Obtaining an EMI licence in Kazakhstan is now one of the most popular requests among fintech companies seeking to legalise the issuance and processing of e-money in a reliable, transparent and regulated jurisdiction. The transition from traditional banking instruments to digital settlements, the growth of cross-border trade, and the scaling up of e-commerce make e-money a key tool of the modern economy. In these conditions, obtaining the appropriate licence is not a formality, but a mandatory step towards full participation in the financial infrastructure.
What is an EMI licence in Kazakhstan and why businesses need it
According to the provisions of Kazakhstan legislation, e-money is pre-paid funds issued by a non-banking financial organisation and used for non-cash settlements. The issuer of e-money cannot be a person who does not have a special permit - this role is played by a licensed payment organisation. Therefore, in order to legally conduct the relevant activities, it is required to attain an EMI licence in Kazakhstan, i.e. to obtain a permit to issue and service electronic means of payment.
Such a licence entitles the holder to the full cycle of work with digital cash equivalents: from issuance to storage of customer funds and their distribution to the declared directions. Unlike the limited functions of payment agents and aggregators, EMI companies can place electronic balances on their accounts, issue funds into circulation and conduct clearing operations. As a result, the environment for e-payment organisations in Kazakhstan becomes broader and more favourable than in the case of the basic PSP format.
It is important to understand how EMI differs from other financial licences. A banking licence involves deposit-taking, lending and dealing with second-tier risks. A PSP (Payment Service Provider) licence is limited in its ability to hold customer funds and cannot issue its own digital units. However, licensing of e-money issuers in Kazakhstan covers not only payments, but also the issuance of a payment instrument that is an independent unit of settlement.
For entrepreneurs focused on scalable fintech solutions, the standards for licensed EMI firms in Kazakhstan provide flexibility in modelling their own services: from mobile wallets to online acquiring. This form of admission is particularly relevant for:
- start-ups creating innovative payment platforms;
- international players looking to enter the CIS and Central Asian markets;
- cryptocurrency companies looking for a legal entry point into the hybrid payments sector;
- cross-border e-commerce services working with multi-currency settlements.
It is also worth noting that legal regulations for EMI operators are not limited to a single licence. The legislation obliges to comply with a wide range of regulatory requirements, including implementation of KYC/AML procedures, maintenance of financial statements and monitoring of customer account balances. In this way, the organisation receives not just a formal authorisation, but commits to a high level of transparency and strict financial discipline.
In practice, an EMI licence gives businesses access not only to legitimate operations in Kazakhstan, but also to establish international links with banks, processing centres and payment services. It becomes a key sign of trust, confirming compliance with global standards in fintech and payment protection.
Legal regulation of EMI functioning in Kazakhstan
National regulations governing the issuance of electronic money and the activities of payment institutions are based on the principles of openness, responsibility and technological flexibility. The main legislative source regulating the issuance of licences in the field of electronic payments is the Law of the Republic of Kazakhstan ‘On Payment Services and Payment Systems’. It defines the procedure for admission to activities, establishes requirements for market participants and provides for measures to protect the rights of e-money holders.
ARDFM in Kazakhstan is responsible for issuing licences and controlling the activities of payment operators. This regulator checks whether a legal entity meets the established standards and decides whether to authorise payment transactions in Kazakhstan. In its work, it uses additional guidelines prepared by the National Bank, including regulations on reserve requirements, capital structure and measures to protect customers' personal data.
For organisations planning to obtain EMI status in Kazakhstan, it is important to consider not only compliance with formal documentary requirements, but also compliance with internal control principles. KYC (customer identification) and AML (anti-money laundering) procedures are particularly scrutinised. The applicant is required to develop and implement internal regulations that eliminate the risks of anonymous transfers, financing of criminal activities and violation of sanctions restrictions.
Financial technologies are constantly improving, and legislation must keep pace with innovations. Therefore, Kazakhstan regularly updates regulations affecting digital finance. Developers of payment solutions aimed at creating an organisation to work with electronic money in Kazakhstan should monitor changes in the regulatory environment, especially in terms of mandatory certification of software, user identification procedures and storage of reserves.
Regulatory requirements for EMI in Kazakhstan cover not only the form but also the content of the activity. The applicant must demonstrate not only legal readiness but also the technical soundness of its product. The licence itself is issued only if the stability of all internal processes, compliance of the IT infrastructure and transparency of the business model are proven. This is why legal support in the EMI authorisation process is critical for a successful market entry.
