Kazakhstan’s special economic zones and industrial zones in 2026: benefits, participation and the risk of losing the status

A special economic zone (SEZ) in Kazakhstan is a precisely delimited part of the national territory on which legal entities entered in the unified register of participants enjoy a special legal regime: a 100 per cent reduction of corporate income tax, a zero coefficient on land tax and the land-use fee, a zero rate of property tax, the free customs zone procedure and land granted free of charge. The regime rests on the Law of the Republic of Kazakhstan No. 242-VI of 3 April 2019 “On Special Economic and Industrial Zones”, chapter 80 of the Tax Code No. 214-VIII of 18 July 2025 and chapter 29 of the Code “On Customs Regulation”. An industrial zone is a different instrument: a territory with ready engineering infrastructure where a participant receives land and utilities but no tax preferences. As at September 2026 Kazakhstan has 18 SEZs and 67 industrial zones on the unified register.

Alert. From 25 August 2026 Law No. 324-VIII tightened the terms of participation: missing the deadlines for design, construction or commissioning for more than three consecutive months (previously six) entitles the management company to terminate the activity agreement unilaterally, and on termination every tax preference is annulled from the beginning of the tax period in which the breach occurred, with additional tax returns due within 30 calendar days. The same law abolished the “non-core activities” regime and cut the share of an SEZ’s territory that may be used for auxiliary activities from 50 per cent to 20 per cent.

The regime’s key parameters in 2026: the summary table

Parameter	Value	Source
CIT reduction on income from priority activities	100 %	art. 735(4), Tax Code
Land tax and land-use fee	coefficient 0	art. 735(1), art. 582(2)(2), Tax Code
Property tax	rate 0 on the tax base	art. 735(1), art. 592(5)(2), Tax Code
Duration of preferences, category A (project up to 3,000,000 MCI)	7 years	art. 735(10), Tax Code; art. 51(2), Law No. 242-VI
Duration, category B (3,000,000 to 14,500,000 MCI)	15 years	same
Duration, category C (from 14,500,000 MCI)	25 years	same
Category B threshold for food, textiles, clothing, leather, electronics and electrical equipment	from 1,000,000 MCI	art. 51(2), part two, Law No. 242-VI
Monthly calculation index (MCI) from 1 January 2026	KZT 4,325	art. 7, Law on the Republican Budget for 2026–2028
Financial security on application	at least 10 % of project value	art. 18(16), Law No. 242-VI
Security for the remaining project value	2 years; 3 years for projects above 15,000,000 MCI	art. 18(17), Law No. 242-VI
Time for the management company to sign the agreement	10 working days from the application	art. 18(10), Law No. 242-VI
Entry on the unified register and certificate	5 working days after receipt of the agreement	art. 18(12), Law No. 242-VI
Unilateral termination threshold for construction delay	more than 3 consecutive calendar months	art. 20(3)(1), Law No. 242-VI
Suspension of activity without approval	more than 2 calendar months	art. 20(3)(2), Law No. 242-VI
Period to cure breaches under the management company’s act	not more than 60 calendar days	art. 20(2), Law No. 242-VI
Annulment of tax preferences on termination	from the start of the tax period in which the breach occurred	art. 735(3), Tax Code
Completion of the free customs zone procedure on loss of status	6 months	art. 287(1)(2), Code on Customs Regulation
Stability of the tax regime against adverse changes	not more than 10 years from the first such change	art. 735(12), Tax Code
Exemption from forei­gn-la­bour permits	projects above 1,000,000 MCI, for the construction period and 1 year after commissioning	art. 36-1(2)(4), Law on Migration

What an SEZ is, and how it differs from an industrial zone

An SEZ and an industrial zone are two different instruments under the same statute, and the decisive difference between them is fiscal: an SEZ participant receives tax preferences, an industrial zone participant does not. Both are governed by Law No. 242-VI of 3 April 2019, but chapter 3 of the Law deals with SEZs and chapter 4 with industrial zones.

The statutory definitions

A special economic zone is, under sub-paragraph 2) of article 1 of Law No. 242-VI, “a part of the territory of the Republic of Kazakhstan with precisely designated boundaries, on which the special legal regime of a special economic zone operates for the conduct of activities in accordance with this Law”.

An SEZ participant is, under sub-paragraph 4) of article 1, “a legal entity carrying on priority activities on the territory of a special economic zone and entered in the unified register of participants of special economic zones”. Two exceptions are built into the definition itself: participants of the SEZ “Park of Innovative Technologies” may carry on priority activities outside the zone’s territory, and individual entrepreneurs may be participants of a border SEZ situated on the EAEU customs frontier.

An industrial zone is, under sub-paragraph 9) of article 1, “a territory provided with engineering and utility infrastructure, made available to private business entities for the placement and operation of business facilities, including in industry, the agro-industrial complex, the tourism industry, transport logistics and waste management”.

An industrial zone participant is, under sub-paragraph 11), an individual entrepreneur or legal entity with which the industrial zone’s management company has concluded an activity agreement.

Different purposes, different mechanics

Article 9 of Law No. 242-VI separates the purposes in terms. An SEZ is created “for the accelerated development of modern high-productivity, competitive production, the formation of a qualitatively new level of services, the attraction of investment, the introduction of new technologies into sectors of the economy and regions, and the increase of employment”. A border SEZ is additionally created to develop cross-border trade, transport infrastructure, tourism and cultural interaction. An industrial zone is created “for the infrastructural support of the development of entrepreneurship in the regions” — and for nothing else.

The status follows from the purpose. An SEZ participant must carry on a priority activity from the list approved by the authorised body for that specific zone; an industrial zone participant carries on any business activity admitted by the regional coordination council. An SEZ participant passes through the unified register and receives a certificate; an industrial zone participant has only a contract with the management company.

The special legal regime

Article 50 of Law No. 242-VI defines the special legal regime of an SEZ as the set of conditions of the zone’s operation for its participants under that Law and under tax, customs and land legislation and the legislation on employment. The SEZ regime is therefore built from five layers of law at once, and each of them is examined in its own chapter of this article.

For industrial zones the Law establishes no special legal regime. Their advantage is ready infrastructure funded by the budget or a private owner, a guarantee of stability of concluded agreements (article 27(8)), and the right of a participant of a state industrial zone to buy its land plot outright (article 34(5)).

The normative base: which instruments are in force, and in what version

Kazakhstan’s SEZ regime is built from four tiers of instruments: the statute on zones, the Tax Code, the customs legislation of the EAEU and of Kazakhstan, and the Government resolutions creating each individual zone. The composition of the base as at 1 September 2026 is set out below.

Instrument	Details	Role	Key provisions
Law of the RK “On Special Economic and Industrial Zones”	No. 242-VI of 3 April 2019; published 5 April 2019; in operation ten calendar days after publication; current version from 25 August 2026	The primary statute: creation of zones, parti­cipa­tion, the agreement, loss of status, industrial zones	arts. 1, 9, 17, 18, 20, 24, 25, 26–35-1, 41, 42, 50–53, 58
Tax Code of the RK	No. 214-VIII of 18 July 2025; in operation from 1 January 2026	Tax preferences for participants and management companies	arts. 734, 735 (chapter 80), 470, 471, 474, 479, 525, 582, 592
Code of the RK “On Customs Regulation in the Republic of Kazakhstan”	No. 123-VI of 26 December 2017	The free customs zone procedure	arts. 281–291 (chapter 29), art. 558
Customs Code of the EAEU	annex to the Treaty of 11 April 2017; ratified by Law of the RK No. 115-VI of 13 December 2017	The supranational basis of the free customs zone procedure	arts. 201–210 (chapter 27)
Law of the RK “On Population Migration”	No. 477-IV of 22 July 2011	Exemption of SEZ participants from forei­gn-la­bour quotas and permits	art. 36-1(2)(4)
Entre­preneu­rial Code of the RK	No. 375-V of 29 October 2015	The relationship between SEZs and investment preferences	art. 283-1(4)(3)
Order of the Minister of Industry and Construction	No. 72 of 22 February 2024, MoJ No. 34030; last amended by orders No. 40 of 04.02.2026 and No. 96 of 12.03.2026	The Rules for maintaining, and the List of, priority activities by SEZ	annexes 1 and 2
Order of the Minister of Industry and Infra­stru­cture Development	No. 599 of 31 July 2019, MoJ No. 19187; amended by order No. 25 of 27.01.2026	The Rules and Criteria for project selection	annexes 1 and 2
Government resolutions creating each SEZ	18 instruments, from Presidential Decree No. 645 of 29 June 2001 to Government Resolution No. 301 of 21 April 2026	Boundaries, term, purposes and target indicators of the specific zone	the Regulation on the SEZ

The amendment chain of Law No. 242-VI

Law No. 242-VI replaced the Law of the RK of 21 July 2011 “On Special Economic Zones in the Republic of Kazakhstan” (article 59(2)). Since 2019 twelve laws have amended it, and three of them define the regime as it stands today.

Law No. 177-VII of 30 December 2022 — the largest amendment (25 references in the text): restated articles 18, 20 and 42, introduced the financial security of the project and the participants’ annual reporting.

Law No. 46-VIII of 12 December 2023 — restated article 51 and introduced, from 1 January 2024, categories A, B and C by project value, to which the Tax Code ties the 7-, 15- and 25-year preference periods.

Law No. 324-VIII of 24 June 2026 “on the development of machine building and transport” — published 25 June 2026, in operation from 25 August 2026 (26 references in the text): abolished the non-core activities regime, introduced statutory selection criteria for manufacturing, made the counter-obligation mandatory, cut the construction-delay threshold from six months to three and the auxiliary-territory share from 50 to 20 per cent.

The remaining amendments: Law No. 399-VI of 02.01.2021 (public-private partnership in zones), Law No. 26-VII of 01.04.2021 (special industrial zones), Law No. 87-VII of 27.12.2021, Law No. 223-VII of 19.04.2023, Law No. 188-VIII of 19.05.2025, Law No. 196-VIII of 24.06.2025, Law No. 220-VIII of 27.09.2025, Law No. 256-VIII of 09.01.2026 (a terminological substitution of “digital” for “information and communication” in articles 18 and 58; in operation six months after publication on 10 January 2026) and Law No. 321-VIII of 24.06.2026 (science-intensive territories; in operation from 25 August 2026).

Three tiers that must not be confused

The CIT, land and property preferences exist only in the Tax Code (article 51 of Law No. 242-VI merely refers to it and sets the categories). The customs preference exists only in customs legislation (articles 52–53 of Law No. 242-VI merely record that the procedure applies). The foreign-labour exemption exists only in the Law on Population Migration (article 54 of Law No. 242-VI merely refers to it). The Law on zones creates no preference of its own — it creates a status to which other instruments attach preferences. That is precisely why losing the status under the Law on zones brings down all three tiers at once.

The map of the regime: Kazakhstan’s 18 SEZs in 2026

As at 1 September 2026 Kazakhstan has 18 special economic zones created and in operation; three of them appeared in 2025, one more in April 2026, and the oldest — “Astana – New City” — has operated since 1 January 2002. In April 2026 the Ministry of Industry and Construction reported 17 zones in 14 regions; the eighteenth, the “Industrial Trade and Logistics Complex ‘Alatau’”, was created by Government Resolution No. 301 of 21 April 2026.

SEZ	Region	Creating instrument	Term of operation	Area	Feature
Astana – New City	Astana	Presidential Decree No. 645 of 29.06.2001 (in force from 01.01.2002); Regulation — Government Resolution No. 772 of 24.11.2017	until 2027	15,264.135 ha	the largest by number of participants
Astana­-Techno­polis	Astana	Government Resolution No. 772 of 24.11.2017	until 2042	2,303.185 ha, including the international airport	port SEZ
Almaty Innovation & Financial Zone (until 22.06.2026 the “Park of Innovative Techno­lo­gies”)	Almaty	Presidential Decree No. 1166 of 18.08.2003; Government Resolution No. 538 of 22.06.2026 renaming and extending it	until 31 December 2049 (extended from 1 January 2028)	256.05 ha	participants may carry on priority activities outside the zone
Seaport Aktau	Mangystau region	Presidential Decree No. 853 of 26.04.2002 (in force from 01.01.2003); Regulation — Government Resolution No. 624 of 06.10.2017	until 1 January 2028	10,384.1178 ha, including Aktau international airport	port SEZ
Ontustik	Shymkent	Presidential Decree No. 1605 of 06.07.2005; Regulation — Government Resolution No. 624 of 06.10.2017	until 1 July 2030	529.0001 ha, including Shymkent international airport	port SEZ
National Industrial Petrochemical Technopark	Atyrau region	Presidential Decree No. 495 of 19.12.2007; Regulation — Government Resolution No. 548 of 11.08.2021	until 31 December 2032	4,551.0404 ha	petro­che­micals
Pavlodar	Pavlodar region	Presidential Decree No. 186 of 29.11.2011; Regulation — Government Resolution No. 624 of 06.10.2017	until 1 December 2036	1,200 ha	chemicals, petro­chemi­cals, metallurgy
Saryarka	Karaganda and Bukhar-Zhyrau district	Presidential Decree No. 181 of 24.11.2011; Regulation — Government Resolution No. 277 of 28.04.2021	until 1 December 2036	1,271.626 ha, including Sary-Arka airport	port SEZ
Khorgos – Eastern Gate	Zhetisu region	Presidential Decree No. 187 of 29.11.2011; Regulation — Government Resolution No. 495 of 01.07.2025	until 2035	5,431.5 ha	logistics SEZ
International Centre for Cross-Border Cooperation “Khorgos”	Zhetisu region	Government Resolution No. 624 of 06.10.2017	until 2041	608.56 ha	on the EAEU customs frontier; individual entrepreneurs admitted; foreign persons excluded
Jibek Joly (until 2020 “Chemical Park Taraz”)	Zhambyl region, Shu district	Presidential Decree of 2012 creating the zone; Regulation — Government Resolution No. 713 of 28.10.2020 (as amended by Resolution No. 1072 of 10.12.2025)	until 1 January 2037	1,205 ha	chemical products
TURAN (until 2020 “TURKISTAN”)	Turkestan region	Government Resolution No. 693 of 29.10.2018 (as amended by Resolution No. 892 of 10.10.2023)	until 2043	3,603.3 ha	tourism, construction, processing
Qyzyljar	North Kazakhstan region	Government Resolution No. 758 of 11.10.2019	until 2044	984.3 ha	machine building, vehicle assembly; special import-VAT rule
Alatau	Almaty region (the cities of Qonaev and Alatau, Talgar and Ili districts)	Government Resolution No. 211 of 15.03.2023 (as amended by Resolutions No. 1187 of 26.12.2023 and No. 990 of 20.11.2025)	until 2048	98,982.98 ha	port SEZ; the largest by area
Aktobe	Aktobe region	Government Resolution No. 3 of 08.01.2025	until 31 December 2049	1,610 ha, including Aktobe international airport	port SEZ; four sub-zones in the region’s districts
Korkyt Ata	Kyzylorda region	Government Resolution No. 336 of 14.05.2025	until 31 December 2049	550 ha	port SEZ; on the “Western Europe – Western China” corridor
Atyrau	Atyrau region (the city of Atyrau and Zhylyoi district)	Government Resolution No. 1028 of 01.12.2025	until 31 December 2036	450 ha	the region’s second zone after the petrochemical technopark
Industrial Trade and Logistics Complex “Alatau”	Zhambyl region, Kordai district	Government Resolution No. 301 of 21.04.2026	until 31 December 2051	165 ha	the newest zone; trade and logistics profile

