual, the entity’s digital signature carrying his identification number, and the director passing biometric identification.

•          The Virtual Warehouse covers the 353 entries of the Order No. 661 list, which is substantively identical to the earlier Order No. 384 list; only the legal basis changed.

•          For goods requiring a consignment note, the invoice is issued on the basis of that note, stating its registration number in line 32; entries 8 and 9 of the list are documented outside the Module.

•          Suspension of e-invoice issuance now has fifteen grounds under article 88 against one under the old article 120-1, and seven of them — sub-paragraphs 7) to 12) and 14) — attach to the status of the first director or sole founder.

•          Failure to issue an e-invoice, and late issuance, carry a warning for a first offence and 20 to 150 MCI on a repeat within a year; consignment note offences are fined from the first occurrence. The 2026 MCI is KZT 4,325.

•          The 2025 tax reform did not touch the Code of Administrative Offences: article 280-1 stands as enacted in 2017 and article 283-1 as amended in 2024.

Summary 

From 1 January 2026 the issuance of invoices in Kazakhstan is governed by the Tax Code of the Republic of Kazakhstan of 18 July 2025 No. 214-VIII and by the Invoice Issuance Rules approved by Order No. 629 of the Minister of Finance of 28 October 2025 (Ministry of Justice registration No. 37241); the earlier Rules under Order No. 370 of 22 April 2019 and Tax Code No. 120-VI have been repealed. The duty to issue an invoice is imposed by article 207 and splits into two tracks: articles 208 and 209 for non-VAT payers and chapter 50 (articles 491 to 501) for VAT payers. Deadlines are common to both and sit in article 493: the general rule is no earlier than the date the turnover arises and no later than fifteen calendar days after it; twenty calendar days on export; the 20th of the following month for utilities, communications and transport; thirty calendar days on the recipient’s demand; and five calendar days from the day the VAT for a non-resident is paid where works or services are acquired from that non-resident. The principal novelty is biometric certification of the electronic invoice under articles 209(6) and 492(6): it applies where a risk is identified in respect of the taxpayer under the article 93 risk management system, is carried out once a day and three times in total, and without it the invoice cannot be issued; the risk criteria are not published, because article 93(3) declares the risk management procedure itself confidential. The “Virtual Warehouse” module covers the 353 entries on the list approved by Order No. 661 of the Acting Minister of Finance of 31 October 2025, and for goods requiring a consignment note under Order No. 657 the invoice is issued on the basis of that note, stating its registration number in line 32. Confirmation of corrected, additional and recalled invoices differs under articles 499, 500 and 501: a VAT-registered recipient must confirm the issuance, and the invoice counts as issued only where confirmation has been given, whereas a non-registered recipient may reject it within ten calendar days, with inaction meaning the invoice counts as confirmed. Suspension of e-invoice issuance is available on the fifteen grounds in article 88. Liability sits in articles 280, 280-1 and 283-1 of the Code of Administrative Offences: failure to issue and late issuance draw a warning for a first offence and 20 to 150 MCI on a repeat within a year, with the MCI set at KZT 4,325 for 2026.

The move to the new Tax Code reaches well beyond invoices: deadlines, article numbers, the set of special tax regimes and the VAT registration procedure have all changed. UPPERSETUP advises on business registration and ongoing support in Kazakhstan, including value added tax registration and configuring tax accounting to the 2026 requirements.

Sources

Primary sources — legislation

•          Tax Code of the Republic of Kazakhstan of 18 July 2025 No. 214-VIII — current text on the Adilet portal

•          Tax Code of the Republic of Kazakhstan of 25 December 2017 No. 120-VI — repealed with effect from 1 January 2026

•          Code of the Republic of Kazakhstan on Administrative Offences of 5 July 2014 No. 235-V — articles 280, 280-1, 283-1

•          Law of the Republic of Kazakhstan of 8 December 2025 No. 239-VIII “On the republican budget for 2026–2028”— article 7, the monthly calculation index

•          Law of the Republic of Kazakhstan of 18 July 2025 No. 215-VIII — the tax reform’s companion statute

Primary sources — subordinate instruments in force

•          Order No. 629 of the Minister of Finance of 28 October 2025, “On approval of the Invoice Issuance Rules and its form” — Ministry of Justice registration No. 37241

•          Order No. 657 of the Acting Minister of Finance of 31 October 2025 — the list of goods requiring consignment notes and the rules for issuing them, registration No. 37317

•          Order No. 661 of the Acting Minister of Finance of 31 October 2025 — the Virtual Warehouse goods list

