Kazakhstan · Licensing & Access
Key points
- National treatment: the March 2026 constitutional referendum confirmed equal rights for foreign and domestic investors; foreign investors no longer enjoy universal privileges, only industry-specific tax incentives in government-encouraged sectors.
- Industries fully closed to foreign investment agreements (negative list): narcotics and psychotropic substances, production/wholesale of excise goods, lotteries, gambling, radioactive materials, specific banking and insurance activities, auditing, securities professional activities, digital mining, credit bureaus, security activities, arms and ammunition, mining and sale of minerals (including coal and oil trading), etc.
- Foreign-share-restricted industries: banking - foreign bank branches prohibited, foreign bank capital share not exceeding 25% of total domestic bank capital, prior approval for acquiring 10%+ of voting shares; insurance - joint-venture non-life insurance foreign share ≤25%, joint-venture life insurance ≤50%; mass media - foreign share ≤20% and no management positions (per 2024 Mass Media Law).
- Mineral resources: the foreign-share cap for uranium mining has been tightened from ≤50% to ≤25% for new agreements and ≤10% for extensions (presidential amendments December 2025); solid minerals and hydrocarbons are subject to tiered regulation.
- Land: since May 2021, foreigners, stateless persons and foreign-invested Kazakh legal entities are fully prohibited from acquiring private ownership or temporary use rights to agricultural land.
- Investment agreement dividends: signing an investment agreement with the Investment Committee can yield 5-year import duty exemptions, state in-kind subsidies up to 30% of investment, 10-year CIT and land tax exemption for new production projects, and 8-year property tax exemption (subject to 'priority investment project' PIR designation).
Procedure
- Determine whether the intended industry is on the negative list or foreign-share-restricted list (exclude prohibited categories first).
- For restricted industries, assess whether the foreign share triggers approval thresholds (e.g. banking ≥10%, uranium ≥25%).
- Large encouraged projects may apply to the Investment Committee to sign an investment agreement to lock in tax incentives and subsidies.
- Specific activities require industry licenses: construction, finance, telecom, energy, pharmaceuticals, education, etc.
- Foreign acquisitions reaching the antitrust notification threshold must be filed with the competition protection authority.
Hard requirements
- Negative-list industries cannot sign investment agreements or require special approval.
- Restricted industries (banking, insurance, media) must meet share-ratio and management-nationality limits.
- Land (especially agricultural) cannot be acquired by foreign investors (hard ban on ownership or use rights).
- Large investments or acquisitions trigger antitrust and foreign-investment security review.
Costs
Investment agreement negotiation and legal service costs (project-scale dependent).Industry license application fees (per competent authority standards).Antitrust and foreign-investment review filing costs.⏱ ⏱ Timeline:Industry access assessment 1-2 weeks; investment agreement negotiation takes months; license approval 1-3 months by industry.⚠ Common risks
- Clear tightening trend in uranium/mineral foreign policy; share caps may be further reduced
- Land ban on foreign ownership is absolute; agriculture/plantation projects must lease and avoid ownership
- Media foreign share ≤20% and no management roles; content business structures constrained
- Investment incentives require a signed investment agreement; without it no universal tax concessions
📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)
Applies to:Industry access and qualification assessment for Chinese investment in Kazakhstan, covering the negative list, shareholding restrictions, investment agreement incentives, industry licenses and antitrust filings
Prerequisites
- Intended industry and business model clarified
- National security or strategic-interest industry trigger assessed
- Large projects assessed for investment agreement (PIR) feasibility
- Localized hiring and management nationality planned
| Step | Action | Owner | Timeline | Cost | Official form / system | Notes & penalties |
|---|---|---|---|---|---|---|
| 1 | Determine whether the intended industry is on the negative list or restricted list (exclude prohibited categories first) Exclude prohibited categories per the negative list (narcotics, gambling, uranium mining, mineral sales, specific media, etc.) | Enterprise / lawyer | 1-2 weeks | Legal opinion fees | Industry access assessment | March 2026 constitutional referendum confirmed national treatment for foreign investors Penalty:Entering a prohibited category makes it impossible to sign an investment agreement |
| 2 | Restricted industries: assess whether foreign share triggers approval thresholds Foreign bank branches prohibited; foreign bank capital share ≤25%; acquiring 10%+ voting shares requires approval; uranium new agreements ≤25%, extensions ≤10%; media ≤20% and no management roles | Enterprise | 1-2 weeks | — | Share-ratio calculation | Insurance: joint-venture non-life foreign share ≤25%, joint-venture life ≤50% Penalty:Exceeding threshold without approval is a violation |
| 3 | Large encouraged projects may apply for an investment agreement to lock in tax incentives and subsidies Sign an investment agreement with the Kazakhstan Investment Committee to obtain 5-year import duty exemption, state in-kind subsidies up to 30%, etc. | Investment Committee / enterprise | Months | Negotiation and legal services | Investment agreement application (business plan, techno-economic feasibility) | Agreement terms remain stable for 25 years (except legal changes) Penalty:Without a signed agreement, no generally applicable tax relief |
| 4 | Specific activities require industry licenses: construction, finance, telecom, energy, pharmaceuticals, education, etc. Apply for operating licenses with the competent authority by industry | Competent authority | 1-3 months | License fees | Industry license application | Financial activities need AFSA/AIFC license; energy and minerals need subsoil use licenses Penalty:Operating without a license is penalized |
| 5 | Foreign acquisitions reaching the antitrust threshold must be filed with the competition protection authority File concentration of undertakings that meets turnover or asset thresholds | Competition protection authority | 1-3 months | Filing fees | Antitrust filing | Review includes completeness check and substantive review phases Penalty:Failure to file is penalized |
| 6 | Land (especially agricultural) cannot be acquired by foreign investors - use leasing instead Agricultural land is fully closed to foreign ownership and temporary use rights; switch to leasing | Enterprise | — | Rent | Lease agreement | Absolute ban since May 2021 Penalty:Prohibited acquisition of ownership is void |
| 7 | Confirm national treatment and plan localization Confirm only national treatment applies, no universal privileges; only government-encouraged industries receive specific incentives; localized hiring arrangements in place | Enterprise | — | — | — | Incentives are conditional on signing an investment agreement |
✅ Self-check list
⚠ Common pitfalls
📅 Ongoing post-incorporation obligations
- Perform investment agreement obligations (incentives correspond to investment commitments).
