Why Operators Consider Kazakhstan
Kazakhstan offers a common-law digital-asset regime that few jurisdictions outside Dubai can match on regulatory rigour, and none match at the same capital floor. The AIFC operates an English-language, English-law perimeter inside Kazakhstan with its own court, financial-services authority (AFSA), public register and consolidated digital-asset rulebook in force since 1 January 2024. The IOSCO Thematic Review of October 2025 placed the AIFC among four jurisdictions globally that fully implement all ten priority recommendations for crypto and digital-asset markets, alongside the UAE, Hong Kong and the EU under MiCA.
The AIFC’s 0% corporate tax regime until 2066 is genuine — but exchange operators are explicitly excluded and pay standard CIT of 20%, which inverts the economics for founders whose primary revenue is trading-venue operations and should be weighted heavily in the structuring decision.
The AIFC sits in the same top tier of IOSCO digital-asset implementation as the UAE and the EU, but its capital floors and authorisation costs are far lower than Dubai’s VARA framework. The base capital for operating a Digital Asset Trading Facility (DATF) is USD 200,000, against around USD 408,000 for a comparable VARA exchange services provider. For founders who want credibility that holds up in front of correspondent banks but cannot justify Dubai-scale capital at launch, Kazakhstan is the structurally cheaper route to a credible licence.
The supporting strengths are real. The crypto-to-fiat rail is operational rather than aspirational, with USD, KZT and EUR settlement under the AFSA cooperation framework. The tax regime is genuinely favourable, with 0% corporate income tax and VAT on qualifying financial-services income until 1 January 2066 (although exchange operators are excluded and pay the standard 20% rate). And the perimeter runs on the principles of English law, in English, through its own court and register, which keeps the interface familiar to founders from BVI, Singapore or DIFC and narrows the conceptual gap for those coming from the EU.
Regulatory Framework
The AIFC operates a special legal order inside Kazakhstan, established by the Constitutional Statute on the AIFC of 7 December 2015, which adopts the principles of English law within the AIFC perimeter and creates a financial-services regime separate from mainland Kazakhstan law. The primary digital-asset rulebook is the AIFC Rules on Digital Asset Activities (DAA), in force since 1 January 2024, with consolidated and amended versions taking effect on 1 January 2025 and 1 January 2026.
Definition: AIFC DASP
A Digital Asset Service Provider (DASP) is an entity authorised by AFSA to carry on one or more of ten regulated digital-asset activities within the AIFC perimeter, including operating a Digital Asset Trading Facility, dealing in or providing custody of digital assets, advising on or arranging deals in digital assets, and providing money services in relation to digital assets (which includes fiat-stablecoin issuance). The framework is governed by the AIFC Rules on Digital Asset Activities and supervised by AFSA. Conceptually, the AIFC DASP designation maps to the FATF Virtual Asset Service Provider (VASP) perimeter, although terminology differs.
Overlapping rule sets
Three rule sets can apply at once, depending on activity: the DAA itself; the AIFC AML/CFT/Sanctions Rules, which apply to every DASP and embed FATF Travel Rule obligations under Recommendation 16; and the AIFC Rules on Providing Money Services, which apply to stablecoin issuers. Separately, the mainland Kazakhstan AML law governs reporting to the Financial Monitoring Agency, into which AFSA-licensed DASPs file suspicious-transaction and suspicious-activity reports. Security tokens and tokenised real-world assets sit outside the DASP regime entirely, running through the separate AIFC Security Token Offering Framework rather than a digital-asset activity head.
Licence Types and Activities Covered
The AIFC recognises ten DASP activity heads under the DAA, each requiring a separate AFSA authorisation. A single legal entity can hold several, subject to AFSA approval of the business plan, capital and substance for each. The activities collectively cover the FATF VASP perimeter and broadly map to MiCA’s CASP services, although terminology and capital differ.
Covered activities
- Operating a Digital Asset Trading Facility (DATF): running a venue that matches buyers and sellers, with or without integrated custody. The flagship category.
- Dealing as principal or as agent: trading on own account, or executing for clients without taking principal risk.
- Managing investments or a collective investment scheme in digital assets.
- Providing or arranging custody of digital assets, including private-key management.
- Advising on, or arranging deals in, digital-asset investments.
- Providing money services: issuance, transmission and exchange of fiat- and commodity-backed stablecoins under DAA Part 4.
What falls outside the regime
Privacy-token activity is prohibited under the DAA, not merely unregistered. Issuance of unsecured digital assets to Kazakhstan residents outside the AIFC perimeter is prohibited under mainland law. Pure mining and validation falls under the mainland regime and the Astana Hub framework, so AIFC DASPs wishing to mine for their own account need separate consideration of mainland licensing. Kazakhstan-resident retail clients are subject to a monthly transaction cap and barred from margin trading on AFSA-licensed DATFs.