Primary sources — subordinate instruments repealed or no longer applied

•          Order No. 370 of the First Deputy Prime Minister — Minister of Finance of 22 April 2019 — the previous e-invoice issuance rules

•          Order No. 384 of the First Deputy Prime Minister — Minister of Finance of 23 April 2019 — the previous Virtual Warehouse goods list; its status in the register is “Updated”, with no repeal marker

•          Order No. 252 of the Minister of Finance of 20 February 2018 — rules for applying the risk management system on criteria that are not confidential information

•          Order No. 586 of the Minister of Finance of 9 October 2025 — the instrument repealing Order No. 252

•          Order No. 568 of the Minister of Finance of 3 October 2025 — rules on the use of biometric identification tools; not repealed but expired under its own paragraph 4 — “applies until 31 December 2025 inclusive”

•          Order No. 294 of the Deputy Prime Minister — Minister of Finance of 27 March 2023 — the biometric identification pilot project

Official regulator resources

•          State Revenue Committee of the Ministry of Finance — information materials on the e-invoice system

•          State Revenue Committee — documents on the e-invoice system

•          National Certification Authority of Kazakhstan — instructions for biometric identification

Notes on Verification

The texts of Tax Code No. 214-VIII, Order No. 629 (including Appendices 1, 2 and 3), Order No. 657, Order No. 661 and the Code of Administrative Offences were checked word for word against the Adilet legal information system — the official normative legal acts portal of the Republic of Kazakhstan. The portal is closed to automated access, so the texts were obtained through a browser. The database state at the time of checking: documents as at 21 August 2026.

Amendment check. The amendment history of Tax Code No. 214-VIII contains three entries: “New” of 18 July 2025 and two entries relating to a single instrument — the Law of 11 June 2026 No. 308-VIII, in force from 1 July 2026. Amendment footnotes were checked individually on each of articles 36, 81, 84, 88, 93, 99, 179, 180, 206, 207, 208, 209, 460, 491, 492, 493, 499 and 848; none carries one. The amendments made by Law No. 308-VIII are terminological and run through the whole text. The amendment histories of Orders No. 629, No. 657 and No. 661 and of budget law No. 239-VIII each contain a single “New” entry, and their texts carry no footnotes. No instrument revising the 2026 republican budget so as to change the monthly calculation index could be found.

Levels of confirmation, distinguished. Instrument numbers, dates and registration numbers, article and paragraph numbers, deadlines, sanction levels in MCI, the list of suspension grounds, the set of e-invoice statuses and the quantified parameters of the biometric procedure are all confirmed from primary texts. The 2026 MCI is confirmed from article 7 of the republican budget law. The composition of the Virtual Warehouse list — 353 entries and their distribution across nomenclature chapters — was obtained by a complete count over the text of Order No. 661.

What no official source confirms. Order No. 629 contains no numerical deadline for how long an invoice remains in the status “Awaiting biometric identification”, nor any statement of when it moves to “Deleted”; an exhaustive search of Appendix 1 found no figure attached to that period. Whether a deleted invoice can be re-issued is not regulated by the Rules. No alternative registration procedure is described for persons covered by the exemptions in paragraph 10. No instrument repealing Order No. 384 of 23 April 2019 could be located in primary sources: Appendix 3 to Order No. 629 does not list it, Order No. 661 contains no repealing clause, and as at 21 August 2026 the Adilet database does not mark Order No. 384 as repealed. The field composition of the “Balances” and “Production” forms is not fixed by any normative legal act that could be located; paragraph 13 of the Rules under Order No. 657 refers to the technical description of the consignment note structure but not of these forms, and neither Order No. 629 nor Order No. 657 delegates the matter.

On unreachable sources. The esf.gov.kz portal did not respond from the network environment used (no connection established), and the host isesf.kgd.gov.kz does not resolve in the domain name system and cannot be treated as an official source. The State Revenue Committee’s materials on biometric identification are dated 2023 and published as .rar and .docx files; no current 2026 guidance on biometric identification deadlines could be found. Nor does the register contain a successor to Order No. 568, which expired on 31 December 2025.

On outdated sources. As at the date of checking, the State Revenue Committee’s “Documents on the e-invoice system” page still links to the repealed Order No. 370 of 22 April 2019. Guidance and materials resting on that order, on articles 412, 413, 120-1 and 136 of the old Tax Code, or on Orders No. 252 and No. 384, are not treated as current law in this article and are cited only as repealed instruments for the purposes of comparison.

Information current as at August 2026.

Disclaimer

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

Published: August 2026.