Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the NBK or AFSA decision, including banking and payment rails.
Get a payment license in Kazakhstan.
Two doors into Central Asia's largest economy: registration with the National Bank as a payment organisation for the domestic tenge market - or an AFSA money-services licence inside the AIFC, on English-law rules, from USD 50,000 base capital and 0% corporate tax on financial services. We fix the door before the file.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Kazakhstan in brief
One country, two regulators - and they do different jobs.
Kazakhstan runs payments on two legal systems at once. The domestic one is the Law on Payments and Payment Systems: a payment organisation registers with the National Bank rather than applying for a licence, and may then provide four things - accepting cash for payments without opening a bank account, distributing e-money and payment cards, accepting and processing e-money payments, and processing electronically initiated payments. The registration file is filed through the e-government portal: charter-capital evidence at the minimum the NBK Board set in its Resolution No. 129 of October 2020, the charter, a partner-bank agreement, the IT and compliance officers named, AML rules and the operating rules approved by the board. Significant payment organisations carry heavier obligations. It is a real supervisory regime priced for the tenge market - and it does not issue e-money itself; banks do.
The second system sits inside the Astana International Financial Centre, where the AFSA licenses Providing Money Services under its own PMS Rules, reissued in 2025: payment services, e-money issuance and - unusually - money services in approved digital assets and fiat stablecoins. Capital is the highest of USD 50,000, 10% of annual audited expenditure, or 1.5% of average outstanding e-money once it passes USD 3 million; client money is safeguarded in client-money accounts, secure liquid assets or by insurance or guarantee. AIFC participants pay no corporate tax on financial-services income until 2066, against 20% onshore and a VAT that rises to 16% in 2026. The honest split: NBK for tenge cash-in and processing at national scale, AIFC for cross-border, digital-asset and English-law structures. Many groups end up holding both - we sequence them.
Two regimes: National Bank registration as a payment organisation (four permitted services, capital per Board Resolution No. 129) for the tenge market - or an AFSA money-services licence in the AIFC: USD 50,000 base capital, 10%-expenditure and 1.5%-e-money tests, PMS 9 safeguarding, digital assets inside.
0% corporate tax in the AIFC to 2066 against 20% onshore; VAT 16% from 2026. We sequence both from our CIS desk.
The two routes
NBK payment organisation - or AFSA money services.
Different laws, different products: the National Bank track for the domestic tenge market, the AIFC track for cross-border and digital-asset money services under English-law rules. We fix the route first, then build once.
NBK registration for the domestic market - AFSA licence for cross-border and digital assets.
01 - NATIONAL BANK TRACK
Payment organisation · registration
Registration with the National Bank under the Law on Payments and Payment Systems: four permitted services around cash acceptance, e-money and card distribution, and processing - with charter capital at the NBK Board minimum and a partner bank behind the model.
Registration with the National Bank under the Law on Payments and Payment Systems: four permitted services around cash acceptance, e-money and card distribution, and processing - with charter capital at the NBK Board minimum and a partner bank behind the model.
- ✓Cash acceptance for payments - no account
- ✓Distribution of e-money and payment cards
- ✓Acceptance and processing of e-money payments
- ✓Processing of electronically initiated payments
- ✓Capital per NBK Board Resolution No. 129
- ✓Registration via the e-government portal
02 - AIFC TRACK
AFSA · PMS Rules 2025Providing Money Services
The AFSA licence in the Astana International Financial Centre: payment services, e-money issuance and money services in approved digital assets - USD 50,000 base capital, expenditure- and float-based tests above it, and a 0% corporate-tax regime to 2066.
AFSA PMS: payments, e-money, digital-asset money services; USD 50k base; safeguarded client money.
- ✓Payment, initiation and account-information services
- ✓E-money issuance and redemption
- ✓Digital-asset and fiat-stablecoin money services
- ✓Base capital USD 50,000 · PMS 10.1
- ✓Higher of 10% expenditure · 1.5% e-money
- ✓Client money safeguarded - PMS 9
Costs and timelines are confirmed for your case before any work begins. The NBK charter-capital minimum is set by Board resolution and confirmed for your service mix; AIFC capital is computed under PMS 10.1 against your projections.
Why Kazakhstan
Central Asia's biggest market - with an English-law door.
The region's deepest consumer economy and its only common-law financial centre sit in the same country. That combination exists nowhere else between Istanbul and Singapore.