Registration of a lawful entity as an initial stage for EMI licence registration
Before starting the process of obtaining permission to issue electronic money, it is required to register a fintech organisation in Kazakhstan in full compliance with the current legal regulations. Without a registered legal entity, the licensing procedure cannot be implemented. At the same time, there are clearly established requirements to the legal form of organisation: the status of an e-money issuer is allowed only in the form of an LLP (limited liability partnership) or JSC (joint stock company).
The determination of the form is based on the intended scale of operations. For start-ups and limited operations, an LLP is the optimal solution, as registration is faster and does not require public reporting. If the project involves attracting investment and international expansion, it is preferable to formalise a JSC. In any case, the notarization of a lawful entity for EMI in Kazakhstan should take into account further requirements for the corporate structure, including the appointment of a resident director and the formation of a supervisory body.
Special attention should be paid to the authorised capital. Under current requirements, the minimum amount is 150 million tenge (approximately USD 330,000 at the current exchange rate). If the company intends to provide several types of payment services, the amount of the minimum capital is increased by 50 million tenge for each added service. These funds must be fully deposited at the time of application and their origin must be officially confirmed by documents. This condition is a mandatory requirement for the issuance of electronic cash in Kazakhstan and any failure to comply may be grounds for refusal to grant a licence.
In addition, it is necessary to ensure that there is an actual office within the State. Having a physical location confirms that the organisation is ready to operate in accordance with domestic law. The premises must be equipped with a system for storing documentation, working areas for staff and a secure internet channel. This condition is required for anyone planning to launch a digital payments business in Kazakhstan, especially when it comes to working with clients in the country.
The registration procedure includes submitting an application to the Ministry of Justice of the Republic of Kazakhstan or via the eGov platform. The standard term is up to 5 working days. It is necessary to submit the charter, decision of the founders, information on the director, ownership structure and legal address. In the case of a joint stock company, additional notarization of shares and information on holders is required. The registration fee is about 3 MRP (approximately USD 30), which makes the entry barrier low compared to other jurisdictions.
Registration of an e-money licence in Kazakhstan cannot be initiated without the full preparation of the legal framework. It is at this stage that the structure on which subsequent approval by the regulator depends is laid down. Mistakes made at the stage of company notarization can delay the licensing process for months and incur additional costs.
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Preparing to apply for an EMI licence in Kazakhstan
Once the notarization of a legal entity has been completed, the next step is the comprehensive preparation of the documents required to apply to the authorised body. This stage involves a comprehensive approach, both on the legal and organisational sides. At this stage, a set of supporting materials is compiled to demonstrate that the organisation meets the criteria for licensing financial institutions in Kazakhstan and has the capacity to carry out payment transactions safely.
First of all, a detailed business plan is developed. Its structure should include a description of the chosen business model, a list of services provided, forecasting of revenues and costs, calculation of expected transaction volumes, and characterisation of the technical architecture of the platform used. It is important to reflect the channels for attracting clients, the retention model, and the principles of working with residents and non-residents. At the same time, the business plan should be based on real calculations, not general assumptions. This is one of the basic requirements when trying to apply for EMI in Kazakhstan.
In addition to the business plan, an extensive list of supporting docs is required:
- Constituent documents (charter, decision on establishment, details of the founders).
- Accounting forms (in case of an existing business - financial statements for previous periods).
- Lease agreement or office documents.
- Information on the internal control system (KYC, AML, compliance, IS).
- Confirmation of the origin of the authorised capital.
All documentation shall be formed in Kazakh and Russian languages, and if there are foreign founders - with certified translations. Submission of an incomplete or incorrectly executed package automatically slows down the process. It follows that the preparation of documents for an e-money licence in Kazakhstan requires professional support and precise adherence to the structure established by the regulator.
One of the prerequisites is the existence of an internal regulatory framework. The company must develop and approve the following policies: anti-money laundering, customer identification, information security, complaint handling and incident management. The documents should not just exist formally, but should be adapted to the specifics of the applicant's business. Without this, it is impossible to issue an EMI licence in Kazakhstan, as the structure of risk and data protection mechanisms is a key focus of the regulator.