Requirements
AFSA applies an integrated set of capital, substance, governance, technology and AML requirements that scale by activity head. Capital floors run from USD 10,000 for advisory and arranging activity to USD 250,000 for principal dealers and custodians. In every case applicants must also hold liquid assets of at least 25% of annual operating expenditure, maintain physical presence on AIFC territory, and conduct their core income-generating activities there; outsourcing those activities outside Kazakhstan is not permitted.
Capital by activity
| Activity Head | Base Capital (USD) | Notes |
|---|---|---|
| Operating a DATF | 200,000 or 12 months working capital | With integrated custody: 250,000 |
| Dealing as Principal | 250,000 | Matched-principal only: 50,000 |
| Dealing as Agent | 50,000 | |
| Managing Investments | 100,000 | |
| Providing Custody | 250,000 | |
| Arranging Custody / Advising / Arranging Deals | 10,000 | |
| Providing Money Services (incl. fiat stablecoin) | 200,000 | Plus 1:1 segregated reserve for stablecoin issuance |
| Liquid asset floor | ≥25% of annual operating expenditure | Applies to every DASP |
Governance, substance and technology
DASPs must appoint Approved Individuals for several controlled functions, including Senior Executive Officer, Compliance Officer, Money Laundering Reporting Officer and Chief Information Technology Officer, each subject to a fit-and-proper assessment before regulated activity can begin. The AIFC Rules on Substantial Presence require participants applying the tax exemptions to conduct their core activities on AIFC territory, with commensurate expenditure and adequate full-time staff there; the test is verified through the annual tax audit, and failure removes the exemption retroactively. In practice this rules out the shell-with-virtual-office structure the headline capital figures might suggest. On technology, every DASP must keep a documented cyber-security policy, segregate hot- and cold-wallet holdings, reconcile book and on-chain balances daily, and commission an annual third-party technology-governance audit before authorisation and on each renewal.
Application Process
AFSA’s pathway runs from pre-application engagement through Authorisation In Principle to full licence, with a parallel company registration through the AIFC Registrar of Companies. The typical sequence is: form an AIFC entity; draft a three-year regulatory business plan with AML, custody, cyber and risk-mitigation policies and commission the mandatory third-party technology audit; submit through the AFSA Self-Service Portal with the application fee and Approved Individual applications; respond to one to three rounds of formal information requests; satisfy the conditions attached to Authorisation In Principle, including capital deposit and banking arrangements; and receive the full licence and a listing on the AFSA public register. The application language is English throughout. A well-prepared single-activity authorisation can complete in roughly four months; DATFs and multi-activity packages routinely run six to twelve months. The FinTech Lab on-ramp adds a further six to eighteen months between entry and full-regime migration, but reduces the capital and fee burden during testing and is the route AFSA recommends for novel models.
Taxation
The AIFC operates one of the most favourable special tax regimes in Eurasia, but with one carve-out that founders frequently miss. AIFC participants pay 0% corporate income tax and 0% VAT on qualifying financial-services income until 1 January 2066, and foreign employees are exempt from personal income tax on AIFC employment income, all conditional on satisfying the Substantial Presence Rules. Digital-asset trading facility operators are explicitly excluded and pay the standard Kazakhstan corporate rate.
Headline rates
| Tax Type | Rate | Application |
|---|---|---|
| Corporate Income Tax (AIFC participant, non-DATF) | 0% | Until 1 January 2066, subject to substance test |
| Corporate Income Tax (DATF operator) | 20% | Standard rate; AIFC exemption does not apply |
| VAT (AIFC participant, qualifying) | 0% | Until 2066, subject to substance |
| Personal Income Tax (foreign AIFC employees) | 0% | On AIFC employment income only |
Kazakhstan implements the Common Reporting Standard and is on the adoption pathway for the OECD Crypto-Asset Reporting Framework. Every exemption is conditional on satisfying the Substantial Presence Rules, verified through the annual tax audit; failure removes it retroactively to the start of the relevant year.
Banking
The AIFC has one of the more developed crypto-to-fiat banking rails in Central Asia, anchored by formal cooperation between AIFC-licensed exchanges and Kazakhstan second-tier banks since the National Bank and AFSA signed implementing rules in January 2024. AIFC DASPs can open KZT, USD and EUR accounts with cooperating second-tier banks, while international correspondent access is more selective and turns on each institution’s own risk appetite. Onboarding typically takes 30 to 90 days, with the usual friction around source-of-funds documentation, beneficial-ownership disclosure and sanctions screening where a controller is Russian-origin or has CIS exposure.
For the operators we work with, banking is a supporting concern rather than the headline. Where we deliver licensing, we help arrange accounts with a credit institution or a licensed EU electronic money institution as part of the engagement, so a licence is not left as a certificate on the wall.