✓
The regional hub
Kazakhstan's economy anchors Central Asia - corridors to Uzbekistan, Kyrgyzstan, the Caucasus and Russia's periphery run through Almaty and Astana naturally.Central Asia's largest economy.
✓
USD 50,000 base capital in the AIFC
The PMS Rules price entry for real money-services startups - the base is fifty thousand dollars, with the expenditure and float tests scaling only as you grow.Startup-priced AIFC entry.
✓
0% corporate tax to 2066
AIFC participants pay no corporate income tax on qualifying financial-services income until 1 January 2066 - a constitutional-statute guarantee, not a budget-cycle incentive.Constitutional, not budgetary.
✓
Digital assets inside the perimeter
The 2025 PMS Rules bring money services in approved digital assets and fiat stablecoins into the same licence family - a rulebook most regulators have not written yet.PMS Rules 2025 cover them.
✓
A registration, not a licence, onshore
The National Bank track is a registration with published document lists - for tenge cash-in and processing models it is the faster, cheaper entry.Faster, cheaper tenge entry.
✓
English law, local market
AIFC contracts, disputes and corporate law run on English-law principles with an AIFC Court - the legal comfort of a hub, next to a 20-million domestic market.AIFC Court next to the market.
How it compares
How Kazakhstan differs from other routes.
Kazakhstan is the only jurisdiction in the region offering a domestic regime and a common-law financial-centre regime side by side. The honest comparison is below.
Kazakhstan vs other jurisdictions
| Feature |  Kazakhstan | Other jurisdictions |
|---|---|---|
| Regimes | NBK domestic + AIFC common law | One regime per country |
| AIFC capital | USD 50,000 base | Higher flat minimums |
| Tax | 0% AIFC to 2066 · 20% onshore | Standard rates only |
| Digital assets | Inside the PMS perimeter | Separate or absent |
Regimes
KazakhstanNBK domestic + AIFC common law
Other jurisdictionsOne regime per country
AIFC capital
KazakhstanUSD 50,000 base
Other jurisdictionsHigher flat minimums
Tax
Kazakhstan0% AIFC to 2066 · 20% onshore
Other jurisdictionsStandard rates only
Digital assets
KazakhstanInside the PMS perimeter
Other jurisdictionsSeparate or absent
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Kazakhstan | NBK registration · AFSA PMS | 20% · AIFC 0% | USD 50k base in AIFC |
 Uzbekistan | Payment organisation (CBU) | 15% CIT | CBU licence · 30-day review |
 Armenia | Payment organisation (CBA) | 18% CIT | AMD 100M total capital |
 Azerbaijan | PI / EMI (CBA) | 20% CIT | 2023 law · CBA capital rules |
KazakhstanLicense typeNBK registration · AFSA PMS
Taxation20% · AIFC 0%
RequirementsUSD 50k base in AIFC
UzbekistanLicense typePayment organisation (CBU)
Taxation15% CIT
RequirementsCBU licence · 30-day review
ArmeniaLicense typePayment organisation (CBA)
Taxation18% CIT
RequirementsAMD 100M total capital
AzerbaijanLicense typePI / EMI (CBA)
Taxation20% CIT
Requirements2023 law · CBA capital rules
Before you apply
Requirements for the Kazakh routes.Requirements for the routes.
Two files, two checklists - the National Bank's is published as a document list, the AFSA's as rules. Below is what a passing application contains on each track.
01
NBK track - a Kazakh legal entity with charter capital at the minimum set by NBK Board Resolution No. 129 (2020), evidenced.
02
NBK track - the registration file via the e-government portal: charter, partner-bank agreement, named IT and compliance officers, AML rules and board-approved operating rules.
03
NBK track - a service mix within the four permitted services; e-money itself is issued by banks, distributed by the payment organisation.
04
AIFC track - an AIFC-registered entity applying to the AFSA for Providing Money Services under the PMS Rules.
05
AIFC track - capital at the highest of USD 50,000, 10% of annual audited expenditure, or 1.5% of average outstanding e-money above USD 3 million (PMS 10.1).
06
AIFC track - client-money safeguarding per PMS 9: client-money accounts, secure liquid assets, or insurance and guarantees meeting the rules.
07
Both tracks - fit and proper management and holders, ownership transparent to UBOs.