It is also required to appoint a person responsible for compliance and implementation of the AML policy. This is usually a full-time employee with experience in financial control, legal support or internal audit. His/her qualifications should be confirmed either by relevant education or a CV demonstrating relevant experience. The presence of this specialist is a prerequisite for notarization of a payment institution with a licence in Kazakhstan, as he or she will be responsible for compliance with all regulations once authorisation is granted.
The preparatory stage determines how confidently the applicant will enter the review procedure. Mistakes at this stage are the most costly, both in terms of time and reputation. Only if there is a complete set of documents that meets the statutory requirements and an effective internal control mechanism is in place, there is a chance to expect an approval.
Procedure for obtaining an EMI licence in Kazakhstan: peculiarities of the process
The procedure for obtaining authorisation to issue electronic money in Kazakhstan is governed by strict regulations. Each organisation intending to apply for an EMI licence in Kazakhstan is obliged to go through the established stages - starting with the submission of an application and ending with notarization in the list of payment operators. Failure to comply with the procedure or submission of an incomplete set of documents may result in a delay or refusal to consider the application. Therefore, it is extremely important to follow the established sequence of actions and rely on accurate legal practice.
Initially, the company forms an electronic application through the digital portal of the ARDFM of the Republic of Kazakhstan. The application contains information about the legal entity, describes the planned activities, the composition of the management, the ownership structure and the technical model of the payment system. All necessary annexes are attached to the application. This is the initial formal step in the procedure for applying for an EMI licence in Kazakhstan and it is critical at this stage to avoid errors in the form, language or authorisation of signatories.
Once the application is accepted, a formal verification of the attached materials begins. The supervisor verifies that the submitted business plan, internal AML/KYC policies, capital data, information systems documents, and office location information are compliant. If there are deviations in structure or key elements are missing, the application is returned without consideration. This is not a substantive rejection, but a technical return. However, in practice, it is at this stage that the most common mistakes are made by applicants seeking to obtain an EMI licence in Kazakhstan within a short timeframe.
If the formal check is passed, the regulator proceeds to the substantive examination. Internal procedures, sources of funding, compliance of the e-money storage model with the established norms are examined, and the company's ability to fulfil its obligations to clients is analysed. As part of obtaining authorisation for payment activities in Kazakhstan, special attention is paid to the internal control policy and the security of the information environment. If necessary, requests may be made to clarify certain sections of the business plan or information security documents.
If all stages have been successfully completed, the Agency decides to grant the licence. The organisation receives an official notification and is included in the state list. This indicates that the process of becoming an e-money issuer in Kazakhstan has been completed. The licence grants the authority to issue and maintain electronic money, as well as to use the national payment infrastructure in accordance with the current legislation. In certain situations, a pre-licence instruction is issued - describing the requirements to be fulfilled before commencing operations.
If the application is rejected, the firm receives a reasoned opinion describing the reasons for the rejection. This may be due to insufficient staff qualifications, unreliable data, a weak financial model or irregularities in the capital structure. In such a case, a reapplication is allowed no earlier than three months later. It is important to analyse the regulator's conclusion, eliminate the identified remarks and go through the procedure for applying for an EMI licence in Kazakhstan again, already taking into account the adjustments.
The time required to obtain a licence to issue electronic money in Kazakhstan is determined by the thoroughness of the documents prepared and the complexity of the proposed business structure. As a rule, the process takes from 45 to 90 days. However, if close co-operation is maintained with supervisory authorities and professional legal support is provided, the registration can be completed in the shortest possible time. For this reason, high quality preparation, legal support and strict compliance with procedural requirements are crucial for applicants wishing to legally and successfully enter the electronic payments market in this jurisdiction.
Financial and organisational obligations for EMI licence holders
Once a company is authorised to operate, it is obliged to comply with the established standing obligations. These regulations apply to both capital and internal operating regulations. Regardless of the size of the company, the regulator requires systematic compliance with the established standards for payment operator licensing in Kazakhstan and conducts regular inspections to confirm compliance with the stated conditions.
The main and determining condition is the availability of a minimum amount of authorised capital. As of the date of application, this indicator should not be less than 100 million tenge (about 220,000 US dollars at the current exchange rate). However, the presence of this amount on the account is not the only condition. The financial position of the company must remain stable throughout its operations. If the capital falls below the established level, the licence may be suspended. Therefore, those who plan to obtain an EMI licence in Kazakhstan should build a safety margin into the asset structure in advance.
