Regulatory AlertsKazakhstan: fintech & payments regulation
RegulatedKazakhstan: Dual regime with AIFC VASP licensing and National Bank oversight
- Lead regulator
- National Bank of Kazakhstan (NBK) & Astana Financial Services Authority (AFSA)
- Also involved
- Financial Monitoring Committee (AML/CFT) · National Bank of Kazakhstan (Banking interface)
- Core law
- Law on Payment Systems and Transfer of Funds (2015) & AIFC Rules on Providing Money Services (2025)
- Entry capital
- USD 100,000 (AIFC VASP); KZT 100m (NBK Payment Institution)
- Approval timeline
- 3-6 months (NBK); 2-4 months (AIFC)
- Customer assets
- Segregated accounts required; no commingling
- Data protection
- Law on Personal Data and Its Protection (2013) · Personal Data Protection Committee
- Sandbox
- Yes - NBK Regulatory Sandbox
Kazakhstan operates a dual regulatory framework. The National Bank of Kazakhstan (NBK) regulates domestic payment institutions and money transfer operators under the Law on Payment Systems. Concurrently, the Astana International Financial Centre (AIFC) offers a common-law jurisdiction regulated by the AFSA, which introduced specific 'Rules on Providing Money Services' in 2025 to license VASPs and money service providers. The NBK maintains strict control over cross-border flows and AML/CFT compliance via the Financial Monitoring Committee.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | LicencePayment Institution License (NBK) / Money Service Provider License (AIFC)[1] NBK license required for domestic processing; AIFC for international/tech-focused models | KZT 100m (NBK); USD 100,000 (AIFC) | 3-6 months | NBK / AFSA |
| E-money & wallet issuance | LicenceElectronic Money Institution License[1] Strictly regulated under NBK framework; AIFC rules may cover crypto-wallets | KZT 100m | 3-6 months | NBK |
| Domestic money transfer | LicenceMoney Transfer Operator License[1] Domestic transfers require NBK authorization and FMC registration | KZT 100m | 3-6 months | NBK |
| Cross-border remittance | LicenceCross-Border Payment License[1] Cross-border flows subject to FMC reporting and NBK oversight | KZT 100m | 3-6 months | NBK |
| Agent network | RegistrationAgent Network Registration[1] Agents must be registered with the licensed Payment Institution | None | 1-2 months | NBK |
| Open banking / account information | Uncertainverify with regulator No specific open banking law; relies on general data protection and NBK guidelines | — | — | — |
| Foreign-exchange services | LicenceForeign Exchange Dealer License[1] FX services require NBK approval and compliance with currency control laws | KZT 100m | 3-6 months | NBK |
New — what changed recently
- 2025-05-30AIFC Rules on Providing Money Services — AFSA introduced specific licensing and capital requirements for Money Service Providers within the AIFC jurisdiction.[1]
- 2023-06-27AFSA Perimeter Guidance on Authorisation — Clarified regulatory scope and general prohibition against unregulated financial activities in the AIFC.[2]
- 2023-04-20Policy Statement on Start-up Banks — AFSA clarified risk-based approach for authorizing start-up banks, requiring parent institution backing.[3]
Market-entry checklist
- 1Choose Jurisdiction: NBK vs AIFCDecide between NBK domestic regulation or AIFC common-law framework based on target market.
- 2Secure Minimum CapitalDeposit KZT 100m for NBK or USD 100,000 for AIFC VASP license before application.
- 3Register with Financial MonitoringMandatory AML/CFT registration with the Financial Monitoring Committee is required for all payment entities.
- 4Submit License ApplicationFile detailed business plan, compliance manuals, and tech governance docs with NBK or AFSA.
- 5Establish Segregated AccountsOpen dedicated client money accounts with licensed Kazakh banks to ensure asset segregation.