What the map tells you

First. The two oldest zones are close to expiry: “Astana – New City” in 2027 and “Seaport Aktau” on 1 January 2028. Under article 24(1) of Law No. 242-VI an SEZ is abolished on expiry of the term for which it was created, and under article 24(2) its territory acquires the status of an industrial zone of republican significance and its participants become industrial zone participants — that is, without tax preferences. Extension is possible by Government decision where more than 20 per cent of the territory is undeveloped or where there are potential investors (article 17(1), part two). No extension instrument for “Astana – New City” appears in the Adilet database as at 1 September 2026, and the official Invest in Astana portal states that “the term of the SEZ «Astana – New City» expires in 2027”.

Second. Seven zones — Astana-Technopolis, Seaport Aktau, Ontustik, Saryarka, Alatau, Aktobe and Korkyt Ata — hold port SEZ status, and Khorgos – Eastern Gate is a logistics SEZ. For customs purposes that matters: under article 281(3) of the Code on Customs Regulation, EAEU goods brought into a port or logistics SEZ are placed under the free customs zone procedure compulsorily, whereas in an ordinary SEZ placement is at the participant’s option.

Third. The List of priority activities (order No. 72 of 22 February 2024 in the version of 12 March 2026) contains sections for 16 zones and contains no section for the SEZs “Atyrau” and “ITLC ‘Alatau’”. Since under article 734(1)(4) of the Tax Code preferences are available only for a priority activity taken from that List, participants of the two newest zones cannot apply the tax preferences until the corresponding sections are added. The procedure for adding an activity to the List is set by article 19 of Law No. 242-VI.

Who can become an SEZ participant, and who is barred

Only a legal entity (in a border SEZ, also an individual entrepreneur) that does not fall within the six excluded categories in article 18(2) of Law No. 242-VI may become an SEZ participant, and only a participant that simultaneously meets the four conditions of article 734(1) of the Tax Code receives the tax preferences. The two lists — statutory and fiscal — do not coincide fully, and that has to be kept in mind from the outset.

Who may not apply: article 18(2) of Law No. 242-VI

The following are not eligible applicants for SEZ participant status:

•          subsoil users;

•          organisations producing excisable goods, except the production and assembly of the excisable goods in sub-paragraph 6) of article 536 of the Tax Code — that is, motor vehicles with an engine capacity above 3,000 cc(this carve-out is what makes vehicle-assembly projects in SEZs possible);

•          organisations and individual entrepreneurs applying special tax regimes;

•          organisations applying investment tax preferences under uncompleted contracts concluded with the authorised investment body before 1 January 2009;

•          organisations implementing, or that have implemented, an investment priority project or an investment strategic project under the investment legislation;

•          organisations in the gambling business.

For a border SEZ on the EAEU customs frontier, foreign natural and legal persons are additionally excluded (article 18(2), part two).

Who gets no preferences even after admission: article 734(3) of the Tax Code

The Tax Code reproduces that list with two extensions. Sub-paragraph 4) of article 734(3) excludes organisations implementing an investment strategic project and also those that have concluded an investment agreement, an agreement on investment obligations or an agreement on the processing of solid minerals. Sub-paragraphs 6) and 7) add participants of Astana Hub and participants of the AIFC.

The mirror-image rule sits in the Entrepreneurial Code: sub-paragraph 3) of article 283-1(4) bars organisations operating in an SEZ from an investment agreement. The SEZ regime and the investment-agreement regime exclude each other at the level of the entity, not of an individual asset. The investment agreements themselves are covered in our guide to investment preferences and the investment contract in Kazakhstan in 2026.

The four conditions of fiscal status: article 734(1)

For the purposes of the preferences, an organisation operating on the territory of an SEZ is a legal entity that simultaneously:

1.        is an SEZ participant under Law No. 242-VI;

2.        is registered as a taxpayer at its location with the tax authority on the territory of the SEZ or with the territorial unit whose competence covers the zone (the system of tax authorities includes separate “territorial units on the territories of special economic zones” for this purpose — article 42(2)(4) of the Tax Code);

3.        has no branches or other separate structural units outside the SEZ, other than representative offices, provided the zone has the necessary infrastructure and facilities;

4.        carries on, on the SEZ territory, a priority activity meeting the purposes of the zone, identified by the general classifier of economic activities.

The third condition is the most underestimated. A company with a production site in an SEZ and a warehouse-branch in another city loses the preferences entirely. The only permissible presence outside the zone is a representative office. The difference between a branch and a representative office under Kazakh law is set out in our guide to the branch and representative office of a foreign company versus an LLP in Kazakhstan.

A separate track for the border SEZ

Article 734(2) repeats the same conditions for participants of a zone whose boundaries coincide with the EAEU customs frontier (today the ICBC “Khorgos”), with one difference: the ban on branches is unconditional there rather than “where infrastructure exists”. In return, an individual entrepreneur on the general tax regime may be a participant — and article 735(5) gives such a participant a 100 per cent reduction of individual income tax.

How participant status is obtained: application, selection, register

SEZ participant status is acquired in two steps: an activity agreement with the zone’s management company, signed within 10 working days of the application, and entry on the unified register of participants with issue of a certificate, which the unified coordination centre effects within 5 working days of receiving a copy of the agreement. The right to tax preferences arises only once the certificate is received (article 18(13) of Law No. 242-VI).

The document package: article 18(3)

Eleven items accompany the application: the applicant’s questionnaire in the authorised body’s form; the certificate of state registration of the legal entity; a copy of the chief executive’s identity document; a copy of the charter; a copy of the supreme body’s decision to operate in the SEZ; a copy of the financial statements for the last financial year (for an entity trading less than 12 months, as at the last reporting date); a feasibility study meeting the authorised body’s requirements (a project justification for digital and innovative technology projects); the servicing bank’s statement of cash movements and a credit report from a credit bureau; a certificate from the state revenue authority on the presence or absence of tax arrears; confirmation of the project’s financial security; and a sketch plan of the territory where construction is required.

Under paragraph 2 of the Rules for project selection (order No. 599 of 31 July 2019) a foreign legal entity submits legalised documents and a legalised extract from the commercial register with a notarised translation into Kazakh and Russian; a non-resident not registered as a taxpayer submits a certificate of the absence of such registration.

The selection criteria: three tiers

The statutory tier. From 25 August 2026, part two of article 18(6) requires prospective participants in manufacturing to meet one of two criteria: production of goods whose production is absent in Kazakhstan, or production of goods whose domestic production does not cover domestic demand. This is a statutory filter against duplicating existing capacity.

The main criteria of order No. 599. No overdue bank debt (evidenced by the bank statement and credit report) and no tax arrears.

The additional criteria of order No. 599. Promotion of similar projects in other regions; an import-substituting or export-oriented orientation; implementation of an industrial-innovation project. Under paragraph 5 of the Rules, applicants meeting the main criteria and at least one additional criterion have priority in concluding an agreement; where several compete, the one meeting more additional criteria prevails.

Refusal and its grounds

Under article 18(7) the management company refuses where the declared activity — including activities within a single technological process — does not match the purposes of the zone, the priority activities or the selection criteria, or where the documents do not meet paragraphs 3 and 4. A reasoned refusal is sent to the applicant in writing and posted on the unified coordination centre’s website within 10 working days (paragraph 9).

The content of the agreement

From 25 August 2026 article 18(10) requires the activity agreement to contain the project implementation schedule with activities and deadlines, the production and planned capacity of the project, and — for manufacturing participants — the participant’s counter-obligation under Kazakh legislation. Construction and commissioning deadlines are a mandatory term of the agreement and of the land-use contracts (article 17(9)).

Register, certificate, tax registration

A copy of the agreement goes to the unified coordination centre no later than the next working day (paragraph 11). The centre enters the applicant on the unified register of SEZ participants and issues the certificate within 5 working days, and within one working day notifies the participant, the management company and the state revenue authorities (paragraph 12). Under article 36 of Law No. 242-VI the unified coordination centre is a legal entity accountable to the authorised body; in practice the function is performed by the directorate for the development of special economic and industrial zones of JSC “Kazakhstan Centre of Industry and Export ‘QazIndustry’”, and the authorised body is the Ministry of Industry and Construction.

A special case is an activity missing from the List. Under article 19 a prospective participant or the management company may apply to the authorised body to add the activity to the priority list, attaching a project passport, an analysis of the socio-economic effect and calculations of the notional losses of the republican and local budgets.

Financial security and counter-obligations: the price of entry

On application a participant must evidence financial security of at least 10 per cent of the project’s value, and within two years security for the entire remaining value; for projects worth more than 15,000,000 MCI the period is three years. Breach of these requirements is a free-standing ground for terminating the agreement under article 20(1) of Law No. 242-VI.

Five forms of security: article 18(16)

The applicant evidences security by one or more of five means: money; a bank guarantee; a suretyship with the surety’s funds evidenced by the same means; a pledge of property; an insurance contract. The Law expressly allows the means to be combined.

The remainder: article 18(17)

Security for the remaining value of the project is provided within two years of obtaining participant status. For a participant whose project exceeds 15,000,000 MCI (at the 2026 MCI of KZT 4,325, that is KZT 64,875,000,000), the period is three years. The security covers the part of the project value not yet implemented at the time of provision, so funds already invested are deducted.

The counter-obligation

From 25 August 2026 an agreement with a manufacturing participant must contain a counter-obligation (article 18(10), part three). Law No. 324-VIII, which introduced the requirement, at the same time added four items to the list of counter-obligations in article 27(3) of the Law “On Industrial Policy” — development of local content, increasing the complexity of the production process, use of goods of Kazakh origin in the construction of facilities, and use of domestic raw materials and materials in the output — and inserted into article 25(5) of the same Law an assessment of the balance of production capacity as a condition for granting industrial-stimulation measures. The specific scope of the counter-obligation is fixed in the agreement and becomes a term whose breach carries the consequences of article 20.

Three rights that balance the requirements

The right to adjust the schedule. Sub-paragraph 5-1) of article 41(1) (inserted by Law No. 324-VIII) allows a participant to amend the project implementation schedule not more than three times during the project, for no longer than the SEZ’s term, provided the obligations of the preceding stages have been performed.

The right to reserved land. Under article 17(3), part six, the management company must reserve part of the land plot for the project’s stages, and reserved plots may not be transferred to others without the participant’s consent — except where the participant itself has failed to perform its phased obligations.

The right to stability. Under article 735(12) of the Tax Code, where adverse changes are made to the size of the reductions in CIT, IIT, land tax, property tax or the land-use fee, the participant applies the provisions of chapter 80 in force on the date its agreement was concluded, for the term of the agreement but for no more than ten years from the day the first such change took effect. The guarantee does not apply where the management company terminates the agreement unilaterally.

Annual reporting and monitoring

A participant must submit an annual report on its activities to the management company (article 41(2)(1)). Monitoring under article 42 is carried out by three actors: the management company continuously, on the basis of primary documentation and annual reports; local executive bodies and the unified coordination centre, on the basis of the management companies’ reporting; and, from 25 August 2026, the unified coordination centre may additionally request further information from the management company or the participant and act on notifications that breaches have not been cured. The monitoring procedure is set by the authorised body.

The tax preferences: what is reduced, and for how long

An SEZ participant reduces corporate income tax on income from priority activities by 100 per cent, applies a zero coefficient to the rates of land tax and the land-use fee, and a zero rate to the property tax base — for facilities on the zone’s territory used in the priority activity. All four preferences are set by article 735 of Tax Code No. 214-VIII.

Corporate income tax

Under article 735(4) an organisation reduces the CIT computed under article 345 by 100 per cent on income from the sale of goods, works and services resulting from priority activities. This is a reduction of the computed tax, not an exemption of the income: the return is filed, the tax is computed, and then reduced.

