By 2026 Kazakhstan runs three regulatory perimeters for financial and crypto business, each with its own law, regulator and entry logic. Astana hosts the AIFC — a common-law enclave with the AFSA regulator and a tax regime until 2066. Outside the centre, the National Bank regime for digital asset service providers has been in force since 1 May 2026: exchange operators need a licence, while trading-platform and DFA-platform operators undergo registration. Near Almaty, Alatau City is launching in stages under a special legal regime: the general mechanism for experimental regimes has applied since 1 July 2026, while the digital-asset provisions enter into force on 1 January 2027. This article compares the routes for a client buying and holding digital assets legally and for a company choosing the appropriate regulatory entry route.
Three perimeters in one country
Two questions set the fork: where the clients are — the AIFC perimeter runs international business on common law, the rest of the country is tenge retail under Kazakh law — and which asset: unbacked crypto, stablecoins, tokenised digital financial assets (DFA) or classic financial services.
| Perimeter | Law and regulator | Market-entry route | Who it fits |
|---|---|---|---|
| AIFC, Astana | Common law, AFSA as regulator, its own court | Banking, asset management, brokerage, DATF exchanges and digital asset custody | International exchanges, funds, export-oriented fintech |
| General Kazakh perimeter | Kazakh law; National Bank and ARDFM | Licence for exchange operators; registration for trading-platform and DFA-platform operators; bank licences issued by ARDFM | Tenge retail, banks, payment services |
| Alatau City, near Almaty | Constitutional Statute and administration acts; digital-asset rules require coordination with the National Bank and ARDFM | Separate digital-asset regulation from 01.01.2027; experimental regimes are a distinct general mechanism | Crypto payment and tokenisation pilots |
The third regime is the youngest. Under Article 90 of the Constitutional Statute, the general experimental-regime mechanism in Article 54 has applied since 1 July 2026; the digital-asset and financial-activity provisions in Articles 47 and 50 enter into force on 1 January 2027, and the statute as a whole on 1 July 2027. The city administration must make the rules for issuing and circulating digital assets by decision of the Council and in coordination with the National Bank and ARDFM. From 1 January 2027, Article 74 directs investment disputes to Kazakh courts or, at the investor's choice, one of the listed arbitral forums, including the AIFC International Arbitration Centre; it does not name the AIFC Court. The live example is Alatau City Bank with Binance Pay-based crypto acquiring in the National Bank sandbox.
The AIFC and AFSA: a common-law offshore perimeter
The AIFC runs on its Constitutional Statute: acts built on common-law principles, disputes in its own court, licences issued by AFSA — the Astana Financial Services Authority. The perimeter covers the classics — banking, asset management, brokerage, insurance, Islamic banking and takaful — plus digital assets.
The economic anchor is targeted rather than general. Under Article 6(3) of the AIFC Constitutional Statute, Centre participants are exempt from corporate income tax until 1 January 2066 on income from a closed list of financial services — Islamic banking, reinsurance and insurance brokerage, investment fund asset management with accounting and custody, brokerage, dealing and underwriting, and further services set by joint act — and a digital asset exchange is expressly carved out of that exemption.
The same services are VAT-exempt under Article 6(8-2). The Centre publishes its summary of benefits separately. The centre's architecture, court and individual programmes live in the AIFC profile; here, the licensing mechanics.
The centre's crypto licence is Operating a Digital Asset Trading Facility, DATF: organising trading in digital assets, with custody and management authorised separately. Firms are verified against the public register at publicreg.myafsa.com. Startups enter via the FinTech Lab sandbox.
Schedule 8 of the AIFC Fees Rules sets the centre's fees: entry and annual supervision are calculated on different bases.
| Fee | Schedule 8 basis | For a DATF |
|---|---|---|
| Pre-application fee | Fixed amount | USD 2,000 |
| Firm's application fee | 30% of the Schedule 1 or 2 fee | USD 29,400 (30% of USD 98,000) |
| Annual supervision, Regulated Activities | 40% of the fee | — |
| Annual supervision, Market Activities | 30% of the fixed fee plus a 0.001% levy | — |
| Approved Individual application | Fixed amount | USD 200 |
One-off DATF entry combines the pre-application and application fees; the USD 200 applies to each Approved Individual application, not the firm's.
DATF exchanges: Binance KZ, Bybit KZ and the market in numbers
The AIFC crypto segment is no showcase. Per the AIFC, January–September 2025 volumes on licensed platforms reached $6.8 billion, 29 licensed digital asset service providers operated, including 12 exchanges, the client base hit 192 thousand and 113 assets cleared the sandbox's Green List. The count moves quarterly, and it is checked against the register before a deal.