08
Both tracks - a programme of operations with volumes and three-year financials the regulator can interrogate.
09
Both tracks - AML/CFT framework with a resident compliance officer and reporting to the financial-monitoring authority.
10
Both tracks - technology, information-security and outsourcing documentation to supervisory standard.
01
NBK: Kazakh entity, Resolution 129 capital.
02
NBK: portal file - charter, bank, officers, AML.
03
NBK: four permitted services only.
04
AIFC: participant entity, AFSA application.
05
AIFC: PMS 10.1 capital - USD 50k+ tests.
06
AIFC: PMS 9 safeguarding.
07
Fit & proper to UBOs.
08
Interrogable programme of operations.
09
AML with resident officer.
10
IT, security and outsourcing files.
Reflects the Law on Payments and Payment Systems, NBK Board Resolution No. 129 (2020) and the AIFC Rules on Providing Money Services (2025 edition), as of 2026.Payments Law + NBK Res. 129 + AIFC PMS Rules 2025, as of 2026.
How it works
From first call to the register - NBK or AFSA.
01
Route and strategy
NBK registration, AIFC licence or both in sequence - fixed in writing against your product and corridors.NBK, AIFC or both - in writing.
02
Company and people
Onshore or AIFC entity, capital evidence and the resident officers each regulator vets.Entity, capital, resident officers.
03
The file
NBK document list or AFSA application per the PMS Rules - complete before filing, because completeness is the timeline.Complete before filing.
04
Regulator review
NBK registration typically inside a quarter; AFSA question rounds answered - plan on four to nine months for the AIFC licence.3-9 months by track.
05
Register entry and launch
Registration or licence issued, safeguarding live, partner bank connected - and the reporting calendar running.Issued, safeguarded, connected.
Quick facts
RegulatorsNBK · AFSA
NBK trackRegistration · 4 services
NBK capitalBoard Resolution No. 129
AIFC base capitalUSD 50,000
AIFC tests10% expenditure · 1.5% e-money
AIFC tax0% to 2066
Onshore tax20% · VAT 16%
Realistic timeline3-9 months by track
Deciding the track is the whole strategy: a tenge cash-in model belongs onshore, a cross-border or digital-asset model in the AIFC. We decide it on the first call.
Your Kazakhstan desk
Run from our CIS & Central Asia desk.
Prifinance - CIS & Central Asia desk
Tallinn · coordinating Kazakh mandates
Roseni 13, Tallinn
01
Kazakh or AIFC company formation
Onshore entity for the NBK track or AIFC participant for the AFSA track - the corporate layer chosen by the route, built for the file from day one.Onshore or AIFC - by route.
02
The NBK registration file
Charter capital, partner-bank agreement, officers, AML and operating rules per the published list - filed through the portal and defended through questions.Published list, filed via portal.
03
The AFSA application
PMS 10.1 capital computation, PMS 9 safeguarding design, programme of operations and digital-asset scoping where relevant - drafted by us and defended through the rounds.PMS 10.1 and 9, defended.
04
Substance and staffing
Resident officers in Almaty or Astana, compliance reporting and operations hires from a deep Russian- and English-speaking talent pool.Almaty/Astana officers, real premises.
We also have offices in
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Kazakhstan.
Two tax worlds to match the two regulators: 20% corporate tax onshore with VAT at 16% from 2026, and a constitutional 0% on financial-services income inside the AIFC until 2066.
Onshore corporate tax 20%
The standard rate on a payment organisation's fee income under the Tax Code - with the 2026 code keeping it at 20% for ordinary companies.Standard Tax Code rate.
AIFC 0% to 2066
AIFC participants providing qualifying financial services pay no corporate income tax until 1 January 2066 - guaranteed by the AIFC Constitutional Statute.To 2066 by statute.
VAT 16% from 2026
The new Tax Code lifts VAT from 12% to 16% in 2026; financial-service exemptions apply by product and are mapped before launch.From 2026; exemptions mapped.
AIFC personal tax relief
Foreign staff of AIFC participants are exempt from individual income tax on their AIFC employment to 2066 - the hiring argument for the Astana desk.Foreign employees exempt.
Withholding and treaties
Dividends leave with withholding relieved under 50+ treaties; AIFC dividend and capital-gain exemptions add a second layer for hub structures.Relieved withholding.