The exception is built into the same provision. The reduction does not apply to income from the sale of construction objects: hospitals, clinics, schools, kindergartens, museums, theatres, higher and secondary educational institutions, libraries, schoolchildren’s palaces, sports complexes, and infrastructure, administrative and residential complexes — unless such sale is on the priority list of a border SEZ.

Under paragraph 7, income from other activities is taxed in the ordinary way, and under paragraph 6 the participant keeps separate tax accounting for priority and other activities. Under paragraph 8 the participant may not apply any other provision of the Code giving a 100 per cent reduction of CIT.

Land and property

Under article 735(1) the 100 per cent reduction works as follows: for land tax and the land-use fee, by applying a coefficient of 0 to the rates; for property tax, by applying a rate of 0 to the tax base. The same rules are duplicated in article 582(2)(2) and article 592(5)(2).

The start dates differ: land tax from the 1st of the month in which the agreement is concluded; property tax from the date the taxable object arises, but not earlier than the agreement date; the land-use fee from the 1st of the month of the agreement until the end of the lease, but not beyond the SEZ’s term. Where facilities are used for both priority and other activities, the amount of tax covered by the preference is determined in proportion to the share of income from priority activities in aggregate annual income (paragraph 2).

Three categories and three periods

Category	Project value	In tenge at MCI 4,325	Preference period
A	up to 3,000,000 MCI	up to KZT 12,975,000,000	7 years
B	from 3,000,000 to 14,500,000 MCI	KZT 12,975,000,000 to 62,712,500,000	15 years
B (food, textiles, clothing, leather, computers, electronic, optical and electrical equipment)	from 1,000,000 to 14,500,000 MCI	KZT 4,325,000,000 to 62,712,500,000	15 years
C	from 14,500,000 MCI	from KZT 62,712,500,000	25 years

The categories are set by article 51(2) of Law No. 242-VI (as amended by Law No. 46-VIII, from 1 January 2024) and the periods by article 735(10) of the Tax Code. The MCI is taken as at 1 January of the relevant financial year. The period is in every case capped by the term of the activity agreement and the term of the SEZ.

The key proviso in part two of paragraph 10: the categories and periods apply to agreements concluded after 1 January 2024. A participant whose agreement predates that date applies the preferences without the category cap — until the agreement or the zone expires. Article 58(7) of Law No. 242-VI (inserted by Law No. 324-VIII) lets participants whose agreements were concluded within five years before 1 January 2024 extend the agreement for no longer than the project’s implementation period, in line with the categories.

Management companies

Under article 735(9) the management companies of both SEZs and industrial zones reduce land tax, the land-use fee and property tax by 100 per cent on facilities used to service the zones. This is the only tax preference that exists in industrial zones — and it goes to the operator, not the participant.

The overall architecture of the new Tax Code is covered in our guide to Kazakhstan’s tax system in 2026: a complete breakdown of the new Tax Code.

What the 2026 Tax Code changed for SEZ participants

From 1 January 2026 SEZ participants operate under chapter 80 of the new Tax Code No. 214-VIII, which kept the four basic preferences but dropped the social tax reduction for participants of the “Park of Innovative Technologies” and widened the list of persons to whom the SEZ regime is unavailable. The comparison with chapter 79 of the former Code No. 120-VI follows.

Element	Code No. 120-VI (to 31.12.2025)	Code No. 214-VIII (from 01.01.2026)
Articles	708–709	734–735
100 % CIT reduction on priority activities	yes	yes, art. 735(4)
Land tax and land-use fee coefficient 0; property tax rate 0	yes	yes, art. 735(1)
100 % social tax reduction for participants of the “Park of Innovative Technologies” where payroll is at least 70 % of expenses	yes, art. 709(9)	absent
Categories A/B/C and the 7/15/25-year periods	yes (from 01.01.2024)	yes, art. 735(10)
Excluded persons	subsoil users, excisable production, special tax regimes, strategic projects, gambling	the same plus parties to an investment agreement, an agreement on investment obligations or a soli­d-mi­nerals processing agreement; Astana Hub participants; AIFC participants (art. 734(3))
Annulment on termination of the agreement	from the start of the tax period of the breach	the same, art. 735(3)
Stability against adverse changes	not more than 10 years	the same, art. 735(12)
Bar on stacking investment tax preferences on SEZ assets	—	art. 283(3)(6)

The lost social tax preference

Article 709(9) of the former Code allowed an organisation on the territory of the SEZ “Park of Innovative Technologies” to reduce computed social tax by 100 per cent on the pay of employees engaged in priority activities, provided such pay was at least 70 per cent of total accounting expenses. Chapter 80 of Code No. 214-VIII contains no such provision, and the word “social” does not appear in the chapter at all. Nor does chapter 85 of the Code contain any transitional rule preserving the preference for existing participants: none of articles 836 to 848 mentions SEZs.

The change coincided with the renaming of the zone itself: by Government Resolution No. 538 of 22 June 2026 the SEZ “Park of Innovative Technologies” was renamed “Almaty Innovation & Financial Zone” and its term extended from 1 January 2028 to 31 December 2049, conditional on meeting its target indicators. Sub-paragraph 4) of article 1 and article 58(1) of Law No. 242-VI still call the zone the “Park of Innovative Technologies” — a discrepancy the legislature has not yet corrected.

Anti-stacking at asset level

Sub-paragraph 6) of article 283(3) of Code No. 214-VIII excludes from the objects of investment tax preferences any assets intended for use in priority activities by SEZ participants. In other words, the same machine cannot attract both the accelerated deduction under articles 283–285 and the CIT reduction under article 735.

Separation from Astana Hub and the AIFC

Adding Astana Hub and AIFC participants to the excluded list in article 734 entrenches the principle of “one status, one regime”. A digital-technology company must choose: participation in the SEZ “Almaty Innovation & Financial Zone”, with the right to operate outside the zone’s territory (article 1(4) of Law No. 242-VI), or Astana Hub participant status under chapter 82 of the Code, which is limited to 1 January 2029. The regimes are compared in our guides to Astana Hub in 2026: the new participation rules and AIFC or LLP: choosing a jurisdiction inside Kazakhstan.

What VAT benefits do an SEZ participant and its suppliers receive?

The VAT regime of a special economic zone has four components: a zero rate for suppliers of goods fully consumed on the SEZ territory (article 470 of Tax Code No. 214-VIII), an extended zero rate for border SEZs (article 471), exempt turnover within and between zones (sub-paragraphs 30) and 35) of article 474) and import exemptions under special investment contracts (articles 479 and 525). Article 735(11) provides that SEZ participants apply the general rules of section 7 of the Code subject to these particular provisions. None of the provisions exempts a participant from VAT “as such”: each is tied to the free customs zone procedure and to specific documents.

Provision of Code No. 214-VIII	Who applies it	Condition	Effect
Article 470(1)	supplier of goods into any SEZ	the goods are on the list in Order No. 466 of the Minister of Industry and Construction of 30 October 2025, placed under the free customs zone procedure and under customs control	0 % VAT for the supplier
Article 470(1), second part	the same supplier	at its own election	may apply the ordinary rate under article 503 (16 %)
Article 471(1)	supplier of goods into a border SEZ	the goods are consumed or sold in activities meeting the zone’s purposes	0 % VAT; no goods list required
Article 474(30)	anyone selling goods, works or services on the territory of a border SEZ	the supply takes place on the zone’s territory	exempt turnover
Article 474(35)	an SEZ participant selling output to another participant	output produced in a priority activity; contract, shipping documents and confirmation of receipt on file	exempt turnover
Article 479(1)(9), article 525(2)(3)	a legal entity in SEZ “Qyzyljar” under a special investment contract	raw materials and materials within vehicles, agricultural machinery and their components; an industrial assembly agreement	import VAT exemption
Article 479(2), article 525(5)	a legal entity under a special investment contract in any SEZ	goods within finished products made in the SEZ; procedure completed by release for domestic consumption; ide­ntifi­cation carried out	import VAT exemption
Article 470(5), article 471(4)	an SEZ participant in breach of the full-co­nsu­mption condition	goods not consumed in activities meeting the zone’s purposes	goods treated as taxable import from the date of entry, with late-payment interest

The zero rate belongs to the supplier, not to the participant

The zero rate under article 470 is the supplier’s preference: the supplier issues the invoice at 0 % VAT and the supplier later claims the refund of excess VAT. The SEZ participant benefits indirectly — through a price without 16 % VAT and without a stranded input-tax credit. At the same time the second part of article 470(1) expressly allows the supplier to apply the ordinary rate under article 503. In practice this means a supplier unwilling to go through the refund procedure may invoice at 16 %, and the participant cannot insist otherwise: the 0 % rate is the seller’s right, not its duty.

A refund of excess VAT to the supplier is made only in respect of goods actually consumed in activities meeting the purposes of the SEZ (article 470(4)). Confirmation of actual consumption is generated by the customs authority from data submitted by the SEZ participant itself (article 470(5)), so the participant’s record-keeping discipline directly determines whether its supplier gets paid from the budget.

The goods list in Order No. 466: eleven zones out of eighteen

Order No. 466 of the Minister of Industry and Construction of 30 October 2025 “On determining the list of goods subject to VAT at the zero rate…” took effect on 1 January 2026, was published in the Reference Control Bank on 10 November 2025 and was not subject to state registration with the Ministry of Justice. It contains eleven appendices, one per zone: “Astana – New City”, “Seaport Aktau”, “Park of Innovative Technologies”, “Ontustik”, “National Industrial Petrochemical Technopark”, “Pavlodar”, “Saryarka”, “Khorgos – Eastern Gate”, “Chemical Park Taraz”, “Qyzyljar” and “TURAN”. The lists are built on EAEU commodity codes; the “Astana – New City” list begins with fresh beef (code 0201), reflecting the zone’s broad profile.

Seven of the eighteen SEZs have no list in Order No. 466: “Astana-Technopolis”, ICBC “Khorgos”, “Alatau”, “Aktobe”, “Korkyt Ata”, “Atyrau” and ITLC “Alatau”. Until a list is approved, a supplier of goods into those zones cannot substantiate the zero rate under article 470 — except in the case of a border SEZ under article 471, where no list is needed. Two appendices to Order No. 466 keep the zones’ former names: “Park of Innovative Technologies” (renamed Almaty Innovation & Financial Zone by Resolution No. 538 of 22 June 2026, after the order was issued) and “Chemical Park Taraz”, which has been called Jibek Joly since 2020. The second discrepancy existed on the day the order was signed and remains uncorrected.

Border SEZs: article 471 and article 474(30)

The Code calls a zone “border” where its limits “fully or partly coincide with sections of the EAEU customs border”. The Regulation on the SEZ “International Centre of Boundary Cooperation «Khorgos»” (Resolution No. 624 of 6 October 2017) expressly assigns that status to the ICBC. For such a zone the zero rate covers not only goods consumed inside it but also goods sold in activities meeting the zone’s purposes, and the sale of goods, works and services on its territory is exempt turnover (article 474(30)). In addition, article 453(7) excludes from sales turnover the shipment of goods previously imported under the free customs zone procedure into a border SEZ. The practical effect is that trade inside ICBC “Khorgos” is conducted without Kazakh VAT, and export from it is evidenced by a declaration bearing the mark of the customs authority at the zone’s checkpoint (article 467(2)(6)).

Exempt turnover between participants

Article 474(35) exempts from VAT the sale of goods produced in a priority activity on SEZ territory, provided three documents exist together: a supply contract with an organisation operating on SEZ territory; documents evidencing shipment to the participant; and documents evidencing receipt by the purchasing participant. On its literal wording the provision is not limited to the same zone — a producer in SEZ “Pavlodar” may supply a participant of SEZ “Saryarka” without VAT if the output was produced under a priority activity. The flip side is that exempt turnover carries no right to credit input VAT attributable to it, so a producer with a large share of such supplies should model the apportionment under chapter 49 of the Code in advance.

Loss of goods under the FCZ procedure is taxable turnover

The loss of goods acquired without VAT and placed under the free customs zone procedure is treated as sales turnover (article 452(1)(7)); the date of the turnover is the date the loss is established (article 460(12)); and the amount of the turnover equals the book value without revaluation or impairment (article 462(13)). The only exception is for goods listed in article 474. For a manufacturing participant this means that writing off defects, shortages and spoilage of goods received at 0 % triggers VAT on book value — a rule rarely built into warehouse-loss planning.

The special investment contract: a benefit that outlived its institution

The exemptions in articles 479 and 525 are addressed to legal entities that have concluded a special investment contract “with the authorised body for concluding special investment contracts determined by the Government”. The institution of the special investment contract itself was removed from the Entrepreneurial Code on 1 January 2026: article 295-1 was excluded by Law No. 215-VIII of 18 July 2025. The Tax Code provisions therefore apply to contracts concluded before 2026 and still in force; there is no legal basis in the Entrepreneurial Code for concluding new contracts of this type, and the Tax Code, which took effect on the same date, did not react to this.

Imports from third countries: interaction with the customs procedure

Goods brought in from outside the EAEU and placed under the free customs zone procedure are not subject to import VAT until the procedure is completed — a consequence of customs rather than tax regulation, discussed below. When the procedure is completed by release for domestic consumption, import VAT becomes payable unless one of the exemptions in articles 479 and 525 for holders of special investment contracts applies. The general import rules, including the recycling and anti-dumping charges that the SEZ regime does not cancel, are covered in our guide to importing into Kazakhstan from third countries in 2026.