The flagships are global brands. Both venues announced full licences in autumn 2024: Bybit on 27 September, Binance Kazakhstan on 1 October; the current scope of each permission is checked against the AFSA register. Bybit operates via bybit.kz, in November 2025 launched the country's first fully regulated P2P platform, and pays AFSA regulatory fees in stablecoins. Local venues ATAIX Eurasia and Intebix sit alongside; the AFSA register shows ATAIX Eurasia Ltd. holding licence AFSA-A-LA-2025-0022 of 15 October 2025, with operating a digital asset trading facility, dealing and custody among its permitted activities. AFSA regularly warns about unlicensed platforms; the AML load on licensees is covered in the Travel Rule explainer.
The National Bank framework since 1 May 2026: crypto beyond the AIFC perimeter
Until 2026, legal crypto lived only inside the AIFC: the baseline Law on Digital Assets No. 193-VII of 6 February 2023 prohibited the issuance and circulation of unbacked digital assets outside the centre. The turn came with the amendments of 16 January 2026 "on the regulation and development of the financial market, communications and bankruptcy". Precision matters: amendments to the existing law, not a "new edition" — signed in January, not in summer 2026 as often retold.
Since 1 May 2026 three provider types operate outside the AIFC, but only an unsecured digital asset exchange operator obtains a National Bank licence: it conducts dealer operations for exchange, purchase and sale on behalf of clients. DFA-platform and trading-platform operators undergo registration with the National Bank and appear in separate registers. Mining stays with the digital development ministry. Capital requirements and limits for individuals sit in secondary regulations; no unified public limits exist in open acts, and the package is fixed against the National Bank site on the filing date.
The exchange-operator register contains two entries as at the last publication of the register file, 11 August 2026. Pax Finance LLP received the first licence on 30 June 2026 (operator registration No. 0126001О, Astana), and AUSU LLP received one on 30 July 2026 (No. 1726001О, Shymkent). The licensed activity is dealer operations for exchange, purchase and sale of unsecured digital assets; the operator's rules must also cover opening and maintaining digital asset wallets.
Pax Finance also announced plans for a crypto-ATM network; for scale, the authorities shut down about 130 illegal exchangers in 2025. The sequel is instructive: in early August the company announced crypto account top-ups from the Alatau City Bank app, the bank did not confirm the partnership, and the channel has been suspended since 5 August 2026 — no resumption announced. Regulated crypto banking in the general perimeter is being built more slowly than the press releases.
Who regulates what
The supervisory split remains a working feature of the market rather than a transitional defect:
| Question | Regulator |
|---|---|
| Exchanges, custody, funds and banks inside the AIFC perimeter | AFSA |
| Exchangers and trading platforms outside the AIFC | National Bank of Kazakhstan |
| Stablecoins | National Bank of Kazakhstan |
| DFA and the platforms they trade on | National Bank of Kazakhstan — keeps the register of DFA-platform operators |
| Banking licences and supervision outside the AIFC | ARDFM |
| Mining | Digital development ministry |
One group can hold an AFSA DATF licence for international business and a separate National Bank licence for dealer exchange operations outside the AIFC: legally these are two different regimes under different law. Neighbouring markets' answers to the stablecoin question are compared in Asian stablecoin regimes.
Banking Law No. 258-VIII and the digital tenge
The banking layer was rebuilt by the same January package: on 16 January 2026 the president signed the new Law on Banks and Banking Activity, replacing the 1995 statute.
Five changes matter for digital banks and fintech.
- Two licence categories: universal, and basic with reduced capital requirements.
- Banks may invest in fintech, AI, cybersecurity and e-commerce.
- "Islamic windows" for universal banks with segregated accounting.
- Recognition of the digital tenge as a form of the national currency. The three kinds of digital financial assets — stablecoins, DFAs whose base asset is financial instruments or other property except money, and financial instruments issued in digital form on a DFA platform — come not from this law but from the January amendments to the Law on Digital Assets (Law No. 259-VIII, in force for this part from 1 May 2026).
- A single financial ombudsman.
Entry-into-force dates for individual provisions are spread across the final clauses — check the current text on adilet.
The digital tenge runs in industrial operation, but in government scenarios: in 2025 ₸336.6 billion was issued, 265 accounts opened and 61,233 transactions processed — budget money marking and subsidy control, not retail wallets. The regulator has announced no mass retail launch date.
Where an individual buys and holds legally
There are four legal channels.
- AIFC exchanges — binance.kz, bybit.kz and other firms from the AFSA register: a full order book, Bybit's regulated P2P, standard KYC.
- National Bank-licensed exchange operators are a new channel; the register published on 11 August 2026 lists Pax Finance and AUSU.
- Eurasian Bank and Intebix crypto cards — the country's first, testing since September 2025, USDT auto-converted to tenge, $1,000 daily limit.