FATF Status and EU Market Access
Kazakhstan is a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism, a FATF-style regional body, and is not on the FATF grey or black list. The AIFC has independently achieved international recognition: the IOSCO Thematic Review of October 2025 identified it as one of four jurisdictions globally fully implementing all ten priority recommendations on crypto and digital-asset markets, and AFSA is a signatory to the IOSCO multilateral memoranda of understanding.
MiCA contains no third-country equivalence regime for digital-asset service providers, and AFSA has not announced an equivalence application. Where the EU is your target market, a member-state CASP authorisation is the route, and it is one we deliver in Lithuania, Cyprus and Malta.
Advantages and Limitations
The AIFC presents a coherent set of trade-offs rather than a uniformly easy or hard choice. The decision turns on target market, activity mix and tolerance for the AIFC’s substance bar.
- IOSCO top-four recognition alongside the UAE, Hong Kong and the EU.
- 0% corporate tax until 2066 for non-DATF DASPs, subject to the substance condition.
- Common-law environment with an English-language regulator and court.
- Capital floors below VARA across every tier.
- An operational crypto-to-fiat banking rail with KZT, USD and EUR settlement.
- × No EU passporting. The licence confers no right to serve EU residents; the EU route is a member-state CASP authorisation.
- × DATF tax carve-out. Exchange operators pay standard CIT of 20%.
- × A genuine substance bar. AFSA requires on-territory activity, office space and full-time AIFC-based staff.
- × Banking friction for Russian-origin controllers at the international correspondent layer.
How Kazakhstan Compares
The natural peer set is Kyrgyzstan within the CIS bloc and the UAE as the regional regulatory upgrade. The AIFC sits clearly above Kyrgyzstan on regulatory rigour and banking access, and below the UAE on capital deployment cost while matching it on IOSCO recognition.
| Factor | Kazakhstan (AIFC) | Kyrgyzstan | UAE (VARA, Dubai) |
|---|---|---|---|
| Regulator | AFSA | Financial Market Regulation Service | Virtual Assets Regulatory Authority (VARA) |
| Timeline | 4–12 months | 3–6 months | 4–18 months |
| Min. Capital | USD 10,000–250,000 by activity | Higher fixed floors for exchange operators | Around USD 27,000–408,000 |
| Corporate Tax | 0% (DATF: 20%) | 10% standard | 9% federal CIT |
| Local Presence | AIFC office + on-territory activity + resident staff | Kyrgyz entity + minimal substance | Dubai office + UAE staff |
| EU Passporting | No (reverse solicitation only) | No | No |
| Best For | IOSCO-grade operators serving CIS, MENA, APAC | Lightest-touch CIS entry point | Global Tier-1 operators with deeper capital |
Kyrgyzstan competes on cost and timeline, not on regulatory depth; the AIFC’s capital floors are higher but its regulatory standing and crypto-fiat banking rail are materially stronger. The UAE outranks Kazakhstan on institutional banking depth and global brand recognition, but at several times the all-in first-year cost.
Frequently Asked Questions
What is the minimum capital for an AIFC DASP licence?
Minimum capital ranges from USD 10,000 for advising, arranging deals and arranging custody, through USD 50,000 for dealing as agent, USD 100,000 for managing investments, USD 200,000 for DATFs and money services, to USD 250,000 for providing custody and dealing as principal. Multi-activity applications combine the activity-specific floors, and every DASP must additionally hold liquid assets of at least 25% of annual operating expenditure.
Does an AIFC DASP licence give access to the EU market?
No. An AIFC DASP licence does not grant EU market access or passporting rights, and MiCA contains no third-country equivalence regime for digital-asset service providers. Operators seeking systematic access to EU clients should obtain a CASP authorisation in an EU member state. We deliver crypto licensing in serviced EU jurisdictions including Lithuania, Cyprus and Malta.
Is Kazakhstan on the FATF grey list?
No. Kazakhstan is a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism, a FATF-style regional body, and is not on the FATF grey or black list. The AIFC has also been recognised by the IOSCO Thematic Review of October 2025 as one of four jurisdictions fully implementing all ten priority crypto-asset recommendations.
Does Tomberg & Partners file licences in Kazakhstan?
Talk to us about your options
We can tell you whether the AIFC suits your business, and deliver crypto licensing in the jurisdictions we serve, including Lithuania, Cyprus, Gibraltar, Malta, Poland, Switzerland and Bosnia. One accountable firm, start to finish.
Banking & Payments
A company and a licence still need a bank account
Banking is one of our three core services. We help high-risk and regulated businesses open the bank and payment accounts that others refuse: we work directly with EU EMIs, payment institutions and crypto-aware banks, confirm appetite before you apply, and make the introduction. Take it with your company and licence, or on its own.
Related Services
- Crypto Licensing Overview: the jurisdictions we deliver, and a VASP, CASP and MiCA primer
- Company Formation: entity formation across the jurisdictions we serve
- Reverse Solicitation Under MiCA: the EU market-access framework for non-EU licensees
- Solutions for Crypto Exchanges: end-to-end support for trading-venue operators