The free customs zone procedure: how “duty-free import” actually works

A free customs zone (FCZ) is a customs procedure under which foreign goods and EAEU goods are placed and used within the territory of an SEZ without payment of import customs duties, taxes, and special, anti-dumping and countervailing duties, provided the conditions of placement and use are met (article 281(1) of the Code “On Customs Regulation in the Republic of Kazakhstan” No. 123-VI). The procedure is governed by chapter 27 of the EAEU Customs Code (articles 201–210) and chapter 29 of the Kazakh Code (articles 281–291); the latter fleshes out the Union rules. The benefit is conditional: duties and taxes are not cancelled but “frozen” until the procedure is completed.

What may be placed under the procedure and who may act as declarant

The procedure covers goods intended for placement and use by an SEZ participant for the purposes of the activities under its activity agreement (article 281(2)). EAEU goods are placed under the procedure at the participant’s election, but for port and logistics SEZs placement is mandatory (article 281(3)). In a port or logistics SEZ goods are deemed placed under the procedure from the day of entry into the zone without separate declaration (article 284(1)). The declarant is a participant of the SEZ where the goods are located; for port and logistics zones, persons that have concluded a warehousing-services contract with a participant may also act as declarant (article 282(2)–(3)). Vehicles carrying cargo into the SEZ and their supplies are not placed under the procedure (article 281(6)). The tax side of bringing goods in from EAEU member states — form 328.00 and the VAT payment procedure — is covered in our guide to VAT on imports from the EAEU into Kazakhstan in 2026.

Order No. 217 of the Minister for Investments and Development of 5 April 2018 (Ministry of Justice registration No. 16778) approves four categories of goods that may not be placed under the procedure: medical goods for emergency care, disaster-relief supplies, rescue equipment and law-enforcement weapons. The list does not extend to the border SEZ.

Three conditions of use

Article 282(5) sets the conditions of use: the goods remain on the SEZ territory for the zone’s term or until the person loses participant status; they are used in accordance with the activity agreement; and operations with them are performed by the declarant or other persons specified in the Code. Permitted operations are listed in article 285: storage, loading, sorting, packing, labelling, processing, manufacturing, assembly, repair, consumption in cases determined by the Commission, and sampling. Operations are permitted only insofar as they conform to the activity agreement (article 285(3)) — a line of business not written into the agreement cannot use the procedure for its needs.

Goods may leave the SEZ territory without completing the procedure, with the customs authority’s permission, in the five cases of article 285(4): repair and maintenance of equipment elsewhere in the EAEU (except capital repair and modernisation), testing and demonstration of samples, completion of the procedure at a competent customs office, the participant’s own production needs under conditions set by the Commission, and processing outside the zone where the SEZ lacks the relevant capacity.

Records, reporting and identification

The declarant keeps records of goods placed under the procedure and of products made from them and reports on them to the customs office that effected the placement (article 283(7)); any change to the goods must be reflected in the records. Full or partial consumption of goods — including in the construction of real estate, the upkeep of equipment and the support of production processes — must be reported (article 285(2)). The record-keeping procedure is set by the State Revenue Committee.

Article 286 lists the methods of identifying foreign goods in finished products: seals and markings, detailed description and photography, comparison of samples, serial numbers, examination of process documentation and customs control during processing. Identification is not a formality: it determines whether, on subsequent release of the products onto the EAEU market, duties are charged on the imported components or on the finished article (article 289).

Status of the output: foreign goods or EAEU goods

Input goods	Status of the output	Provision of Code No. 123-VI
EAEU goods only (whether or not placed under the procedure)	EAEU goods	article 281(8)
Foreign goods, or foreign goods together with EAEU goods	foreign goods — for removal to the rest of the EAEU	article 281(9)
The same, when exported outside the EAEU	EAEU goods if the sufficie­nt-pro­cessing criteria are met	article 290
Goods the customs authority cannot identify	EAEU goods for export outside the EAEU; foreign goods for any other purpose	article 281(10)

The sufficient-processing criteria — a change of commodity code at any of the first four digits, the ad valorem rule, or completion of a list of operations set by the Commission — apply only when the output is exported outside the EAEU (article 290(1)–(2)). For supply to the Kazakh market and other member states, output made from foreign components remains foreign goods, and completing the procedure requires release for domestic consumption with payment of duties. Status is confirmed by an opinion of an authorised organisation of a member state (article 290(7)); absent such an opinion, the output is treated as EAEU goods for export outside the EAEU and as foreign goods for any other purpose (article 290(8)).

Rates: which date governs the duty

Article 289(1) sets two approaches. For foreign goods that have not been processed, release for domestic consumption uses the rates in force on the day the declaration placing the goods under the FCZ procedure was registered. For equipment commissioned and used by the participant to implement its agreement, and for goods in port and logistics SEZs, the rates on the day the release-for-domestic-consumption declaration is registered apply. For processed output with identified components, duties are calculated on the components at the rates of their placement date; without identification, on the finished product (article 289(2)). This makes identification an economic and not merely a compliance issue: where the duty rate on the finished article exceeds the rate on the components, the absence of identification directly increases the payment.

Customs risks: when a deferred duty becomes a debt with interest

The obligation to pay duties and taxes “frozen” by the free customs zone procedure revives on seven events listed in article 288(7) of Code No. 123-VI — from removal of goods from the zone without completing the procedure to their loss — and is discharged as if the goods were released for domestic consumption without any benefit, with interest at the National Bank base rate for the entire period of the procedure (article 288(8) and (10)). The greatest practical risk arises not from deliberate breach but from loss of participant status: from that day the company has six months to complete the procedure for all goods, failing which the customs authority detains them.

Seven events that trigger the payment deadline

Event (article 288(7))	Payment deadline
Removal of foreign goods or products made from them from the SEZ without completing the procedure or without customs permission	the day of removal or, if not established, the day the fact is discovered
Transfer of goods to another person without completing the procedure (other than transfers between participants under article 285(8) and (10))	the day of transfer or of discovery
Failure to return to the SEZ, by the customs-set deadline, goods taken out for repair, testing, own needs or processing	the day the deadline expires
Failure to complete the procedure by the set deadline for goods taken out for completion at a competent customs office	the day the deadline expires
Loss of foreign goods or products made from them, other than destruction through accident, force majeure or natural wastage	the day of loss or of discovery
Failure to submit, by the set deadline, documents evidencing burial, recycling or destruction of goods	the day of removal from the SEZ
Termination of the export procedure for products recognised as EAEU goods and not exported in time	the day after the deadline under article 219 expires

On any of these events, import duties, taxes and trade-defence duties are payable “as if the goods were placed under the procedure of release for domestic consumption without the application of tariff preferences and payment benefits” (article 288(8)). The rates are those on the day the FCZ placement declaration was registered — for foreign goods and identified components; for output without identification, those on the day the payment deadline falls (article 288(9)). Where the customs authority lacks precise information about the goods, the base is determined from the information available, and where the commodity code is determined at fewer than ten digits, the highest duty, VAT and excise rate within the grouping applies.

Interest as on a deferral

Amounts payable under article 288(8) attract interest “as if a deferral of payment had been granted in respect of those amounts from the day the goods were placed under the free customs zone procedure until the day the payment deadline expires” (article 288(10)). Under article 93 of the Code the interest is 1/360 of the National Bank base rate per day, at the rate in force in each period. For equipment imported five years ago this means five years of interest — on top of the duty and VAT themselves. Once paid or recovered, these amounts can be offset or refunded only on subsequent completion of the procedure or detention of the goods in the prescribed manner (article 288(11)).

Six months after loss of status

Article 287(1) requires the procedure to be completed within six months of the day the SEZ ceases to operate (or a decision is taken to stop applying the procedure on its territory) and within six months of the day a person loses participant status. Completion is effected by placing the goods under other procedures, except transit: re-export or export for removal outside the EAEU (article 287(5)); release for domestic consumption, processing, temporary import and the other procedures in sub-paragraph 1) of paragraph 6 for removal to the rest of the EAEU; and transfer to another participant by that participant placing the goods under the FCZ procedure itself (article 287(8)). If the procedure is not completed within the six months, it terminates automatically and the goods are detained by the customs authorities under chapter 52 of the Code (third parts of article 287(3) and (4)). Until completion, the former participant must continue to comply with all conditions of use of the goods (article 282(6)).

What this means for exit planning

Loss of status — on expiry of the agreement, on termination or on abolition of the zone — starts a clock within which the company must decide the fate of every item of equipment and every stock of raw material: pay duties and VAT at the rates of the import date, export outside the EAEU, transfer to another participant or dispose of it with an opinion from the competent authority. For a manufacturing participant with imported equipment worth billions of tenge, the payment on release for domestic consumption can exceed all the CIT savings accumulated, so the customs “exit balance” should be modelled before the activity agreement is signed, not when it ends.

Land and infrastructure: what a participant gets free and what it pays for

State-owned land on which an SEZ is created is leased to the management company for the zone’s term, and the management company passes it to participants carrying out priority activities free of charge — and to persons carrying out auxiliary activities for a fee (article 17(3) of Law No. 242-VI). Free land use, a zero land-use fee under article 735 of the Tax Code and connection to budget-funded infrastructure are the three parts of the “land” benefit; they operate together, but each has its own limits.

Two areas and two caps

The Law sets two quantitative limits. The aggregate area of an SEZ designated for auxiliary activities may not exceed 20 % of the zone’s total area; for manufacturing projects, the area outside the production area may not exceed 30 % of the production area (article 17(3)). The second limit directly affects site layout: administrative buildings, parking and storage beyond the cap will not be approved by the management company, which is the body that subdivides the plots.

The management company must reserve part of the plot for the project stages set out in the activity agreement and may not transfer the reserved land to others without the participant’s consent — unless the participant itself has breached the staged implementation schedule. Construction and commissioning deadlines are a mandatory term of the activity agreement and of the sub-lease agreements (article 17(9)); missing them by more than three consecutive months is a ground for unilateral termination under article 20.

Buying the land: not available to everyone

Article 17(3-2) allows state plots to be transferred into the ownership of SEZ participants, except foreign legal entities, subject to easements under the Land Code. On expiry of the activity agreement a purchased plot is removed from the territory of the special legal regime under article 16 of the Law. For a group with a foreign parent this means only a Kazakh legal entity can buy the land — an LLP with foreign participation is not caught by the prohibition, since it is a Kazakh legal entity, whereas a branch of a foreign company cannot be an SEZ participant at all: article 1 of Law No. 242-VI defines a participant as a legal entity (individual entrepreneurs are admitted only in the border SEZ), and a branch is neither. The general restrictions on foreigners and foreign-owned companies acquiring land are set out in our guide to buying real estate in Kazakhstan as a foreigner in 2026.

Infrastructure and utilities

SEZ plots must be provided with infrastructure from the budget and other lawful sources (article 17(4)); budget-funded facilities are transferred to the management company by lease, trust management or contribution to charter capital and may then be let to participants. A participant may build the infrastructure it needs at its own expense beyond its plot within the zone, subject to agreement with neighbours and the management company. Suppliers of electricity, heat, gas and water must give participants access “analogous to that of other consumers” (article 23) — a guarantee of non-discrimination, not of a preferential tariff.

The “one-stop shop” principle

On SEZ territory, public services are provided on a “one-stop shop” basis by the State Corporation “Government for Citizens”, and other services may be provided on the same basis by the management company (article 17(7)–(8)). Article 1(6) defines the principle as minimising the applicant’s involvement in collecting documents and limiting direct contact with service providers. In practice the scope of one-stop services varies by zone and depends on the capacity of the particular management company.

Auxiliary activities: no preferences

Persons seeking to carry out auxiliary activities — logistics, catering, services for participants — must be Kazakh producers of goods, works and services and be registered as businesses (article 21(2)). They sign their own activity agreement with the management company, receive land for a fee and do not enjoy the tax preferences of article 735 of the Tax Code, which are addressed only to participants entered in the unified register. Confusing the two statuses is a common source of error when structuring projects in which the production and service parts belong to different group companies.

Foreign labour: when an SEZ participant needs neither quota nor permit

An SEZ participant with a project worth more than 1,000,000 MCI (4,325,000,000 tenge in 2026), together with its general contractors, contractors, subcontractors and service providers, is exempt from the quota and from permits to hire foreign labour for the period of construction and assembly works and until one year after commissioning of the facility — within a list of categories and headcount set by an inter-agency commission (article 36-1(2)(4) of the Law “On Migration of the Population” No. 477-IV). Article 54 of Law No. 242-VI refers to employment legislation, and the procedure itself is set by the joint order of the Minister of Labour and Social Protection No. 259 of 29 June 2023 and the Minister of Industry and Infrastructure Development No. 474 of 29 June 2023 (Ministry of Justice registration No. 32958), as restated by joint order No. 416/381 of 31 October 2024 and amended in January and April 2026 (the latter in force from 12 July 2026).

Parameter	Value
Project threshold	more than 1,000,000 MCI
Who is exempt	the SEZ participant, its general contractor, contractors, subco­ntra­ctors, service providers
Period	construction and assembly works plus one year after commissioning
Where the application goes	to the SEZ management company (appendices 1–3 to the Rules)
Document check	management company together with the akimat — 5 working days
Referral to the commission	the authorised body — within 2 working days via the “Foreign Labour” digital system
Commission meeting	no later than 15 calendar days from receipt of the documents
Form of decision	commission minutes drawn up in the digital system separately for each organisation

What is filed and what is checked

The application is accompanied by the foreign workers’ identity documents, notarised and legalised education documents with translations, evidence of work experience, a justification for the hiring, a copy of the project (contract) worth more than 1,000,000 MCI and information on local content in personnel (paragraph 4 of the Rules). The management company and the local executive body check the workers against the qualification requirements of professional standards and qualification handbooks (paragraph 7). The commission comprises representatives of the Ministry of Industry and Construction, the migration authority, the Ministry of Internal Affairs, the Ministry of Energy, the akimats and the single coordination centre (paragraph 11); decisions are taken by majority vote.

