Crypto Licence Kazakhstan Afsa National Bank

Crypto Licence in Kazakhstan 2026: AFSA and National Bank Regimes Compared

Key Takeaways

• Kazakhstan has rebuilt its crypto market as a state-managed system that is restrictive for retail and deliberately open to regulated foreign institutions.
• It runs two parallel regimes: the AFSA/AIFC offshore track and the national onshore track.
• The Astana International Financial Centre (AIFC) offers qualifying participants tax exemptions, including exemption from corporate income tax on specified financial-services income until 1 January 2066, subject to applicable conditions. 
• From 1 May 2026, Kazakhstan’s national framework introduced specific licensing and registration routes for digital-asset service providers outside the AIFC.
• Onshore, authorities have shut down 130 illegal exchanges and capped retail crypto purchases on AIFC-licensed platforms at $1,000 per month.The onshore regime (Law on Digital Assets, 2023) spans several bodies, including the National Bank, ARDFM, Financial Monitoring Agency, and the Ministry of Artificial Intelligence and Digital Development. The National Bank separately oversees the digital tenge (CBDC).Unsecured assets such as Bitcoin are largely routed into the AIFC.

For companies looking to expand into Central Asia and the CIS corridor, Kazakhstan has established one of the region’s most clearly defined regulatory frameworks for digital-asset businesses. But entering the market is not simply a matter of registering a company and applying for a crypto licence.

Kazakhstan offers two regulatory pathways for digital-asset businesses, and the right one depends on how and where the business plans to operate.

The Astana Financial Services Authority (AFSA) regulates companies based in the Astana International Financial Centre (AIFC). Businesses operating outside the AIFC fall under Kazakhstan’s national digital asset framework, where the National Bank oversees key licensing and registration requirements.

This distinction matters for exchanges, custodians, brokers, fintech companies and other digital-asset businesses because the applicable regulator, capital requirements, entity structure and compliance obligations can differ depending on the activity.

This guide explains the main regulatory routes for crypto businesses in Kazakhstan, the licences and registrations available, the capital and compliance requirements involved, and how businesses can determine which framework applies.

Why do many companies choose Kazakhstan?

Kazakhstan’s appeal to digital-asset businesses comes partly from the development of the AIFC as a dedicated financial-services centre. The AIFC operates under its own legal and regulatory framework, and AFSA supervises authorised firms. Its rules specifically cover activities involving digital assets, including dealing, custody, advising, arranging and operating a Digital Asset Trading Facility.

For businesses considering the AIFC route, the zone provides a well-established framework for international financial institutions. It has its own legal system and financial services regulator, giving digital asset businesses clear rules to follow and a defined process for meeting regulatory requirements.

The tax position can also be an important consideration for qualifying AIFC participants. However, businesses should not treat the AIFC as an automatic tax-free zone. Any available tax treatment depends on the entity, income, applicable rules and substance requirements. Companies considering the AIFC should therefore assess the tax position separately rather than assuming that incorporation alone creates a blanket exemption.

Kazakhstan has also been building the infrastructure needed to connect digital assets with the broader financial system. The National Bank has introduced a regulatory sandbox for fintech and digital-asset projects, and the 2026 framework provides regulated channels for digital-asset platforms to work with the banking sector.

For regulated institutions, the 2026 framework represents a maturing market with defined rules, published requirements, and a clear supervisory structure.

Advantages of a Cryptocurrency License in Kazakhstan

A regulated digital-asset licence gives businesses the legal basis to provide digital-asset services in Kazakhstan within a defined supervisory framework. Depending on the business model and operating structure, the relevant route may be the AFSA framework within the AIFC or the national framework, where the National Bank and other authorities oversee different digital asset activities. This gives businesses a defined regulatory route and greater certainty around how their activities are supervised.

The AIFC also offers a significant tax advantage. Qualifying AIFC participants can receive a 0% corporate income tax rate on income from specific financial services until 2066, subject to the applicable conditions. The benefit is not automatic for every AIFC company. Businesses must meet substance requirements, including carrying out core income-generating activities in the AIFC and maintaining an appropriate level of operations and employees.

