Legal News — September 2026 - FCHAIN

Legal News — September 2026

In September 2026, a number of legislative changes come into effect in Kazakhstan, affecting construction, employment relations, migration, business activities, notarial services, financial reporting, digitalization, public procurement, and other areas. Businesses should take the new requirements into account when preparing documents, interacting with government authorities, employing foreign workers, and carrying out certain types of activities.

 

Construction: Turnkey Projects and New Demolition Rules

Starting September 14, government obligations under turnkey construction projects are divided into two categories depending on the type of customer. If the customer is a budget program administrator, government obligations cover the rights and obligations of the customer and supplier within the amount allocated from the budget in relation to financial obligations under turnkey construction contracts that have been assumed but remain outstanding and have been approved by the relevant budget commission. If the customer is a quasi-public sector entity, the obligations under turnkey construction contracts and the related agreements on the assumption of government obligations concluded between the budget program administrator, the customer, and the supplier are taken into account. Such agreements must be preceded by an agreement between the budget program administrator and the quasi-public sector entity. The amount of a turnkey construction contract may also be revised due to changes in the exchange rate of the national currency against a foreign currency. Such revision requires a decision of the relevant budget commission or maslikhat. Starting September 5, new rules for issuing decisions on the demolition of construction facilities apply. Design, construction and installation, engineering, and expert works must be performed by entities holding the required permits. When preparing a work execution plan for demolition, the results of a technical inspection of the reliability and stability of the facility must be taken into account. If demolition is carried out simultaneously with the construction of a new facility, construction must be performed on the basis of design documentation that has undergone comprehensive non-departmental expert review. A technical inspection is not required for facilities included in a renovation program. Demolition works must also include appropriate safety measures, temporary fencing, access roads, and construction waste disposal.

 

Pension Savings: New Investment Opportunities

Starting September 7, Kazakhstan citizens may transfer their pension savings into trust management by an investment portfolio manager. To do so, an application must be submitted to the Unified Accumulative Pension Fund (UAPF), specifying the selected investment portfolio manager and the relevant investment portfolio. The manager may form conservative, moderate, or high-risk portfolios. The contributor may independently determine the amount of pension savings to be transferred into trust management.

 

New Requirements for Medicines and Medical Devices

Kazakhstan is introducing a mechanism for conducting investigations in the area of medicines and medical devices. As part of such investigations, samples of medicines, medical devices, raw materials, and components may be collected for laboratory testing. The investigation identifies the causes of violations and determines the entities that failed to comply with legislative requirements. Following the investigation, a report is prepared specifying the identified violations, measures required to remedy them, and the relevant deadlines. The results of the investigation, except for information protected by law, must be published on the website of the relevant government authority within ten business days after the investigation is completed. In addition, the maximum cost of a control mark for the labeling of dietary supplements has been set at KZT 2.68 per unit, excluding VAT.

 

Digital Resources for Remote Medical Services

Requirements have been approved for digital resources used to provide remote medical services. These include telemedicine systems and platforms, NTMS, and wearable medical devices. Such systems must provide digital authentication of patients and healthcare professionals, enable informed consent, provide access to personal health information, and integrate with healthcare digital systems. The development of telemedicine functionality is divided into three stages: consultation services, diagnostic services with digital data transmission, and laboratory services with digital data transmission.

 

Changes to Employment Legislation

The list of documents required for concluding an employment contract has been updated. When hiring an employee for a position requiring specific knowledge and skills, the employee must provide a document confirming education or special knowledge, professional training, or retraining. In certain cases, a document confirming recognition of professional qualifications may also be required. In addition, the concept of professional training has been introduced into the Labour Code. It covers the acquisition, updating, and development of professional knowledge and skills, as well as professional training, retraining, and advanced training.

 

Mentorship When Employing Foreign Workers

A new requirement for employers engaging foreign workers in Kazakhstan has been introduced into the Law on Migration of the Population. Such employers must arrange mentorship for Kazakhstan employees. A foreign specialist is assigned as a mentor to a Kazakhstan employee to transfer the professional knowledge, skills, and experience that formed the basis for engaging the highly qualified foreign worker. The procedure for organizing mentorship will be determined by the relevant rules and requirements of the authorized body.

 

Recognition of Professional Qualifications

The powers of local executive bodies in the area of professional qualification recognition have been expanded. In particular, they will be able to provide registered unemployed individuals with a one-time voucher to reimburse the costs of undergoing the professional qualification recognition procedure and participate in updating the register of professions and professional standards. The functions of the National Body for Professional Qualifications have also been defined. These include developing the methodology of the National Qualifications System, reviewing professional standards, providing digital support for the system, maintaining the register of accredited recognition centers, and engaging in international cooperation. The new provisions also cover the comparability of professional qualifications and the recognition of international certificates confirming professional qualifications and skills.

 

State Control in the Area of Migration

A procedure is being introduced for state control over compliance with migration legislation by organizations and individuals providing employment intermediary services for Kazakhstan citizens seeking employment abroad. Control may be carried out both with and without an on-site visit. During preventive control without an on-site visit, the authorized body analyzes reports and digital data. If violations are identified, the entity receives a recommendation to remedy them no later than ten business days from the date of detection. Such preventive control without an on-site visit may be conducted no more than once per quarter.

 

Notarial Activities: New Grounds for Suspension and Revocation of Licenses

Starting September 8, amendments concerning notarial activities and legal assistance come into effect. The grounds for suspending a notary’s license have been expanded. They include repeated disciplinary liability, violations of personal data protection legislation, and repeated failure to comply with deadlines for entering information on notarial acts into the Unified Notarial Digital System. Additional circumstances have been established in which a license is suspended for a specific period, including when a notary enters public service, performs compulsory military service, or submits an application to temporarily cease exercising their powers. The grounds for revoking a license have also been expanded. They include violations that cause damage to the interests of the state, individuals, or legal entities; the unlawful transfer of a private electronic digital signature key to another person; and repeated violations of personal data protection legislation. Electronic notarial documents must be created and maintained in the Notarial Digital Archive.