The key condition is local content in personnel: the participant must maintain the share of Kazakh employees set by the commission’s decision on the akimat’s recommendation (paragraphs 9 and 14–15 of the Rules). Exemption from the quota does not mean free hiring: the commission approves specific categories and numbers, and exceeding the list returns the employer to the general permit regime.

What stays under the general regime

Projects worth up to 1,000,000 MCI, and hiring after one year from commissioning, are governed by the general rules: quota, permit from the local executive body, the permit fee and local-content requirements. SEZ participation as such gives foreign employees no visa or immigration advantage — visas and registration are processed on the general basis. The general rules are covered in our guide to Kazakhstan’s permit to attract foreign labour in 2026.

Risks of losing status: five grounds on which a participant loses the regime

SEZ participant status is lost on five groups of grounds: termination of the agreement by the management company for material breach (article 20(3) of Law No. 242-VI), termination for failure to confirm financial security (article 20(1)), expiry of the activity agreement, abolition of the zone on expiry of its term (article 24), and reorganisation without re-registration of the right to participate (article 25). Law No. 324-VIII of 24 June 2026 tightened the first ground: the construction-delay threshold was cut to three months, and article 20 itself was renamed “Procedure for deprivation of participant status”.

Ground	Provision	Who initiates	Can it be cured?
Delay in design, construction and assembly works or commissioning of more than three consecutive calendar months without good reason	article 20(3)(1)	the management company, unilaterally	no — a stand-alone ground
Suspension of activity for more than two calendar months without the management company’s consent	article 20(3)(2)	the management company	agree the suspension in advance
Failure to remedy breaches of the agreement or the law within the period set in the management company’s notice (no more than 60 calendar days)	article 20(3)(3), article 20(2)	the management company, after a notice	yes — within the notice period
Failure to confirm financial security: 10 % on application, the balance within two years (three years for projects above 15,000,000 MCI)	article 20(1), article 18(16)–(17)	the management company	yes — before the deadline
Expiry of the activity agreement	the activity agreement (article 18(10))	automatic	extension by agreement, if the zone’s term allows
Abolition of the SEZ on expiry of its term	article 24	the Government (extension where more than 20 % of the territory is undeveloped or investors exist)	outside the participant’s control
Merger, accession, conversion, spin-off or division without re-re­gistra­tion of the right	article 25	reo­rgani­sation at the participant’s decision	re-re­gistra­tion under article 18(3)–(4)

The remedy notice: the only “yellow card”

Article 20(2) obliges the management company, on discovering non-performance of the agreement or of legal requirements affecting the project, to draw up a notice setting a remedy period of no more than 60 calendar days. Only the third termination ground (failure to remedy under a notice) involves such a warning stage. The first two grounds — a delay of more than three months and a suspension of more than two months — are framed as stand-alone and require no prior notice, although the activity agreement may provide for a notification procedure. “Good reasons” for delay are not defined in the Law; before 25 August 2026 the threshold was six months, and practice under the three-month threshold has yet to form.

Financial security as a delayed trigger

The applicant confirms financial security of at least 10 % of the project cost by cash, bank guarantee, suretyship, pledge of property or insurance contract — in any combination (article 18(16)). Security for the remaining part of the cost is confirmed within two years of obtaining status, or within three years for projects above 15,000,000 MCI (64,875,000,000 tenge in 2026) (article 18(17)). Failure to meet these requirements entails termination under article 20(1) “in the manner provided by this Law, civil legislation and the agreement”. For debt-financed projects the second deadline is often the more critical: the loan agreement may still be unsigned by the end of the second year.

Monitoring: who detects breaches and how

Article 42 establishes three-tier monitoring: the management company — continuously, on the basis of primary documents and participants’ annual reports; the akimats and the single coordination centre — on the basis of the management companies’ reporting; and the single coordination centre additionally — through requests to the participant and on the management company’s notifications of unremedied breaches. The monitoring procedure is set by the Ministry of Industry and Construction. The participant’s annual report (article 41(2)(1)) is the main document from which schedule deviations are identified, so its contents should be reviewed with counsel before filing.

Abolition of the zone: what happens to participants

Under article 24 an SEZ is abolished on expiry of the term for which it was created. The territory acquires the status of an industrial zone of republican significance, the management company becomes the industrial zone’s management company, and participants become industrial zone participants; participants holding sub-lease rights may buy their plots under the Land Code, subject to the restrictions for the border zone. The rule does not apply to a science-intensive territory (an addition made by Law No. 321-VIII). Tax preferences do not survive: an industrial zone has none. The nearest deadline is SEZ “Astana – New City”, which runs to 2027; no extension act appears on Adilet as at 1 September 2026, and “Seaport Aktau” runs to 1 January 2028. Extension is decided by the Government where more than 20 % of the territory is undeveloped or potential investors exist (article 17(1)) — both conditions look achievable for “Astana – New City” with its 15,264 hectares, but there is no legal certainty until a resolution is adopted.

Consequences of losing status: what must be paid, and from what date

Where the management company terminates the agreement, tax preferences are annulled from the start of the tax period in which the breach occurred (article 735(3) of Tax Code No. 214-VIII); the participant must file additional returns for that period within 30 calendar days, and the free customs zone procedure must be completed within six months (article 287(1)(2) of Code No. 123-VI). In other words, loss of status operates retrospectively for taxes and prospectively for customs — and with interest in both cases.

Consequence	Provision	Timing	Additional burden
Annulment of the CIT, land tax, land-use fee and property tax reductions	article 735(3) of the Tax Code	from the start of the tax period of the breach	late-payment interest under the general rules of the Tax Code
Additional tax returns	article 735(3), third part	no later than 30 calendar days from termination	admi­nistra­tive fines for non-filing
Management company’s report to the tax authority of the termination and the breach date	article 735(3), second part	no later than 30 calendar days	—
Loss of the stability guarantee	article 735(12), third part	from the date of unilateral termination	the current wording of chapter 80 applies
Completion of the free customs zone procedure	article 287(1)(2) of the Customs Code	six months from loss of status	duties and VAT at the rates of the import date plus interest at 1/360 of the base rate per day
Detention of goods on non-co­mple­tion	article 287(4), third part, of the Customs Code	on expiry of the six months	storage and sale under chapter 52
Termination of the land sub-lease	article 20(4) of Law No. 242-VI	together with the activity agreement	vacating the plot, dismantling or selling the facilities
Notification of the state revenue authority, the coordination centre and the akimat	article 20(5) of Law No. 242-VI	2 working days from termination	—
Goods treated as taxable import for VAT	article 470(5), article 471(4) of the Tax Code	from the date of import	interest from the import VAT due date

Tax retrospectivity: from the start of the breach period, not the termination date

The wording of article 735(3) ties annulment to the tax period “in which the breach constituting the ground for termination occurred”. If the management company identified a construction delay that began in February 2026 and terminated the agreement in 2027, the preferences are annulled from 1 January 2026. The management company reports the breach date to the tax authority (second part of paragraph 3), so the dispute over when the breach “occurred” becomes the central tax dispute on termination; a notice issued after desk control or an audit is contested under the rules described in our guide to desk control, tax audits and appeals in Kazakhstan in 2026. Annulment affects all four preferences — CIT, land tax, land-use fee and property tax — not only the one linked to the breached obligation.

Annulment does not apply on expiry of the agreement or abolition of the zone: in those cases the preferences simply cease for the future. The difference is fundamental for an investor offered a “termination by mutual agreement”: article 735(3) speaks of termination by the management company “in accordance with the legislation on special economic and industrial zones”, and a voluntary exit by agreement does not literally fall within that text — but there is no confirming practice, and for a large project the exit terms should be fixed in writing with the tax authority.

Loss of stability

The non-deterioration guarantee in article 735(12) — application of the version of chapter 80 in force on the agreement date where reductions are later removed or resized, for no more than ten years from the first such change — does not apply on unilateral termination by the management company. A participant deprived of status cannot rely on the former levels of benefit even for periods before termination once they have been annulled.

The customs unwind

The six-month period in article 287 of the Customs Code runs from the day status is lost, not from the day the company learned of the termination. Within that period the procedure must be completed for every declaration: release for domestic consumption with payment of duties, VAT and interest; export outside the EAEU; transfer to another participant; or disposal. For equipment the rates are taken on the day the release-for-domestic-consumption declaration is registered, for other foreign goods on the day of placement under the procedure (article 289(1)), and interest accrues from the day of placement (article 288(10)). After the period expires the goods are detained under chapter 52 and, after the prescribed storage periods, may be sold.

Land and buildings

Termination on the grounds in article 20(3) automatically ends the sub-lease of the plot (article 20(4)). The fate of the buildings is determined by the activity agreement and the sub-lease; the Law contains no direct compensation rule, leaving the participant to sell the facility to another zone participant (with re-registration of the land) or dismantle it. Purchase of the plot under article 17(3-2) is not available after termination — that option exists for current participants and for the case of abolition of the zone (article 24(2)).

Industrial zones: what the status gives without tax benefits

An industrial zone is a territory equipped with engineering and utility infrastructure and made available to private businesses for locating facilities in industry, agro-industry, tourism, logistics and waste management (article 1(9) of Law No. 242-VI); unlike an SEZ it creates no special tax or customs regime for participants but offers a ready site, land under contract and the “one-stop shop” principle. The only tax preference is addressed not to the participant but to the management company: under article 735(9) of the Tax Code, management companies of SEZs and industrial zones reduce by 100 % the land tax, land-use fee and property tax on facilities used to service the zone.

Five types of zone

Article 26 divides industrial zones into state zones — of republican significance, of regional significance, and small — and private zones; a special industrial zone is a variety of private zone (article 1(7-1)).

Type	Who creates and finances it	Term	Land for the participant	Features
Republican significance	financed wholly or partly from the republican budget; or a former SEZ under article 24	at least 20 years, extendable by the akimat	sub-lease from the management company under an activity agreement; right to buy under the Land Code (article 34(5))	admission via the regional coordination council (article 34(2))
Regional significance	financed from the local budget	at least 20 years	the same	the same
Small	under the rules on small industrial zones; in commissioned production buildings transferred to SMEs (article 27(5))	per the rules	premises rather than plots	aimed at small and medium business
Private	individuals or non-state legal entities from their own funds, investment or loans (article 27(4))	set by the owner	sub-lease of privately owned plots (article 33(6))	concept agreed with the akimat within 10 calendar days (article 30)
Special (a variety of private)	the same; the owner may act as management company if experienced in working to international quali­ty-mana­gement standards	set by the owner	lease until commi­ssio­ning, then an exclusive right to buy (article 33-1(2))	direct application of international building codes; a single management company (article 33-1(12))

Agreement, selection and termination in a state zone

The applicant files an application with the management company under the rules and criteria for selecting projects for SEZs and industrial zones (Order No. 599 of 31 July 2019); the agreement is concluded on a positive admission decision of the regional coordination council (article 34(1)–(2)). All transactions relying on the zone’s status are valid only after the zone is entered in the unified register of industrial zones (article 27(7)). Termination: the management company draws up a non-performance notice, sets a remedy period of no more than 60 calendar days and, if the breach is not remedied, gives at least 10 working days’ notice of termination (article 34(4)). A participant may amend its project schedule no more than three times (article 46(1)(2-1) as amended by Law No. 324-VIII) and must report to the management company annually.

Special industrial zone: a private site under international standards

The special industrial zone was introduced by Law No. 26-VII of 1 April 2021. Its distinctive features: the landowner may designate itself as management company; the management company may sell plots, lease them or contribute them to charter capital; on a sale the plot is first leased with a ban on pledge and sub-lease to third parties, and after commissioning the participant obtains an exclusive right to buy it (article 33-1(1)–(2)). The owner finances the internal engineering infrastructure and the fire service itself, and the management company may supply power, water, gas and telecommunications under its own licences. Six activities are prohibited in a special zone under article 33-1(9): production failing environmental or occupational-safety requirements; weapons and ammunition; nuclear materials; cement, clinker, coal products, lime and gypsum; waste processing and disposal; refineries and nuclear facilities. The Law’s standard-form documents do not apply to special zones (paragraph 7), and the akimat may withdraw special-zone status where life, health, the environment or national security are at risk or where the owner fails to deliver the concept (article 35-1) — after which the zone continues as an ordinary private zone.

How many zones and where

According to the unified register of industrial zones published by QazIndustry on 19 December 2025, Kazakhstan has 67 industrial zones; by the author’s count from the “type” column these are 11 zones of republican significance, 40 of regional significance, 12 private (including one special zone — «Birlik» in Astana, entered in the register on 22 April 2024) and 4 small zones in Kyzylorda region (register data, author’s count from the “type” column). The small industrial zone programme is growing faster than the register: according to the Ministry of Industry and Construction on 6 August 2025, since 2024, with the participation of regional social-entrepreneurial corporations, 34 small industrial zones are being implemented in eight regions with a total area of 272,000 m² and a cost of 66.8 billion tenge, of which 46.6 billion was provided as concessional loans from the Industrial Development Fund; 54 new applications worth more than 100 billion tenge have been filed, and 94 business initiatives with 170 billion tenge of investment and more than 3,000 jobs are planned.

