Kazakhstan is considering introducing a new obligation for employers to submit information on their staffing schedules to the Unified Employment Contract Accounting System. The proposed amendments are included in a draft law prepared by the Ministry of Labor and Social Protection of the Population. The draft also proposes introducing the concept of a \u201cstaffing schedule\u201d directly into the Labor Code for the first time. The regulatory impact analysis for the draft was published on the Open Legal Acts portal on September 28, 2026, and its public discussion concluded on October 1. At this stage, the proposed amendments remain in draft form. The new requirements will apply only after the relevant law enters into force.<\/p>\n
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It is proposed to supplement Article 1 of the Labor Code with a new subparagraph 81-1). Under the draft, a staffing schedule will be defined as an employer\u2019s act containing information on the organizational structure, the number of staff positions, and the list of positions or professions. The current version of the Labor Code does not contain a separate definition of a staffing schedule. According to the developers of the draft, the absence of a unified definition results in different approaches among employers to preparing and maintaining this document.<\/p>\n
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Currently, employers submit information on the conclusion, amendment, and termination of employment contracts, as well as employee leave, to the Unified Employment Contract Accounting System. Information on staffing schedules is not currently recorded in the system.<\/p>\n
The draft proposes expanding this obligation. Employers would be required to submit information on:<\/p>\n
The procedure for submitting this information will be determined by the authorized labor authority. The requirement is expected to apply to all employers regardless of their organizational and legal form, form of ownership, or business category. The draft does not provide exemptions for specific categories of employers.<\/p>\n
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Employers will be able to submit the information through the employer\u2019s electronic account or by integrating their own HR systems with the Unified Employment Contract Accounting System. For large companies using their own HR management systems, the developers envisage the use of existing application programming interfaces and a transition period. At the same time, employers will retain the option of entering information manually through their electronic accounts. No separate information system is planned for implementing the new requirement. The format for submitting the information will be determined by the authorized labor authority. After the initial submission of the staffing schedule, employers will be required to update the information in a timely manner whenever the organizational structure or staffing levels change. According to the estimates of the draft developers, the initial submission may take up to 30 minutes, while each subsequent update may take up to 10 minutes.<\/p>\n
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The Unified Employment Contract Accounting System currently contains information on employment contracts but does not include information on employers\u2019 staffing structures. Including staffing schedule information is expected to enable government authorities to compare the number of employees with employment contracts against the approved number of staff positions and identify vacant positions. The developers of the draft also expect this information to be used to identify indications of fictitious employment and concealed employment relationships. For state supervision purposes, the data is also expected to be used as part of a risk-based approach.<\/p>\n
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The proposed requirements have not yet entered into force. According to the draft, the obligation to submit staffing schedule information to the Unified Employment Contract Accounting System will take effect simultaneously with the entry into force of the law on improving labor legislation. A transition period of at least 60 calendar days following the first official publication of the law is also envisaged. According to the estimates of the Ministry of Labor and Social Protection of the Population, 50% of employers are expected to submit staffing schedule information in 2027, 60% in 2028, and 70% in 2029.<\/p>\n
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If the proposed amendments are adopted, maintaining staffing schedule information will become part of employers\u2019 interaction with the Unified Employment Contract Accounting System. Companies will need not only to make the initial submission of information on their organizational structure, staffing levels, and positions but also to keep this information up to date when subsequent changes occur. This increases the importance of maintaining accurate HR documentation and ensuring consistency between information on the company\u2019s staffing structure and the data recorded in the Unified Employment Contract Accounting System. At the same time, the specific format for submitting the information is yet to be determined by the authorized authority, and the requirement itself remains at the draft legislative stage.<\/p>\n
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As employment processes continue to become increasingly digitalized, systematic HR record-keeping and the timely recording of changes are becoming increasingly important. FChain provides comprehensive HR and legal services to employers, including HR administration, documentation reviews, and support with labor law compliance matters.<\/p>\n
As the proposed amendments are still at the draft stage, employers should monitor the further progress of the draft law and the final requirements governing the submission of staffing schedule information to the Unified Employment Contract Accounting System. FChain provides HR and legal support to businesses and assists companies in organizing their HR processes in accordance with the requirements of the legislation of the Republic of Kazakhstan.<\/p>\n
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