Banking access is another important consideration for licensed businesses. Kazakhstan has been developing a regulated framework for digital asset service providers to work with commercial banks. This can give licensed operators a clearer path for setting up banking relationships and fiat on- and off-ramp services, depending on the requirements of the banks and regulators involved.

A regulated structure can also help businesses build trust with clients and counterparties. This credibility is reinforced by international recognition: in October 2025, IOSCO identified the AIFC as one of only four jurisdictions globally to have fully implemented all ten of its priority recommendations for crypto and digital-asset markets. Businesses also operate under published regulatory rules and supervisory requirements, including applicable AFSA fees. 

Licensing also gives businesses a clearer set of compliance requirements to work with. Depending on the activity, these may include AML/CFT controls, regulatory reporting, governance, cybersecurity, technology risk management, client protection, and ongoing regulatory obligations. Having these requirements clearly defined helps businesses build the right processes and systems from the start rather than retrofitting them later.

Requirements for Acquiring a License in Kazakhstan

The exact requirements depend on whether the business applies through the AIFC or the national framework and on the activity it intends to conduct.

Fit-and-proper requirements

Regulators expect information about the people behind a digital-asset business. This can include founders, shareholders, beneficial owners, directors, senior executives and compliance personnel.

The business should be prepared to demonstrate that relevant individuals have appropriate experience, integrity and suitability for their roles.

Capital requirements

Capital requirements vary significantly by activity. Under the AIFC framework, the capital requirements include:

• A Digital Asset Trading Facility must maintain the higher of USD 200,000 or 12 months’ operational expenses, subject to the applicable rules.
• A digital-asset custody business requires USD 2500,000.
• Dealing as principal requires USD 250,000 full dealing book; USD 50,000 for order matching only or depends on AFSA’s determination, while dealing as agent requires USD 50,000.
• Certain advising or arranging activities have lower capital requirements depending on the applicable category.

The AIFC rules also contain liquidity requirements, including requirements linked to annual operating expenditure.

Under the national framework, the requirements are activity-specific. For example, the National Bank requires an unsecured digital-asset exchange operator to maintain minimum charter capital of KZT 50 million. The operator must also meet requirements relating to its organisational structure, risk management, compliance and operations.

AML and CFT

AML/CFT controls are another central requirement. Depending on the activity, the business should have procedures covering customer identification, customer due diligence, sanctions screening, transaction monitoring, suspicious-activity reporting and record-keeping.

These controls should be designed before the business begins operating rather than added after the licence is obtained.

Local presence and substance

Businesses using the AIFC route should also consider local substance requirements, including the appropriate registered office, management presence and relevant personnel.

National operators must satisfy the corporate and registered-address requirements applicable to their category. For example, the National Bank requires digital financial-asset platform operators to be established as a joint-stock company or limited liability partnership.

Custody and security

Businesses handling customer assets need additional safeguards around custody and technology. These can include key-management procedures, transaction-signing controls, access management, segregation of duties, incident response and business continuity.

Types of Cryptocurrency License in Kazakhstan

Kazakhstan does not have one universal crypto licence. The authorisation depends on the activity and the regulatory framework under which the business operates.

Within the AIFC, AFSA regulates several digital asset activities. The AIFC Rules on Digital Asset Activities specifically include Dealing in Investments as Principal, Dealing in Investments as Agent, Providing Custody, Arranging Custody, Advising on Investments, Arranging Deals in Investments, Providing Money Services and Operating a Digital Asset Trading Facility.

The national framework introduced additional categories from 1 May 2026. The National Bank identifies three principal digital-asset service-provider categories:

• Unsecured digital-asset exchange operator, which carries out exchange, purchase and sale operations involving unsecured digital assets for clients.
• Digital-asset trading platform operator, which provides the infrastructure for organised trading in digital assets.
• Digital financial-asset platform operator, which operates a platform for the issuance and circulation of DFAs and related accounting and custody functions.