The restriction people forget

Participants of industrial zones, like SEZ participants, may not apply the special tax regime based on the simplified declaration (article 723(2)(6) of the Tax Code). For a small business offered space in a small industrial zone this means moving to the general regime with 20 % CIT and VAT — sometimes more expensive than renting outside the zone. The regimes are compared in our guide to Kazakhstan’s special tax regimes 2026: three regimes instead of seven.

SEZ, industrial zone, investment agreement, Astana Hub, AIFC: which to choose?

Kazakhstan’s five regimes are mutually exclusive by status — an SEZ participant cannot at the same time be party to an investment agreement, an Astana Hub participant or an AIFC participant (article 734(3) of the Tax Code; article 283-1(4)(3) of the Entrepreneurial Code) — and differ along three axes: where one must physically be located, for how long the benefits are fixed, and what happens on breach. The table compares the regimes as at September 2026.

Criterion	SEZ	Industrial zone	Investment agreement	Astana Hub	AIFC
Principal act	Law No. 242-VI; chapter 80 of the Tax Code	Law No. 242-VI	article 283-1 of the Entre­preneu­rial Code; chapter 81 of the Tax Code	Law No. 207-V “On the Innovation Cluster «Astana Hub»”; chapter 82 of the Tax Code	Consti­tu­tional Law No. 438-V
Territorial link	activity on the zone’s territory (except Almaty Innovation & Financial Zone)	siting the facility in the zone	none	none	registration in the AIFC
Project threshold	no general threshold; categories A/B/C by value	none	200,000–5,000,000 MCI by project type (under the Code); 7,500,000 MCI under the operative Rules	none	none
CIT	100 % reduction on priority activities; 7/15/25 years	none	100 % reduction on the project; no more than 10 years	100 % reduction (article 739 of the Tax Code)	exemption on listed financial services until 1 January 2066 (article 6(3))
Land tax, land-use fee, property tax	coefficient 0 / rate 0	none (management company only)	coefficient 0 / rate 0, up to 10 and 8 years	none	exemption for facilities on the Centre’s territory (article 6(8))
VAT	0 % for suppliers under the goods list; exempt turnover between participants	general regime	no special rules in chapter 81	exempt turnover and imports (article 738 of the Tax Code)	general regime with the carve-outs of article 6(8-1)
Customs	free customs zone procedure	none	none (duties only under the simplified investment contract)	none	none
Foreign labour	outside the quota for projects above 1,000,000 MCI during construction + 1 year	general regime	right to hire (article 283-1(7))	general regime (5-year visa under article 7-1 of Law No. 207-V)	without a permit (article 8(1) of the Consti­tu­tional Law)
Stability	up to 10 years from the first adverse change (article 735(12) of the Tax Code)	stability of the agreement (article 27(8) of the Law)	10 years (article 737 of the Tax Code)	chapter 82 limited to 1 January 2029	until 2066 under the text of the law
Consequence of breach	annulment from the start of the breach period	termination of the agreement	annulment from the date of conclusion (article 736(9) of the Tax Code)	general regime from the start of the breach period (article 739(4))	loss of participant status
Special tax regimes	prohibited (article 723 of the Tax Code)	prohibited (article 723 of the Tax Code)	prohibited (article 283-1 of the Entre­preneu­rial Code)	—	—

Three questions that decide the choice

First — where will production be located? An SEZ and an industrial zone require physical presence on the territory; an investment agreement does not. For a plant that needs a specific site outside the existing zones, an SEZ is unavailable, whereas an investment agreement with an in-kind grant of land is a workable option. In-kind grants and thresholds are covered in our guide to investment preferences and the investment contract in Kazakhstan.

Second — which matters more, duration or customs? Category C in an SEZ gives up to 25 years of CIT reduction against 10 years under an investment agreement, and the free customs zone procedure is the only one of the five regimes that removes import duties on equipment without a simplified investment contract. For a capital-intensive, export-oriented producer with imported equipment the SEZ wins; for a project with mostly Kazakh and Eurasian components the customs element adds no value.

Third — how far back does a breach reach? Annulment in an SEZ is retrospective to the start of the tax period of the breach; under an investment agreement it runs from the date of conclusion, that is for every year of the agreement. On this criterion the SEZ is gentler, but its termination grounds — three months’ construction delay — are harsher and require no warning.

Combinations that do not work

SEZ preferences and the investment tax preferences of articles 283–285 of the Tax Code cannot be applied to the same asset (article 283(3)(6)). One cannot be both an SEZ participant and an Astana Hub participant — a digital company chooses between Almaty Innovation & Financial Zone and Astana Hub (compared in our guide to Astana Hub in 2026). The simplified declaration cannot be used in an SEZ. The only permitted combination is an SEZ participant and, separately, a supplier applying the 0 % rate under article 470 — but those are different persons.

The regime in numbers: what the official figures show and what they leave out

According to the Ministry of Industry and Construction, as reported by Kazinform on 17 April 2026, over the life of the SEZ regime 558 investment projects have been implemented, more than 10.8 trillion tenge of investment attracted, over 41,000 jobs created, 13.9 trillion tenge of output produced, exports have exceeded 1 trillion tenge, and 799.7 billion tenge has been paid to the budget. The ministry states the multiplier as follows: every tenge of budget spending on infrastructure has attracted 8.8 tenge of private investment and 1.6 tenge of tax receipts. The figures are departmental and reproduced by the agency; there is no primary publication on the ministry’s website open to machine verification, so they are presented as second-tier data with the source stated.

Indicator	Value	Period	Source
Number of SEZs and regions	17 SEZs in 14 regions (as at 17 April 2026; 18 from 21 April 2026)	at publication	ministry via Kazinform; Resolution No. 301
Projects implemented	558	whole period	ministry via Kazinform
Investment attracted	more than 10.8 trillion tenge	whole period	the same
Jobs	over 41,000	whole period	the same
Output produced	13.9 trillion tenge	whole period	the same
Exports	over 1 trillion tenge	whole period	the same
Taxes paid to the budget	799.7 billion tenge	whole period	the same
Output in 2025	3.1 trillion tenge (+34 % on 2024)	2025	the same
Projects under imple­menta­tion	586 worth 12.9 trillion tenge; a further 43,000 jobs expected	at publication	the same
“Astana – New City”	88 projects under way, about 10,000 jobs, investment over 693 billion tenge, a further 188 projects at various stages (54 manu­factu­ring, 134 construction industry), infra­stru­cture 87 % complete, infra­stru­cture spending 24.8 billion tenge	at publication	the same

What does not add up within the release

The ministry calls “Astana – New City” the leader, “generating more than 70 % of all SEZ output in the country”, and in the same text gives the zone’s “output of products — over 103 billion” tenge. With total SEZ output of 3.1 trillion tenge in 2025, a 70 % share would be roughly 2.2 trillion, not 103 billion; the two figures evidently refer to different periods or bases (for example, output of projects under implementation only), but the release does not explain this. The Invest in Astana portal, for its part, attributes to the zone 71 % of the aggregate output, 44 % of the tax receipts and 22 % of the exports of all SEZs in the country — without stating the reference period. The ratio of 799.7 billion tenge of taxes paid to 10.8 trillion tenge of investment attracted over the whole period — about 7.4 % — is itself an illustration of how deep the regime’s preferences run.

What the participants’ register says

The unified register of SEZ participants, published by QazIndustry as a PDF as at 31 July 2026 (780 pages), is cumulative and includes entries for every participant ever registered, including those whose agreements have been terminated. By the author’s count, the register contains about 458 entries marked as terminated against roughly 2,900 certificates issued across 16 zones — that is, roughly one participant in six over the regime’s history has left early. The estimate is approximate (the register is not structured for machine analysis) and is offered as an indicator of the scale of the status-loss risk, not as official statistics.

What the numbers do not contain

The official data do not disclose the distribution of projects by category A/B/C, the amount of benefits granted by tax (so-called tax expenditure), the number of terminations under each ground of article 20, or the customs payments assessed on completion of the free customs zone procedure. Without these data, any efficiency comparison between an SEZ and an investment agreement remains qualitative. An investor taking a decision should ask the management company of the specific zone for data on the number of current participants, terminations over the past three years and infrastructure utilisation — the Law obliges management companies to monitor (article 42) but not to publish the results.

The 2026 reform: what exactly changed for current and future participants

In 2026 the SEZ regime was changed by four acts of different levels: Tax Code No. 214-VIII (from 1 January), Law No. 324-VIII (from 25 August), Order No. 466 on the goods lists for the zero VAT rate (from 1 January) and Resolution No. 538 renaming and extending Almaty Innovation & Financial Zone (from 22 June); alongside them stand Law No. 256-VIII (from 11 July), Law No. 321-VIII (from 25 August), Resolution No. 301 creating ITLC “Alatau” (from 21 April) and the updated foreign-labour rules (from 12 July). The summary below states which changes affect whom.

Change	Act and provision	In force from	Who is affected
Non-core activities regime abolished: sub-pa­ra­graphs 5-1)–5-3) of article 1, article 41-1 and article 17(9)(2) excluded	Law No. 324-VIII, paragraph 14	25.08.2026	persons operating in zones under non-core activity agreements
“Production area” defined (article 1(15-1)) and a 30 % cap on non-pro­du­ction area for manufacturing	Law No. 324-VIII	25.08.2026	new manufacturing participants
Share of territory for auxiliary activities cut from 50 % to 20 %	Law No. 324-VIII, article 17(3)	25.08.2026	management companies; auxiliary operators
Statutory selection criteria for manu­factu­ring: products not made in Kazakhstan, or whose domestic production does not meet demand	Law No. 324-VIII, article 18(6)	25.08.2026	manufacturing applicants
Mandatory contents of the agreement: schedule, capacities; counte­r-obli­gation for manufacturing	Law No. 324-VIII, article 18(10)	25.08.2026	new agreements
Constru­ctio­n-delay threshold for unilateral termination cut from six to three months	Law No. 324-VIII, article 20(3)(1)	25.08.2026	all participants, including existing ones
Right to amend the schedule no more than three times	Law No. 324-VIII, article 41(1)(5-1); article 46(1)(2-1)	25.08.2026	SEZ and industrial zone participants
Conditions for Government extension of an SEZ: more than 20 % undeveloped territory or potential investors	Law No. 324-VIII, article 17(1)	25.08.2026	zones with expiring terms
Right to extend the agreement to the project term by category for participants who signed five years before 1 January 2024	Law No. 324-VIII, article 58(7)	25.08.2026	“legacy” participants
Reference to article 462 of the former Tax Code replaced by article 536 of Code No. 214-VIII	Law No. 324-VIII, article 18(2)(2)	25.08.2026	technical
Social tax reduction for the “Park of Innovative Technologies” removed; exclu­ded-pe­rsons list expanded	Code No. 214-VIII, articles 734–735	01.01.2026	digital participants; holders of investment agreements, Astana Hub and AIFC participants
Asset-level anti­-sta­cking: assets of SEZ participants’ priority activities are not objects of investment tax preferences	Code No. 214-VIII, article 283(3)(6)	01.01.2026	all participants
Goods lists for the 0 % VAT rate for 11 zones	Order No. 466 of the Ministry of Industry and Construction of 30.10.2025	01.01.2026	participants’ suppliers
PIT renamed Almaty Innovation & Financial Zone; term to 31.12.2049	Resolution No. 538 of 22.06.2026	22.06.2026	the zone’s participants
Creation of ITLC “Alatau” (Kordai district, to 31.12.2051)	Resolution No. 301 of 21.04.2026	21.04.2026	logistics projects
“Scie­nce-inte­nsive territory” — exception to conversion into an industrial zone on abolition	Law No. 321-VIII, article 24	25.08.2026	future zones on scie­nce-inte­nsive territories
“Information and communication technologies” replaced by “digital technologies” in articles 18 and 58	Law No. 256-VIII	11.07.2026	terminology
Registration of forei­gn-la­bour applications in the “Foreign Labour” digital system, minutes per organisation	joint order No. 134/182 of 14–15.04.2026	12.07.2026	participants with projects above 1,000,000 MCI

What matters for current participants

Three changes apply to everyone, not only to new agreements: the three-month delay threshold, the new monitoring procedure of article 42 and asset-level anti-stacking. The stability clause of article 735(12) of the Tax Code protects only the size of the tax and fee reductions — it does not extend to the termination grounds in Law No. 242-VI or to procedural rules. A participant whose construction schedule had already slipped risked termination for a delay of more than six months before 25 August 2026, and from that date for more than three, and Law No. 324-VIII contains no transitional provision on the point.

What matters for future participants

A manufacturing applicant will have to show that the product is not made in Kazakhstan or that domestic production does not meet demand — a criterion the Law states but without a verification methodology; the agreement must contain a counter-obligation “in accordance with the legislation of the Republic of Kazakhstan”, the content of which the Law itself does not disclose either. Until subordinate rules appear, both provisions will be applied at the discretion of management companies and the Ministry of Industry and Construction, and applicants should request their position in writing before preparing the feasibility study.

Defects and inconsistencies in the current acts that must be taken into account

As at September 2026 the SEZ regulatory framework contains at least nine discrepancies between acts or within a single act — from stale references to excluded articles to a wrong cross-reference to chapter 80 instead of chapter 81 inside the Tax Code itself. None of them invalidates the regime, but each creates a zone of discretion for the management company, the tax authority or the customs authority, and each should be closed by the wording of the activity agreement or by written clarifications.