- Binance Pay-based Crypto Pay acquiring — QR and POS payments in the National Bank sandbox since July 2026.
Both stories are dissected in the Alatau City Bank profile.
The frame is standard: a bank account requires a local IIN and, as a rule, a personal visit — entry mechanics are in the residency guide; Russian passports go through enhanced sanctions screening with possible refusal. The retail heavyweights have not entered crypto: Kaspi and Halyk, the largest names on the country's retail banking market, have no public crypto products — they are waiting for the industrial stage, not the sandbox. Kazakhstan participates in the CRS and digital asset income is declared under the new Tax Code — "invisible" crypto is not part of this construction.
DATF, a National Bank licence or a bank via M&A
The choice comes down to market and asset.
A DATF in the AIFC
If the business is international: common law, a predictable regulator and the FinTech Lab sandbox. The tax side is assessed separately: the corporate income tax exemption running to 2066 under Article 6(3) of the Constitutional Statute does not extend to a digital asset exchange. The price is the centre's perimeter: nationwide tenge retail formally sits outside the operator's field.
A National Bank licence
If the product targets the domestic market and the firm itself conducts dealer operations for exchanging unsecured digital assets; trading-platform and DFA-platform operators undergo registration. The regime is young — the first licence is dated 30 June 2026, secondary rules are still being written, and the only public bank integration is suspended, so regulatory lag belongs in the plan from the start.
A banking licence
The heaviest entrance, though the new law's basic licence lowers the bar, and the Alatau City Bank case shows the alternative: buying an operating bank with its licence and client base instead of a greenfield build.
The tax frame is shared: since 1 January 2026 the Tax Code No. 214-VIII of 18 July 2025 has been in force — the article numbering changed completely, so old references in contracts, memos and legal templates now point into the void. It does not touch AIFC benefits: the regime running to 2066 sits in Article 6 of the Constitutional Statute, with the carve-outs that article sets out. Compare Kazakhstan's doors with other markets in the licence regime map.
The AIFC's real distinction only shows up against its competitors. Of twelve crypto regimes compared on capital, published fees, custody and segregation, substance, retail access and the travel rule in the map of crypto licences, the AIFC is one of only two that publish their whole price: US$200,000 of capital or twelve months of working capital, US$98,000 to be authorised and US$30,000 a year thereafter plus a variable quarterly component. The other is Dubai's VARA: Schedule 2 of the VA Regulations 2023 sets an application fee of AED 40,000 or AED 100,000 by activity and annual supervision of AED 80,000 or AED 200,000 per licensed activity, on top of AED 800,000 of capital for exchange services; the FSRA, the DFSA, the SFC, MAS, FINMA, the FSA and the FSC publish no fee schedule, and nine of the twelve regulators publish no determination target at all. What Kazakhstan does not offer is reach: like every regime on that grid except the MiCA CASP, an AFSA licence is territorial, so a firm that needs European clients is choosing a second authorisation rather than a cheaper first one.
Q/A
Where can an individual legally buy crypto in Kazakhstan?
On AIFC exchanges from the AFSA register — binance.kz, bybit.kz and others, including Bybit's regulated P2P; since late June 2026 also through National Bank-licensed exchange operators, and the current register lists Pax Finance and AUSU. Exchange outside licensed venues remains a grey zone: about 130 illegal exchangers were shut down in 2025. Step one: check the venue against the AFSA or National Bank registers.
How does an AFSA DATF licence differ from a National Bank licence?
A DATF operates inside the AIFC perimeter: common law, AFSA supervision and an international orientation; the Centre's tax reliefs are targeted and do not cover a digital asset exchange for corporate income tax purposes. Outside the AIFC, a National Bank licence is required for an exchange operator's dealer operations with unsecured digital assets; trading-platform and DFA-platform operators undergo registration. The two regimes do not substitute for each other.
What happened between Pax Finance and Alatau City Bank?
On 30 June 2026 Pax Finance received the National Bank's first licence for dealer exchange operations, and in early August announced crypto account top-ups from the Alatau City Bank app. The bank did not confirm the partnership, the posts were deleted, and the channel has been suspended since 5 August 2026 with no resumption announced. Bank integrations under the new framework arrive more slowly than the announcements.
Do AIFC benefits survive the new Tax Code?
Yes, but the relief is targeted. Article 6 of the AIFC Constitutional Statute exempts income from a closed list of financial services from corporate income tax until 1 January 2066 (paragraph 3) and the same services from VAT (paragraph 8-2), while a digital asset exchange is carved out of the corporate income tax exemption. The new code left those provisions intact. The trap is elsewhere: Tax Code No. 214-VIII renumbered its articles from 1 January 2026, so references to the old code in contracts and templates need re-checking.