In addition to fund, mandatory reserves are provided for. Issuers are obliged to hold the equivalent of the issued digital money on designated bank accounts. These funds can not be used for operating activities and must be available to cover customer liabilities at any time. This mechanism guarantees the safety of client money and builds trust on the part of market participants. This is a basic criterion for those seeking to formalise the status of a payment organisation with an EMI-licence in Kazakhstan.
Special attention is paid to reporting. Companies are required to provide:
- quarterly reports on financial position,
- information on the structure of electronic money in circulation,
- reports on fulfilment of obligations to clients,
- documents on compliance with AML/KYC policies.
Reporting is submitted electronically via a personal account on the regulator's website. Certain forms require an auditor's certification. Failure to comply with the submission deadlines will result in a warning, and in case of systematic non-compliance - revocation of the licence. Thus, the requirements for EMI companies in Kazakhstan are not limited to the moment of obtaining authorisation - it is a system of constant control.
The company's IT infrastructure is also under increased scrutiny. The regulator expects the system to have fault tolerance, protection from external attacks, monitoring and transaction logging systems. Availability of own software or a reliable external supplier ensuring continuous operation of the service is a mandatory condition for companies licensing a payment company in Kazakhstan and providing online services. In addition, it is necessary to ensure backup duplication of information, retention of action logs and development of internal data protection procedures.
Thus, after receiving the status of a payment organisation, the company's work is just beginning. The rules are strict, and compliance with them requires an aligned structure: both financial and operational. Any deviation from the norms may cost the business its licence. Therefore, at this stage, not only discipline is required, but also legal support to ensure continued compliance.
The advantages of obtaining an EMI licence in Kazakhstan
With the growing competition in the fintech sphere, Kazakhstan offers exceptional opportunities that make this jurisdiction perceived as an attractive platform for both domestic and foreign investors.
For entrepreneurs analysing the prospects of becoming an issuer, the EMI licensing procedure in Kazakhstan opens the way to building an open and scalable business model.
The main advantages of obtaining an EMI licence in Kazakhstan include:
- Currency flexibility - the ability to use multi-currency settlements and open accounts in dollars, euros, yuan and other currencies without restrictions.
- Non-resident service - no ban on registration of foreign clients, which gives room for global expansion.
- Low entry threshold - reasonable financial capital requirements, transparent registration, flexible reporting rules.
- Regulator's loyalty to innovation - the National Bank and the FRA demonstrate readiness to adapt regulations to the realities of the digital economy.
- Legal stability - the ability to protect business interests within the framework of international agreements and arbitration.
These factors make Kazakhstan an alternative to more expensive and regulated jurisdictions. At the same time, the degree of legal protection and openness of the business environment gives organisations the right to operate within the framework of international regulations.
No less significant is the fact that notarization of a payment company in Kazakhstan offers a chance to integrate into a set of government programmes aimed at digital transformation of the economy. The government is actively developing the fintech ecosystem by introducing support mechanisms for technology startups, which is especially relevant for small teams and pilot projects.
Thus, the strategic importance of the EMI licence in Kazakhstan goes far beyond formal admission. It is a tool for development, scaling up and legal access to global markets - in a jurisdiction that is ready to co-operate and support digital entrepreneurship.
Prospects for EMI and fintech market development in Kazakhstan
Kazakhstan is actively developing the digital economy, and the fintech sector is one of the key priorities of the state strategy. The country is implementing a national programme ‘Digital Kazakhstan’ aimed at supporting innovative payment services and transforming the traditional banking sector. In this environment, obtaining an EMI licence in Kazakhstan becomes not just a formal procedure, but part of a large-scale movement towards technological leadership in the region.
The interaction between government and business plays a key role in development. Regulatory authorities demonstrate openness to initiatives from private companies and constantly update legal norms. For example, in recent years, reporting requirements have been simplified, regulatory sandboxes for pilot projects have been introduced, and integration with international payment systems has begun. This has a positive impact on the EMI licensing process in Kazakhstan, making it more accessible to new entrants.