No.	Discrepancy	Where	Practical significance
1	The fourth part of article 17(1) preserves the participant’s rights for the term of an “investment agreement under article 295-2 of the Entre­preneu­rial Code” with investment of at least 15,000,000 MCI. Since 1 January 2026 article 295-2 governs the investment obligations agreement, the investment agreement is article 283-1, and the 15,000,000 MCI threshold matches neither instrument (200,000–5,000,000 and from 75,000,000 MCI). Law No. 324-VIII restated the second part of the same paragraph and added a new third part, but left the inve­stment-a­greement text (now the fourth part) unchanged	Law No. 242-VI	the rule preserving the regime for the term of the agreement is effectively inapplicable to new agreements
2	Article 58(6) brings into force “the provisions of the second part of article 51”, whereas article 51 is divided into paragraphs, and article 58(7) refers to “paragraph 2 of article 51”	Law No. 242-VI	technical imprecision; read as paragraph 2
3	Article 1(4) and article 58(1) call the zone the “Park of Innovative Techno­lo­gies”, renamed Almaty Innovation & Financial Zone by Resolution No. 538; article 58(1) limits the right to operate outside the zone’s territory to 1 January 2028, while the zone’s term has been extended to 2049	Law No. 242-VI; Resolution No. 538	the right of digital participants to operate outside the territory after 2028 requires a separate legislative decision
4	Article 592(5)(3) of the Tax Code grants the 0 property-tax rate to “a person that has concluded an investment agreement subject to the provisions of chapter 80” — the SEZ chapter; the same land-tax benefit in article 582(2)(4) correctly refers to chapter 81	Tax Code	a technical cro­ss-refe­rence error; it does not affect the inve­stment-a­greement holder’s benefit
5	Articles 479, 525 and 735 of the Tax Code grant exemptions under a special investment contract; article 295-1 of the Entre­preneu­rial Code on that contract was excluded from 1 January 2026 by Law No. 215-VIII	Tax Code; Entre­preneu­rial Code	the benefit is available only under previously concluded contracts
6	The list of priority activities (Order No. 72 of 22.02.2024 as amended to Order No. 96 of 12.03.2026) contains 16 sections and no sections for SEZ “Atyrau” (created 01.12.2025) or ITLC “Alatau” (created 21.04.2026)	Order No. 72 of the Ministry of Industry and Construction	until sections are added, an applicant in those zones cannot substantiate a priority activity
7	Order No. 466 on the goods lists for the 0 % VAT rate calls the zone “Chemical Park Taraz”, renamed Jibek Joly in 2020, and contains no lists for seven zones	Order No. 466 of the Ministry of Industry and Construction	suppliers to seven zones cannot apply the 0 % rate under article 470
8	The legislation page of the sez.qa­zindustry­.gov.kz portal refers to Tax Code No. 120-VI, repealed from 1 January 2026	coordination centre portal	the portal cannot be relied on to identify Code articles
9	In the footnote to Law No. 242-VI on Adilet the Law of 19.05.2025 is shown as “No. 188-VII”; the actual number is 188-VIII	Adilet	cite as 188-VIII

Why this matters for the agreement

The management company concludes the agreement on the standard form, which reproduces the wording of the Law, including the reference to an “investment agreement under article 295-2”. An investor relying on preservation of the regime for the term of an investment agreement under article 17(1) must understand that since 1 January 2026 that provision points to a different instrument, and should insist that the agreement states the duration of the preferences directly, in years, by category A, B or C — the only construction that works without cross-references.

What to check before signing

Before signing, obtain from the management company the current version of the section of Order No. 72 for the specific zone with its activity codes, the appendix to Order No. 466 for the zone (if zero-rated supplies are critical to the model) and confirmation of the zone’s term under the current Government resolution — the three documents whose discrepancies are most often discovered only after construction has begun.

Step-by-step algorithm: from choosing a zone to the first year in the regime

Entering an SEZ takes, from choosing the zone to entry in the register, at least 15 working days under the Law (10 working days from filing to signature of the agreement under article 18(10) and 5 working days for entry in the register under article 18(12)), but a realistic timeline, allowing for document preparation, financial security and agreement of the land plot, is three to six months. The algorithm below follows Law No. 242-VI, Orders No. 599 and No. 72 and chapter 80 of the Tax Code.

1.        Check the status exclusions. Confirm that the company is not a subsoil user, a producer of excisable goods, a user of a special tax regime, a party to an investment agreement, or an Astana Hub or AIFC participant (article 18(2) of the Law; article 734(3) of the Tax Code). A status exclusion cannot be avoided by creating a project company if that company itself falls under the same criterion.

2.        Match the project’s activity code to the section of Order No. 72 for the specific zone. The priority activity is determined by the list section for the zone where the project will be; there are no sections yet for “Atyrau” and ITLC “Alatau”. If the code is missing, initiate its inclusion under article 19 of the Law before applying.

3.        Choose the zone by term and profile. Compare the zone’s term with the project horizon: category C gives 25 years of benefits, but no longer than the zone’s term and the agreement. “Astana – New City” runs to 2027 and “Seaport Aktau” to 1 January 2028; for projects with a horizon beyond five years, zones running into the 2040s are preferable.

4.        Model the economics of the regime. Calculate the effect of the 100 % CIT reduction on priority income, zero land and property tax, the free customs zone procedure for the equipment list and — separately — the “exit balance”: duties, VAT and interest on completing the procedure after 5, 10 and 15 years. Remember that suppliers may decline to apply the 0 % rate under article 470.

5.        Determine category A, B or C. Project value in MCI as at 1 January of the application year: up to 3,000,000 MCI — A (7 years), from 3,000,000 to 14,500,000 — B (15 years), from 14,500,000 — C (25 years); for food, textiles, leather, electronics and electrical equipment, category B is available from 1,000,000 MCI (article 51 of the Law).

6.        Prepare the financial security. At least 10 % of the project cost in cash, guarantee, suretyship, pledge or insurance (article 18(16)); schedule confirmation of the balance within two years (three years for a project above 15,000,000 MCI).

7.        Assemble the eleven-document package under article 18(3) and Order No. 599, including a feasibility study with schedule and capacities; for manufacturing, a justification of the “product not made or not meeting demand” criterion (article 18(6)) and a draft counter-obligation.

8.        File the application with the management company and obtain either the agreement or a reasoned refusal within 10 working days of filing (article 18(9)–(10)); on refusal, cure the grounds and re-apply — a refusal does not bar a new application.

9.        Conclude the activity agreement with the schedule, capacities and construction and commissioning deadlines (articles 17(9) and 18(10)); write into the agreement the delay-notification procedure and what counts as good reason, since the Law does not define them.

10.    Obtain the certificate and entry in the register within 5 working days (article 18(11)–(12)); register with the tax authority at the location within the zone (article 734(1)(2) of the Tax Code) and close, or convert into representative offices, any branches outside the zone.

11.    Formalise the land and the customs regime. Sign the sub-lease with the management company; agree the site layout within the 30 % cap on non-production area; file the first declaration placing goods under the free customs zone procedure and set up records under article 283(7) of the Customs Code with identification of components.

12.    Build control over deadlines and reporting. The annual report to the management company (article 41(2)(1) of the Law), reporting to the customs authority, separate accounting of income from priority activities, monitoring of the three-month delay threshold and the two-month suspension threshold, and a schedule with headroom for no more than three amendments. Missing the second-year deadline to confirm financial security is the most common cause of termination, and a calendar prevents it.

Typical mistakes of SEZ participants and what they cost

Eight of the ten mistakes below stem not from ignorance of the benefits but from underestimating the conditions for keeping them: deadlines, records, group structure and the customs “exit”. Each is priced — in terms of lost benefit, additional assessment or termination.

1.        A branch or warehouse outside the zone. The condition in article 734(1)(3) of the Tax Code is the absence of branches and separate subdivisions outside the SEZ, other than representative offices. A regional warehouse registered as a branch removes the right to the chapter 80 preferences for the tax period in which the condition is not met: the company ceases to be an “organisation operating on SEZ territory” within the meaning of the Code. Cost: 20 % CIT on all priority income for the period plus late-payment interest.

2.        Counting on 0 % VAT from suppliers. The rate under article 470 is the supplier’s right, not its duty; the goods must be on the Order No. 466 list, and seven zones have no list. A model built on VAT-free purchases loses 16 % of working capital until offset if the supplier declines.

3.        Missing the financial-security confirmation deadline. The balance of the security must be confirmed within two years (article 18(17) of the Law); bank-financed projects often fail to make it. Cost: termination under article 20(1) and annulment of the preferences.

4.        Suspending production without consent. A stoppage of more than two calendar months without the management company’s consent is a stand-alone termination ground (article 20(3)(2)). A ten-week scheduled line overhaul without written consent formally falls within the rule.

5.        No identification of components. Without identification under article 286 of the Customs Code, duties on release of output onto the EAEU market are calculated on the finished article at the rates of the breach date, not on the components at the rates of the import date (article 289(2), article 288(9)). Cost: the rate differential plus loss of lower historical rates.

6.        Ignoring the “exit balance”. On loss of status the free customs zone procedure must be completed within six months with payment of duties, VAT and interest at the base rate for the entire period (articles 287–288). For equipment imported ten years ago the interest can exceed the duty itself.

7.        Mixing priority and auxiliary statuses within a group. A group service company on an auxiliary activity gets no article 735 preferences and pays for land; moving part of the production functions to it “for convenience” reduces the main participant’s preferential income.

8.        Applying preferences twice to the same asset. The investment tax preferences of articles 283–285 of the Tax Code do not apply to assets of an SEZ participant’s priority activities (article 283(3)(6)). A claimed accelerated deduction is annulled from the start of its application under article 285.

9.        Writing off losses without VAT. Loss of goods received VAT-free under the free customs zone procedure is sales turnover at book value (article 452(1)(7), article 462(13)). Defects and shortages in such goods create VAT payable that is absent from the production budget.

10.    Betting on “stability” instead of reading new acts. The clause in article 735(12) protects only the size of the tax and fee reductions and does not operate on unilateral termination; it does not protect against changes to the termination grounds (three months instead of six from 25 August 2026), the monitoring procedure or customs rules. Cost: termination under a rule that did not exist when the agreement was signed.

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

The SEZ regime is designed for manufacturing and logistics projects with a horizon of seven years or more, imported equipment and a readiness to fix the construction schedule to the month; it does not suit companies with a distributed structure, trading and service models, or projects that need a site outside the existing zones. The criteria below allow the decision to be taken in a single meeting.

It suits

Export-oriented or import-substituting production in the zone’s priority sectors, where a 100 % CIT reduction for 7–25 years and zero land and property tax are material to payback; projects with imported process equipment of a value at which the deferral of duties and VAT under the free customs zone procedure is comparable to a year’s profit; large projects above 1,000,000 MCI, where exemption from the foreign-labour quota during construction removes the constraint on installation; projects in port and logistics zones (“Seaport Aktau”, “Khorgos – Eastern Gate”, “Alatau”), for which the free customs zone procedure is part of the operating model rather than merely a benefit.

It does not suit

Companies with branches in other regions that are not prepared to convert them into representative offices; subsoil users, producers of excisable goods and users of special tax regimes — by express prohibition; trading and distribution models, since the benefits are tied to production in priority activities; projects dependent on zero-rated VAT purchases in zones without an Order No. 466 list; small businesses for which the loss of the simplified declaration outweighs the gain; and projects with a horizon under five years — the regime recovers its administrative cost only over the long run.

When a professional review is needed

A professional review is essential in four situations: when choosing between an SEZ and an investment agreement for a project above 5,000,000 MCI, where the difference in the benefit period and in the retrospective reach of annulment is measured in billions of tenge; when structuring a group with production and service companies, so as not to lose the preferences through a branch or mixed statuses; when planning the customs “exit balance” for equipment more than five years old; and on any construction-schedule slippage of more than two months — before the management company issues a notice. If the project involves registering a new Kazakh legal entity to participate in the zone, the starting point is the choice of form and tax residence — the options and the registration procedure are set out on our Kazakhstan business registration page, and an LLP with foreign participation is compared with a branch in our guide to an LLP in Kazakhstan for foreigners in 2026.

Frequently asked questions about Kazakhstan’s SEZs and industrial zones

What tax benefits does an SEZ in Kazakhstan give in 2026? An SEZ participant reduces CIT on income from priority activities by 100 %, applies coefficient 0 to land tax and the land-use fee and rate 0 to property tax (article 735(1) and (4) of Tax Code No. 214-VIII) for 7, 15 or 25 years depending on category A, B or C, and its suppliers may apply the 0 % VAT rate under the Order No. 466 list. The social tax reduction that applied to the “Park of Innovative Technologies” was removed from 2026.

How many SEZs does Kazakhstan have and which is the newest? As at 1 September 2026 there are 18 SEZs; the newest is ITLC “Alatau” in the Kordai district of Zhambyl region, created by Government Resolution No. 301 of 21 April 2026 for a term to 31 December 2051.

How does an SEZ differ from an industrial zone? An SEZ is a territory with a special legal regime including tax preferences and the free customs zone procedure; an industrial zone is a site with infrastructure, land under contract and a “one-stop shop”, but without tax or customs benefits for participants. The only benefit in an industrial zone is addressed to its management company (article 735(9) of the Tax Code).

Can a foreign company become an SEZ participant? A participant is a legal entity entered in the register (individual entrepreneurs are admitted only in the border SEZ — article 1 of Law No. 242-VI), so a foreign company participates through a Kazakh legal entity — usually an LLP with foreign participation; a branch cannot be a participant. A foreign legal entity also cannot buy a state land plot in the zone (article 17(3-2)).

What happens if the management company terminates the agreement? Tax preferences are annulled from the start of the tax period in which the breach occurred (article 735(3) of the Tax Code), the participant files additional returns within 30 calendar days, the land sub-lease ends, and the free customs zone procedure must be completed within six months with payment of duties, VAT and interest at the base rate (articles 287–288 of the Customs Code).

