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- Madina Erasylovna, what results has the banking sector reached by 2025? How do you assess the situation in the financial market considering external and internal challenges?

- In 2024, Kazakhstan's economy and financial sector were developing in the context of external and internal challenges.

At the global level, tough macro-financial conditions persisted due to increased geopolitical risks and sanctions restrictions. The global energy commodities market experienced increased volatility amid regional conflicts, as well as slowing growth in major EU countries and China.

At the local level, Kazakhstan has faced economic consequences from floods, as well as high inflation and rates limiting business access to long-term financing. Inflation at year-end was 8.6%, but remains at a high level. Its slowdown is mainly due to moderately tight monetary policy (the NBK's base rate is 15.25%) and lower food prices.

Despite external and internal challenges, Kazakhstan's economy is demonstrating progressive growth, which totalled 4.4% YoY in the first 11 months of last year. The basic sectors of the economy maintain positive growth rates. The highest growth is observed in agriculture (+13.4%) and construction (+10.3%). Trade grew by 8.2%, transport - by 8.1%, manufacturing - by 5.3%.

In turn, the banking sector remains stable and grows, actively supporting the economic goals of the state. Positive dynamics is observed in all key financial indicators. Banks’ assets increased by 15.1% in the first 11 months of last year, reaching 59 trln tenge (2.2 times growth since 2020). Deposits grew by 13.3% to 40 trln tenge (2.2 times growth since 2020), indicating growing confidence in the banking system on the part of economic agents.

The banks' loan portfolio grew by 17.2% to 35 trln tenge (2.4 times growth since 2020). Loan quality remains at a high level, the share of NPLs is 3.2% or 1.1 trln tenge (NPL ratio of 8.1% in 2020).

In 2023, the International Monetary Fund and the World Bank conducted the Kazakhstan Financial Sector Assessment Program (FSAP) to assess the compliance of banking regulation and supervision with the Basel Committee's principles of effective banking supervision.

The IMF and World Bank experts noted significant progress in the development of risk-based supervision in Kazakhstan, including the introduction of risk-based supervision under the SREP methodology, regular asset quality review (AQR) and supervisory stress testing, which have become annual activities that complement the supervisory assessment process. A positive assessment was given to the implementation of Basel-3 standards, including the introduction of systemic, conservation and countercyclical capital buffers and new liquidity (LCR) and funding (NSFR) standards.

According to the results of the assessment of compliance with the Principles, it was noted that banking regulation and supervision in Kazakhstan fully or significantly comply with 22 out of 29 Principles (more than 75%), partially compliant - 7.

At the same time, the FSAP Mission recommended to take measures to finalize the alignment of certain capital and liquidity requirements to the Basel standards.

In implementation of the FSAP recommendations, supervisory add-ons to the minimum capital adequacy based on the results of supervisory review (SREP), asset quality review (AQR) and stress testing were introduced from 2024. To enhance bank resilience, the conservative capital buffer for banks was increased from 2.0% to 2.5%, if breached, restrictions on dividend payments are imposed.

With a view to enhancing financial stability, the implementation of all elements of consolidated supervision of banking conglomerates was finalized last year. In particular, a new procedure for calculating the adequacy of a banking conglomerate's own capital was introduced to ensure a more accurate assessment of the minimum requirements for the own capital of the banking conglomerate's participants and to eliminate the risk of overestimating the conglomerate's financial stability indicators.

In order to strengthen supervision over banking conglomerates, requirements were introduced to the risk management and internal control system of a banking conglomerate, the role of the board of directors of a banking holding company was strengthened, requirements were introduced to capital management, stress testing and sensitivity analysis of the main types of risk inherent in the activities of a banking conglomerate, and requirements were established for monitoring liquidity risk of the banking conglomerate's participants.

To improve credit risk management and accurately assess asset quality, the concept of non-performing loans (NPLs) was introduced, with the value of NPLs set at no more than 10% of the loan portfolio.

In order to enhance co-operation and ensure effective cross-border supervision of banks in accordance with the standards of the Basel Committee, Memorandums were concluded with the US Office of the Comptroller of the Currency, the Financial Services Commission and the Financial Supervisory Service of the Republic of Korea and the Hungarian National Bank.

This year, in order to increase the stability of the banking system and prevent excessive increase of the borrowed capital, it is planned to introduce a new prudential norm - leverage ratio, which will be set at the level of 3% of risk assets and contingent liabilities.

The Agency also plans to introduce legislative amendments aimed at tightening transactions with related parties and establishing requirements for auditing related parties. The relevant amendments are planned to be envisaged within the framework of development of the new law on banks.

Our measures to reduce risks in the banking system of Kazakhstan were highly assessed by S&P Global Ratings and raised the country's position in the BICRA rating. The experts improved the assessment of risks in the banking sector from group «8» to group «7». This was achieved due to, among other things, an effective policy of strengthening supervision over the financial sector. Improvement of rating led to increase of ratings of seven Kazakhstan financial organizations.

S&P Analysts also noted the resilience of the banking sector to macroeconomic challenges and geopolitical risks. The assessment of the quality of assets and financial performance of banks exceeded their expectations. As a result of the implementation of systemic measures, the level of problem loans in the system decreased from 18% in 2020 to 7-7.5% in 2024, which contributed to the improvement of the country's financial stability.

In general, the completion of the reforms being implemented will ensure full compliance with the standards of the Basel Committee on Banking Supervision, which will contribute to improving the sustainability of the banking system and strengthening risk management mechanisms.