Regional cost base
Almaty engineering and compliance salaries price far below European hubs - the operating base of a licensed model stays lean.Almaty salaries.
Tax summary
Corporate tax - onshore20%
Corporate tax - AIFC0% to 2066
VAT16% from 2026
AIFC staff income tax0% foreign staff
Dividend withholdingTreaty-relieved
Tax treaties50+
*Figures as of 2026 per the State Revenue Committee and the AIFC Constitutional Statute. Qualifying-activity scoping for AIFC relief is confirmed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Kazakh or AIFC company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, registered or licensed institution.
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Kazakhstan · NBK · AFSA
Launch your payment project in Kazakhstan with expert support.
Full-service assistance - from incorporation to the NBK registration or AFSA licence, safeguarding and ongoing compliance.
Get a consultation →Free legal opinion
Is Kazakhstan the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The Kazakh payment licence, answered.
What does a payment business need in Kazakhstan?+
One of two things: registration with the National Bank as a payment organisation under the Law on Payments and Payment Systems for the domestic market, or an AFSA licence for Providing Money Services inside the AIFC. They are different laws with different products - we fix which on the first call.
What can an NBK-registered payment organisation do?+
Four services: accept cash for payments without opening a bank account, distribute e-money and payment cards, accept and process e-money payments, and process electronically initiated payments. E-money itself is issued by banks.
How much capital does the NBK track need?+
Charter capital at the minimum set by NBK Board Resolution No. 129 of October 2020, evidenced in the registration file - we confirm the figure for your service mix before anything is drafted.
How much capital does the AIFC licence need?+
The highest of USD 50,000 base capital, 10% of annual audited expenditure, or 1.5% of average outstanding e-money once it exceeds USD 3 million - PMS Rule 10.1. Multiple activities trigger the highest applicable test.
How is client money safeguarded in the AIFC?+
Per PMS 9: placed in client-money accounts, invested in secure liquid assets meeting the rules' criteria, covered by qualifying insurance or bank guarantees, or held under an AFSA-approved alternative arrangement.
Can the AIFC licence cover digital assets?+
Yes - the 2025 PMS Rules include money services in approved digital assets and fiat stablecoins within the same licence family, which is rare. Scoping it in from the start is cheaper than adding it later.
How long does it take?+
NBK registration typically completes inside a quarter from a complete file; the AFSA licence runs four to nine months with question rounds. Completeness is the lever on both - and our job.
How are payment companies taxed?+
20% corporate tax onshore with VAT at 16% from 2026; inside the AIFC, 0% corporate tax on qualifying financial-services income until 2066 and no personal income tax for foreign staff. Two different tax worlds, deliberately.
What substance is expected?+
Resident management and a compliance officer, real premises in Almaty or Astana, partner-bank arrangements on the NBK track, and safeguarding and systems documentation to supervisory standard on both.
Why Kazakhstan rather than a Gulf or EU hub?+
Because the market is here - Central Asia's largest economy and its corridors - and because the AIFC gives that market an English-law, zero-tax door no neighbour has. For Central Asian models it is the natural anchor; hubs come second.
Which route?+
NBK registration domestic; AFSA licence in the AIFC.
NBK services?+
Cash-in, e-money/card distribution, processing.
NBK capital?+
Per Board Resolution No. 129 - confirmed for your mix.
AIFC capital?+
Highest of USD 50k, 10% expenditure, 1.5% e-money.
Safeguarding?+
PMS 9: client accounts, liquid assets, insurance.
Digital assets?+
Inside the 2025 PMS Rules.
How long?+
3-9 months by track.
Taxes?+
20% onshore; 0% AIFC to 2066; VAT 16%.
Substance?+
Resident officers, premises, partner bank.
Why Kazakhstan?+
The market plus an English-law, zero-tax door.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
Google4.7★★★★★
“As a software development crew at FewMoreTaps OÜ, we've had the pleasure of working with Prifinance on some key financial moves.First of all, navigating the world of corporate banking and finance can be a maze, but Prifinance made it feel like a walk in the park. They helped us set up a corporate bank account without the hassle of jumping on a plane or drowning in paperwork. Everything was done remotely, smoothly…”
Google
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Google
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Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.Free legal opinion: which Kazakh route fits your project and what it will cost.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the National Bank of Kazakhstan or the Astana Financial Services Authority or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.