How long a construction delay leads to termination? From 25 August 2026 — more than three consecutive calendar months without good reason (article 20(3)(1) of Law No. 242-VI as amended by Law No. 324-VIII); previously the threshold was six months. Suspension of activity for more than two months without consent is a separate ground.

Does an SEZ participant need a permit for foreign workers? Not for projects worth more than 1,000,000 MCI during construction and assembly works and until one year after commissioning — within the list of categories and headcount approved by the inter-agency commission (article 36-1(2)(4) of the Law “On Migration of the Population”). Other projects are subject to the quota and permits.

Does an SEZ participant pay customs duties on equipment? Not when the equipment is placed under the free customs zone procedure, for as long as it stays in the zone and is used under the agreement (article 281 of the Customs Code). On release for domestic consumption or loss of status, duties and VAT are paid; for commissioned equipment, at the rates of the release date (article 289(1)).

Can an SEZ be combined with an investment agreement or Astana Hub? No: parties to an investment agreement and Astana Hub and AIFC participants are excluded from the SEZ regime (article 734(3) of the Tax Code), and organisations in an SEZ are excluded from the investment agreement (article 283-1(4)(3) of the Entrepreneurial Code).

What is the term of SEZ “Astana – New City”? To 2027 under Decree No. 645 of 29 June 2001 and the Regulation approved by Resolution No. 772 of 24 November 2017; no extension act appears on Adilet as at 1 September 2026. Extension is possible by Government decision where more than 20 % of the territory is undeveloped or potential investors exist (article 17(1) of the Law).

Does the 0 % VAT rate apply to supplies into any SEZ? No: the goods lists in Order No. 466 are approved for 11 zones; there are no lists for “Astana-Technopolis”, ICBC “Khorgos”, “Alatau”, “Aktobe”, “Korkyt Ata”, “Atyrau” and ITLC “Alatau”. For ICBC “Khorgos” as a border SEZ, article 471 of the Tax Code applies, where no list is needed.

What is a special industrial zone? A variety of private industrial zone on whose territory international building codes and standards may be applied directly (article 1(7-1) of Law No. 242-VI); the landowner may act as management company itself, sell plots to participants after commissioning, and must maintain the engineering infrastructure and fire service at its own expense (article 33-1).

Key takeaways

Kazakhstan’s SEZ regime in 2026 means four tax preferences for 7–25 years, the free customs zone procedure and free land in exchange for keeping to the construction schedule, providing financial security and having no branches outside the zone; the price of breach is retrospective annulment of the benefits and six months for the customs “exit”.

•          Kazakhstan has 18 SEZs; “Astana – New City” runs to 2027, “Seaport Aktau” to 1 January 2028 and ITLC “Alatau” to 2051. The zone’s term caps the category C benefit period.

•          A 100 % CIT reduction on priority activities, coefficient 0 for land tax and the land-use fee, rate 0 for property tax — for 7 years (A, up to 3,000,000 MCI), 15 years (B, up to 14,500,000 MCI) or 25 years (C); the social tax reduction was removed from 2026.

•          The 0 % VAT rate is the supplier’s right under the Order No. 466 lists, approved for 11 of the 18 zones; exempt turnover between participants is under article 474(35) of the Tax Code.

•          The free customs zone procedure defers rather than cancels duties: on loss of status, six months to complete, rates of the import date (for equipment, the release date) and interest at the base rate for the whole period.

•          From 25 August 2026 a construction delay of more than three consecutive months is a ground for unilateral termination without warning; the stability clause gives no protection against it.

•          A participant is a Kazakh legal entity (in the border SEZ, also an individual entrepreneur) without branches outside the zone; subsoil users, excisable production, special tax regimes, investment agreements, Astana Hub and the AIFC are excluded.

•          An industrial zone gives a site, land and a “one-stop shop” but no tax benefits to participants and bars the simplified declaration; the property-tax benefit is addressed to its management company.

•          The acts contain at least nine inconsistencies — from article 17’s reference to the superseded version of article 295-2 of the Entrepreneurial Code to the absence of priority-activity sections for the two newest zones; each should be closed in the agreement.

Summary 

Kazakhstan’s special economic zones (SEZs) are governed by Law No. 242-VI of 3 April 2019 “On Special Economic and Industrial Zones” (as amended by Law No. 324-VIII of 24 June 2026, in force from 25 August 2026), chapter 80 of Tax Code No. 214-VIII (articles 734–735, from 1 January 2026) and chapter 29 of the Code “On Customs Regulation” No. 123-VI. An SEZ participant is a Kazakh legal entity on the register (in the border SEZ, also an individual entrepreneur), registered with the tax authority within the zone, with no branches outside the zone and carrying out a priority activity under Order No. 72. Benefits: a 100 % CIT reduction, coefficient 0 for land tax and the land-use fee, rate 0 for property tax for 7/15/25 years by category A/B/C (up to 3,000,000, up to 14,500,000, from 14,500,000 MCI; the 2026 MCI is 4,325 tenge), a 0 % VAT rate for suppliers under Order No. 466 (11 zones), the free customs zone procedure, free land, and exemption from the foreign-labour quota for projects above 1,000,000 MCI. Conditions: financial security of 10 % on application and the balance within two years (three above 15,000,000 MCI), a construction schedule, an annual report. Loss of status: a construction delay of more than three months, a suspension of more than two months, failure to remedy breaches within 60 days, failure to confirm security; consequences — annulment of preferences from the start of the breach period (article 735(3)), additional returns within 30 days, completion of the customs procedure within six months with duties, VAT and interest (articles 287–288 of the Customs Code), termination of the land sub-lease. Kazakhstan has 18 SEZs (as at 1 September 2026) and 67 industrial zones (register of 19 December 2025); industrial zones give participants no tax benefits. Prepared by UPPERSETUP, September 2026.

Sources

All links lead to official texts in the “Adilet” legal information system of the Ministry of Justice of the Republic of Kazakhstan (tier 1), official acts of the Government and ministries, QazIndustry registers and — for statistics — Kazinform news agency reports reproducing data of the Ministry of Industry and Construction (tier 2, marked). Texts were verified as at 1 September 2026.

Laws and codes

1.        Law of the Republic of Kazakhstan No. 242-VI of 3 April 2019 “On Special Economic and Industrial Zones” — as in force on 25 August 2026.

2.        Code of the Republic of Kazakhstan No. 214-VIII of 18 July 2025 “On Taxes and Other Mandatory Payments to the Budget (Tax Code)” — chapter 80 (articles 734–735), articles 42, 56, 283, 452–453, 460, 462, 467, 470–471, 474, 479, 503, 525, 582, 592, 622, 723, 738–741.

3.        Code of the Republic of Kazakhstan No. 123-VI of 26 December 2017 “On Customs Regulation in the Republic of Kazakhstan” — chapter 29 (articles 281–291), article 93.

4.        Customs Code of the Eurasian Economic Union — chapter 27 (articles 201–210).

5.        Entrepreneurial Code of the Republic of Kazakhstan No. 375-V of 29 October 2015 — articles 283-1, 283-2, 295-2.

6.        Law of the Republic of Kazakhstan No. 477-IV of 22 July 2011 “On Migration of the Population” — article 36-1.

7.        Law of the Republic of Kazakhstan No. 207-V of 10 June 2014 “On the Innovation Cluster «Astana Hub»” — article 7-1.

8.        Constitutional Law of the Republic of Kazakhstan No. 438-V of 7 December 2015 “On the Astana International Financial Centre” — articles 6, 8.

9.        Law of the Republic of Kazakhstan “On the Republican Budget for 2026–2028” — article 7 (MCI 4,325 tenge).

10.    Law of the Republic of Kazakhstan No. 86-VII of 27 December 2021 “On Industrial Policy” — articles 25, 27 (counter-obligations).

11.    Code of the Republic of Kazakhstan No. 120-VI of 25 December 2017 (Tax Code) — repealed from 1 January 2026; cited only for comparison of chapter 79.

Laws amending Law No. 242-VI

12.    Law No. 324-VIII of 24 June 2026 — in force from 25 August 2026.

13.    Law No. 321-VIII of 24 June 2026 — in force from 25 August 2026.

14.    Law No. 256-VIII of 9 January 2026 — in force from 11 July 2026.

15.    Law No. 215-VIII of 18 July 2025 — investment-preference reform, in force from 1 January 2026.

16.    Law No. 220-VIII of 27 September 2025, Law No. 196-VIII of 24 June 2025, Law No. 188-VIII of 19 May 2025, Law No. 46-VIII of 12 December 2023, Law No. 223-VII of 19 April 2023, Law No. 177-VII of 30 December 2022, Law No. 87-VII of 27 December 2021, Law No. 26-VII of 1 April 2021, Law No. 399-VI of 2 January 2021.

Acts creating and governing the SEZs

17.    Presidential Decree No. 645 of 29 June 2001 “On the creation of the special economic zone «Astana – New City»”and Government Resolution No. 772 of 24 November 2017 (Regulations on SEZ “Astana – New City” and “Astana-Technopolis”).

18.    Presidential Decree No. 1166 of 18 August 2003 “On the creation of the special economic zone «Park of Innovative Technologies»” and Government Resolution No. 538 of 22 June 2026 (renaming as Almaty Innovation & Financial Zone, extension to 31 December 2049).

19.    Presidential Decree No. 853 of 26 April 2002 “On the creation of the special economic zone «Seaport Aktau»”, Decree No. 1605 of 6 July 2005 “Ontustik”, Decree No. 186 of 29 November 2011 “Pavlodar” and Government Resolution No. 624 of 6 October 2017 “On certain issues of special economic zones” (Regulations on SEZ “Seaport Aktau”, “Ontustik”, “Pavlodar”, ICBC “Khorgos”).

20.    Presidential Decree No. 495 of 19 December 2007 (NIPT) and Government Resolution No. 548 of 11 August 2021.

21.    Presidential Decree No. 181 of 24 November 2011 “Saryarka” and Government Resolution No. 277 of 28 April 2021.

22.    Presidential Decree No. 187 of 29 November 2011 “Khorgos – Eastern Gate” and Government Resolution No. 495 of 1 July 2025.

23.    Government Resolution No. 343 of 29 May 2019 (ICBC “Khorgos”, management company).

24.    Government Resolution No. 713 of 28 October 2020 (Jibek Joly).

25.    Government Resolution No. 693 of 29 October 2018 “On the creation of the special economic zone «TURAN»”.

26.    Government Resolution No. 758 of 11 October 2019 “On the creation of the special economic zone «Qyzyljar»”.

27.    Government Resolution No. 211 of 15 March 2023 “On the creation of the special economic zone «Alatau»”.

28.    Government Resolution No. 3 of 8 January 2025 “On the creation of the special economic zone «Aktobe»”.

29.    Government Resolution No. 336 of 14 May 2025 “On the creation of the special economic zone «Korkyt Ata»”.

30.    Government Resolution No. 1028 of 1 December 2025 “On the creation of the special economic zone «Atyrau»”.

31.    Government Resolution No. 301 of 21 April 2026 “On the creation of the special economic zone «Industrial Trade and Logistics Complex «Alatau»”.

Subordinate acts

32.    Order No. 599 of the Minister of Industry and Infrastructure Development of 31 July 2019 “On approval of the rules and criteria for selecting projects” — Ministry of Justice registration No. 19187.

33.    Order No. 72 of the Minister of Industry and Construction of 22 February 2024 (list of priority activities) — registration No. 34030, as amended to 12 March 2026.

34.    Order No. 466 of the Minister of Industry and Construction of 30 October 2025 (goods lists for the 0 % VAT rate)— in force from 1 January 2026.

35.    Order No. 519 of the Minister of Industry and Infrastructure Development of 18 July 2019 “On approval of the Rules for issuing the certificate of registration as an SEZ participant” — registration No. 19059, as amended by Order No. 25 of 27 January 2026.

36.    Order No. 217 of the Minister for Investments and Development of 5 April 2018 (goods not to be placed under the free customs zone procedure) — registration No. 16778.

37.    Joint Order No. 259 of the Minister of Labour and Social Protection of 29 June 2023 and No. 474 of the Minister of Industry and Infrastructure Development of 29 June 2023 (list of categories and headcount of foreign labour of SEZ participants) — registration No. 32958, as in force on 12 July 2026.

38.    Government Resolution No. 1041 of 24 November 2023 (list of persons for whom no foreign-labour permit is required).

Registers and statistics

39.    Unified register of SEZ participants as at 31 July 2026 (QazIndustry, PDF).

40.    Unified register of industrial zones as at 19 December 2025 (QazIndustry, PDF).

41.    QazIndustry portal of special economic and industrial zones, “Legal framework” section — as at 1 September 2026 refers to Tax Code No. 120-VI.

42.    Kazinform, 17 April 2026: “Over 41,000 jobs created in Kazakhstan’s SEZs” — data of the Ministry of Industry and Construction (tier 2).

43.    Kazinform, 6 August 2025: “34 small industrial zones under way in Kazakhstan, 54 more at application stage” — data of the Ministry of Industry and Construction (tier 2).

44.    Invest in Astana — the official investment-promotion portal of the city of Astana, “SEZ and IZ” section — statement that the term of SEZ “Astana – New City” expires in 2027 and the zone’s share of all SEZs’ output, taxes and exports (tier 2).

Disclaimer

This material is for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision, obtain individual professional advice that takes account of the specific situation, jurisdiction, company status and current regulatory requirements. The information is current as at September 2026.