Obtaining authorisation for e-money in Kazakhstan provides companies with a strategic advantage against the backdrop of emerging markets in Central Asia. Against the backdrop of unstable regulatory regimes in other countries in the region, Kazakhstan offers predictable rules, developed banking infrastructure and access to world-class cloud and IT services. As a result, fintech companies can not only serve local clients, but also build cross-border models with access to neighbouring jurisdictions.
Not only startups, but also large investment groups, including those from the UAE, Turkey, South Korea and Singapore, are showing interest in the market. This confirms that applying for payment organisation status in Kazakhstan is not seen as a trial step, but as a full-fledged investment in a long-term presence. Moreover, the steady growth in the number of digital wallet users and the increasing volume of non-cash transactions confirm the high potential of domestic demand.
Thus, Kazakhstan's market is forming a sustainable ecosystem in which regulator, business and user interact. More and more initiatives are aimed at integration with the EU, EAEU and Middle East countries, which strengthens the country's position as a transit and technology platform. That is why obtaining an EMI licence in Kazakhstan in good time is not only a step towards legalisation, but also a gateway to new strategic opportunities.
How we support the process of obtaining an EMI licence in Kazakhstan
The process of licensing a payment organisation requires not only knowledge of the legislation, but also deep involvement in regulatory practice. We support projects at all stages - from choosing the legal form to obtaining the final licence. This allows us to significantly reduce timeframes, minimise the risks of rejection and ensure the legal stability of the business. Our work is based on a clear understanding of how EMI status is granted in Kazakhstan, as well as what difficulties and risks may await the applicant.
We start the process with a detailed legal and financial review of the project. Our team analyses the business concept, the origin of funds, the organisational scheme and the technological basis of the payment service. At this stage, it is important not only to comply with the law, but also to build a structure that is convenient for further scaling. Depending on the tasks, we offer optimal solutions for choosing between LLP and JSC, as well as developing a structure with participation of foreign beneficiaries. This approach provides the client with a stable position already at the stage of legal support in obtaining an EMI licence in Kazakhstan.
The second stage is preparation of documentation. We prepare a full set of installation and internal regulations, such as a business plan, calculation of financial parameters, AML/KYC-rules, internal risk management regulations and dossire security protocols, in accordance with legal requirements. All documents are agreed with the customer and customised to the specifics of the business. If a client launches a fintech product with non-standard logic (e.g. a hybrid of wallet and crypto-acquiring), we select appropriate arguments and prepare explanations for the supervisory authority. This is especially important for complex projects that need justification at the stage of assistance in applying for an e-money licence in Kazakhstan.
After preparing the full package, we represent the client's interests before the Agency for Regulation and Development of the Financial Market. We submit documents, correspond with the regulator, prepare responses to enquiries and participate in negotiations. If necessary, we conduct preliminary consultations with relevant specialists and adapt materials to their recommendations. Thanks to this, the application is considered faster and with fewer revisions. Practice shows that this approach reduces the probability of rejection by more than half. We view the issue of EMI notarization services in Kazakhstan as a complex task that requires coordination of not only the lawful, but also the operational part.
Our work does not end when the licence is issued. We support our clients during the post-licence period: we prepare internal regulations, help build a compliance function, advise on reporting and interaction with banks. If the business expands, we prepare documents for opening branches, amending the licence or transforming the corporate structure. This allows businesses not to waste resources on building a legal block from scratch, but to focus on the client and product side.
We do not offer template solutions. Each project is unique. That is why our team builds support taking into account the peculiarities of a particular business, risk level, jurisdiction of founders and scaling plans. Companies that apply to us for EMI status in Kazakhstan receive not just legal registration, but strategic support with a focus on sustainable growth in the digital economy.
Conclusion
Modern fintech requires not only technological readiness, but also a strategically calibrated choice of jurisdiction. With the global increase in control over payment instruments, Kazakhstan offers entrepreneurs a balanced solution: legal predictability, flexible regulation and access to emerging markets. That is why registering an EMI company in Kazakhstan becomes not just an administrative procedure, but a full-fledged investment step with a high payback potential.
The jurisdiction offers an optimal balance between the level of requirements and speed of authorisation. A transparent licensing system, digital infrastructure, openness to international capital and multi-currency settlements - all this makes Kazakhstan one of the few regions where it is possible to obtain an EMI licence in Kazakhstan without excessive costs and administrative barriers.
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