Main Digital Asset License Categories

Digital mining is licensed through the Ministry of Artificial Intelligence and Digital Development. ARDFM separately regulates the circulation of digital financial assets other than stablecoins

AFSA and National Bank Regimes Compared

Kazakhstan’s digital asset market is divided between the AIFC framework and the national regulatory framework. The AIFC operates under its own legal regime, with AFSA acting as the independent financial regulator. Its framework covers activities such as operating a Digital Asset Trading Facility, providing custody, dealing in investments, and advising on investments. The AIFC also operates within a legal environment based on English common law principles.

Outside the AIFC, Kazakhstan’s national framework covers digital asset activities. The National Bank licenses unsecured digital asset exchange operators and registers digital asset trading platform and digital financial asset platform operators. ARDFM regulates digital financial assets other than stablecoins, while the Ministry of Artificial Intelligence and Digital Development licenses digital mining. The Financial Monitoring Agency handles financial monitoring and AML/CFT enforcement.

This makes the National Bank shorthand for a broader national regulatory structure, not a single regulator covering every digital asset activity. The National Bank also plays a broader role in Kazakhstan’s monetary and digital financial infrastructure, including developing the digital tenge.

State oversight is also visible in enforcement. According to Kazakhstan’s Financial Monitoring Agency (AFM), authorities shut down 130 unlicensed cryptocurrency exchanges in 2025 that were allegedly involved in laundering criminal proceeds, and seized virtual assets valued at USD 16.7 million.This illustrates the importance the authorities place on keeping digital asset activity within regulated channels.

One important correction: it is no longer accurate to say that unsecured digital assets can only legally circulate through the AIFC. Kazakhstan’s national framework now provides regulated channels for specified unsecured digital-asset activities outside the AIFC. The 2026 framework separately recognises digital financial assets (DFAs), including money-backed stablecoins, tokenised real assets, and digital forms of traditional financial instruments, each with its own regulatory treatment.

Which regime applies?

The answer depends on the activity. AFSA regulates exchange and custody activities conducted within the AIFC. Unsecured digital-asset exchanges outside the AIFC require National Bank licensing. Digital-asset trading platforms require National Bank registration under the applicable framework.

How can Liminal help?

Obtaining a licence is only one part of launching a digital-asset business. Exchanges, custodians and other regulated operators also need infrastructure that can securely manage wallets, private keys and transactions.

Liminal provides institutional custody and wallet infrastructure designed for digital-asset businesses. Its MPC-based wallet architecture supports secure key management and transaction signing across multiple digital assets and networks.

Transaction governance adds an additional layer of operational control through approval workflows, access permissions, transaction policies and audit trails.

For compliance operations, Liminal integrates with third-party solutions for KYT, AML screening and Travel Rule workflows, including a direct integration with Notabene.

Multi-chain wallet infrastructure and APIs can also connect custody and transaction capabilities with exchanges, treasury systems, payment infrastructure and other enterprise systems.

Liminal supports the technology and operational infrastructure of a regulated digital-asset business. It does not replace the licensing, capital, governance or compliance requirements imposed by Kazakhstan’s regulators.

Final Thoughts

Kazakhstan’s digital asset market has moved toward a more structured and closely supervised model. For businesses looking to enter the market, the key consideration is not simply whether crypto activity is permitted, but which regulatory framework applies to the services they plan to provide. Since May 2026, the national framework has expanded to cover unsecured digital assets, digital financial assets, and regulated digital asset service providers, while the AIFC continues to operate under its own legal and regulatory framework.

The practical starting point is the activity. Businesses providing exchange or custody services within the AIFC may fall under AFSA. In contrast, activities outside the AIFC may fall under the National Bank and other national authorities, depending on the service. Mining and certain digital financial asset activities have their own regulatory requirements.

Obtaining a licence or registration is only the starting point. Businesses also need sufficient capital, appropriate governance, AML/CFT controls, cybersecurity, custody arrangements, transaction monitoring and reliable technology infrastructure.

For institutions entering Kazakhstan, the goal should be to build an operating model that meets regulatory requirements while giving the business the security, controls, and infrastructure needed to operate digital assets at scale.