 

Changes to Enforcement Proceedings and the Activities of Private Bailiffs

Starting September 1, a standard professional liability insurance contract for private bailiffs is introduced. An insured event is the occurrence of civil liability of a private bailiff for damage caused to the property interests of third parties as a result of professional errors committed during the enforcement of enforcement documents. Standard forms of private bailiff resolutions have also been updated. In particular, new forms have been introduced for requesting information on the income and accounts receivable of debtors, as well as information on income received through online platforms and mobile applications used for platform-based employment.

 

Updates for Entrepreneurs

Starting September 23, a new notification form for commencing activities as an individual entrepreneur applies. The notification on the commencement or termination of activities by a taxpayer engaged in the production, assembly, or completion of excisable goods has also been updated. A separate notification form is also introduced for the commencement and termination of activities involving facilities of minor epidemiological significance. The procedure for obtaining a permit for scrap metal collection has also been updated. Documents are submitted through the digital government web portal. Their completeness and validity are checked first, followed by verification of compliance with the applicable permit requirements.

 

Changes in Industry and Imports

The rules governing the planning and conclusion of agreements aimed at industrial development have been updated. Major customers submit their procurement plans to the authorized body annually, after which the agreed list of goods is published in the register. Manufacturing enterprises may then submit applications to conclude the relevant agreements. Starting September 1, rules for allocating quotas for the import of spark plugs from China also apply. The annual quota is 6 million units, of which 80% is allocated to foreign trade participants and 20% to distributors. A license is required to import goods within the quota without paying anti-dumping duties. Goods imported under the quota may not be exported to the territory of other member states of the Eurasian Economic Union (EAEU).

 

Digitalization of HR Processes

Uniform rules for managing HR processes through a digital HR system have been approved for public institutions and quasi-public sector organizations. The system is intended to ensure the automation and transparency of HR procedures, while organizations are required to maintain accurate, complete, and up-to-date employee information. Starting January 1, 2027, where certain information is unavailable, employers will be able to obtain it from digital systems to identify conflicts of interest. Electronic HR documents must be stored and archived in a manner that ensures their legal validity and enables subsequent verification of their authenticity.

 

New Rules for Verifying Electronic Digital Signatures

Rules for creating and verifying the authenticity of electronic digital signatures have been adopted. Verification includes cryptographic verification of the electronic digital signature, verification of the signatory’s certificate and, where applicable, verification of the timestamp receipt. If the verification is successful, the electronic document is recognized as equivalent to a document bearing a handwritten signature and has the same legal effect. An electronic document may also contain multiple electronic digital signatures, provided that previously created signatures remain verifiable.

 

Financial Reporting by Public Interest Entities

The rules for submitting financial statements by public interest entities to the depository are being amended. However, the general procedure and deadlines for submitting financial statements remain unchanged. The amendments concern the legal basis of the rules, terminology, interaction with the tax authorities’ digital systems, and mandatory audit requirements. In addition, audit reports will be submitted in digital PDF format.

 

Public Procurement

Starting September 8, a new exemption from the national treatment regime in public procurement is introduced. It applies to goods and services included in the Register of Trusted Digital Objects and originating from foreign countries, except for certain categories of goods and cases provided for by legislation. Individuals and legal entities included in the Register of Kazakhstan Manufacturers are eligible to participate in the relevant public procurement procedures.

 

Key Considerations for Businesses

The September legislative changes affect multiple areas of business operations, including contractual matters, construction, HR processes, employment relations, migration, licensing, financial reporting, digital documents, and participation in public procurement. Businesses should therefore review their internal procedures and documentation in a timely manner to ensure compliance with the new requirements, particularly where their activities involve foreign employees, construction, regulated activities, public procurement, or mandatory reporting.

 

Professional Services from FChain

Legislative changes affect multiple areas of business operations, from HR and migration processes to construction, reporting, and industry-specific regulation. FChain provides comprehensive professional support to companies in Kazakhstan, taking into account current legislative requirements.

• Legal support for business— legal advice on Kazakhstan legislation and ongoing support with business operations, documentation, and interaction with government authorities.
• Legal Support for Construction Companies in Kazakhstan — legal support for construction businesses in relation to contractual matters, permitting documentation, and compliance with industry-specific requirements.
• Legal Support for Pharmaceutical Companies in Kazakhstan — legal support for pharmaceutical businesses, taking into account the specific regulatory requirements applicable to their activities in Kazakhstan.
• Legal audit — a comprehensive review of a company’s activities, contracts, and internal documents to identify potential legal risks and non-compliance with applicable legislation.
• Accounting and tax services — accounting and tax record keeping, preparation of reports, and support for the company’s ongoing financial processes.
• HR Services — employment documentation, preparation of HR records, and support for HR procedures in accordance with employment legislation.
• Migration Services— support for companies and foreign specialists with employment-related migration matters and the preparation of required permits and documents in Kazakhstan.

Comprehensive professional support enables companies to respond to legislative changes in a timely manner and reduce legal, HR, and financial risks. FChain specialists are ready to provide professional advice and determine an appropriate support model based on the specific needs and activities of each company.

 

Tourism Regulations Updated

Prepared by: Anel Kosmaganbetova

Assistant to the Director

FChain Kazakhstan

  📩almaty@f-chain.com
WhatsApp: +7 771 214 1820