- Industry license renewal and compliance management.
- Antitrust filing and follow-up on concentration matters.
- Maintain localized hiring ratios.
- Re-file for major changes.
- Maintain PIR designation (investment progress).
🔗 Official portals
🔧 CCC Mandatory Certification (China · Source-Country Manufacturing Prerequisite)
Benchmarked against C2P's product-compliance module: C2P lists a global certification catalog, whereas this library turns China's CCC into a do-it-now checklist — determine catalog scope, pick the body, type testing, factory inspection, obtain certificate, annual surveillance. Applies to all outbound products sourced from / supplied via China.
📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)
Applies to:Physical products produced or imported in mainland China that fall under the Compulsory Product Certification Catalog; includes outbound enterprises 'sourcing manufacturing/supply from China with domestic-sale or domestic-sale-linked channels'. Pure-export products that can provide export proof may apply for exemption, but the determination must be made first.
Prerequisites
- Product BOM and model frozen
- Determined against the latest CCC Catalog whether it is listed
- Domestic production plant has basic quality system in place
- Selected a CNCA-designated certification body (mainly CQC)
| Step | Action | Owner | Timeline | Cost | Official form / system | Notes & penalties |
|---|---|---|---|---|---|---|
| 1 | Determine whether the product is in the CCC mandatory catalog Cross-check against the latest CNCA Compulsory Product Certification Catalog and implementation rules to confirm the product model is listed; note the catalog is dynamically adjusted (some products have been removed). | Manufacturer / compliance consultant | A few days | — | CCC catalog cross-check | Products outside the catalog need no CCC; but 'similar names' are easily misjudged — verify against the CN sub-items in implementation rules. Penalty:Certifiable product produced/sold/imported without certification → unlawful, punished by customs and market regulator |
| 2 | Select a designated body & submit application Submit the certification application to a CNCA-designated body (mainly China Quality Certification Centre CQC), specifying the certification model. | Certification body (CQC etc.) | Acceptance in days | Application fee | CCC certification application | Only certificates from designated bodies are valid. Penalty:Certificate from a non-designated body is invalid |
| 3 | Send samples for Type Testing Per the implementation rules, send samples to a designated lab for safety, EMC and other type tests and obtain the test report. | Designated lab | Weeks | Testing fee | Type test report | Must use a production-representative sample. Penalty:Failed test cannot proceed to next step |
| 4 | Initial factory inspection The body inspects the plant's quality-assurance capability (man/machine/material/method/environment + consistency control), confirming consistency with the type-tested sample. | Body inspection team | Days–weeks | Inspection fee | Factory inspection report | Failed inspection and consistency defects are common blockers. Penalty:Factory inspection failed → no certificate issued |
| 5 | Certification decision → obtain CCC certificate + mark The body makes a certification decision combining test and inspection results; upon approval issues the CCC certificate, and the enterprise applies for and uses the CCC mark per rules. | Certification body | Decision in days | Certificate fee / mark fee | CCC certificate / CCC mark | The mark must be applied per spec; counterfeiting is prohibited. Penalty:No certificate or counterfeit mark → administrative even criminal liability |
| 6 | Post-certification supervision (annual factory inspection) During the certificate's validity, accept annual follow-up inspection and product sampling to maintain validity. | Certification body | Every year | Annual fee / supervision fee | Annual supervision report | Missed inspection or failed sampling may suspend/revoke the certificate. Penalty:Certificate revoked → product banned from sale |
| 7 | Export / domestic-sale release & exemption determination Domestic sale/import cleared against the CCC certificate; pure-export products meeting conditions may apply for exemption with export proof, but catalog determination and record retention must be done first. | Enterprise / customs | With business | — | Export proof / customs clearance | 'Export exemption from CCC' ≠ blanket exemption; determine batch by batch per customs and certification rules. Penalty:Domestic sale/import without required certificate → punished |
✅ Self-check list
⚠ Common pitfalls
📅 Ongoing post-incorporation obligations
- Annual factory-inspection and product sampling
- Certificate maintenance and change declaration (model/BOM/critical parts)
- Compliant use of the CCC mark
- Retain export-exemption records for inspection
- Track dynamic catalog adjustments
🔗 Official portals
CompliGo · Outbound Compliance Automation
You now have the essentials. Hand it to CompliGo: auto-generate compliance documents, real-time validation, and one-click regulatory alerts. Free trial for new users.