What measures is the Agency taking on its part to expand corporate lending?

- Along with improving regulation and ensuring stability of the financial system, the Agency is actively working to fulfil the Head of State's instruction to expand lending to the real sector of the economy.

First. The Agency has introduced a number of incentive prudential measures. The key condition for expanding lending is that banks have sufficient capital and liquidity.

When deciding to issue a loan, banks assess risks and determine the necessary capital to cover potential losses. Traditionally, for loans to small and medium enterprises (SMEs), the risk-weighting ratio is 100%. In order to reduce the burden on capital when lending to such entities, we have decided to reduce this ratio to 50%. This measure should encourage banks to lend more actively to SMEs, including start-ups. Similar relaxations were introduced for syndicated loans.

Reduced LCR and NSFR liquidity ratios of 0.9 will be applied to free up liquidity for banks until 2026, provided that the released liquidity is redirected to lending to the real sector.

These measures reduce pressure on banks' capital and liquidity, freeing up additional funds for lending to the real sector.

Second. One of the main factors constraining entrepreneurs' access to credit is the requirement of banks to have collateral. When assessing collateral, banks apply various discounts, which leads to a reduction in the loan amount or even a refusal to grant it.

Since 2020, we have been conducting an annual assessment of banks' asset quality (AQR), including collateral. This allows us to determine the real value of collateral and set more accurate liquidity ratios. Initially, these ratios were higher, but now we have brought them in line with the actual value of collateral. Thus, we increased liquidity ratios for pledges in the form of motor vehicles, equipment and cash under public-private partnership agreements and off-take contracts. Given the limited quality of collateral available to agricultural producers, we also recognized grain receipts as hard collateral.

In order to reduce the amount of provisions created by banks, the requirements for their calculation in terms of forced restructuring criteria were also revised. Separate impairment criteria were introduced for investment loans. This measure will give banks more opportunities to lend investment loans both individually and as part of project financing.

In addition, to reduce administrative barriers and ensure prompt decision-making on SME lending, the maximum loan size within which a simplified procedure for analyzing the borrower's creditworthiness is applied was revised from the current level of 0.2% of the capital to 500 mln tenge or 0.2% of the bank's capital.

Third. Subsidiary foreign banks represent a great potential for business lending. Today there are 9 subsidiary foreign banks operating in Kazakhstan. The total capital of their parent organizations is about 1.3 trln USD, and the loan portfolio of subsidiary banks is 2.9 trln tenge.

In this regard, it is important to use the capabilities of parent banks to expand lending to the real sector. To this end, last December we introduced new prudential measures. In particular, we increased the maximum value of banks' capitalization ratio to non-resident liabilities. In addition, we recognized foreign currency bonds of international financial institutions as domestic assets when calculating the domestic asset allocation ratio. These measures enhanced the access of foreign bank subsidiaries to funding from parent banks for subsequent financing of entrepreneurs.

Fourth. Due to the high base rate and existing tax incentives, investments in highly liquid assets, including government securities, remain attractive for banks. In addition, high-margin consumer lending remains attractive against the background of demand from the population.

In this regard, the new Tax Code considers fiscal measures to increase the attractiveness of bank corporate lending. In particular, it is planned to introduce differentiated corporate income tax rates for banks and microfinance organizations, providing for a lower rate for income from business lending. In addition, tax arbitrage between banks' income from investments in government securities and business lending will be eliminated.

Along with this, we have taken measures to discourage the active issuance of consumer loans. Thus, the risk weighting for such loans was increased from the standard 100% to 350%, depending on the loan amount and interest rate.

Last June, legislative amendments for the development of syndicated lending were also adopted. They provide for the expansion of syndicate participants to include non-resident banks and AIFC banks, as well as the possibility of converting a bank loan into a syndicated loan. A project office for syndicated financing has been established on the basis of Baiterek Holding, which is actively working with development institutions and private banks. As a result, financing of five projects worth 835 bln tenge has already been approved, and 12 more projects totalling 6.5 trln tenge are under consideration.

One of the problems in expanding corporate lending is the short-term funding base of banks. In order to provide banks with long-term funding for lending to investment projects, together with the National Bank, a mechanism was launched to invest pension assets of the Unified Accumulative Pension Fund in bank bonds of up to 500 bln tenge for a period of up to 7 years on market terms. To date, banks have attracted 220 bln tenge for further lending.

To digitize business lending procedures, banks' information systems were integrated with 49 services of state databases on legal entities, real estate, tax data, licensing, income and others. Work will continue to expand the remote submission of loan applications by business entities.

The measures taken have created favourable conditions for further economic growth and are already yielding results. In January-November 2024, the issuance of new loans to real sector entities increased by 19.3% compared to 2023 and totalled 16.1 trln tenge. The aggregate portfolio of loans to businesses increased by 12.0% to 12.6 trln tenge.

To expand the potential of the guarantee system, the creation of the SME Loan Guarantee Fund with the participation of banks is being discussed. This model envisages that guaranteeing will be carried out not only at the expense of the state budget, but also with the participation of banks and SMEs themselves.

Participation in the system of guaranteeing banks and SMEs reduces dependence on the state budget, making the system more self-financing, and facilitates risk sharing between the state, banks and businesses, increasing the overall sustainability of the system.

In general, to increase the availability of credit to business, it is important to create appropriate macroeconomic conditions to ensure low and stable inflation and interest rates, as well as a stable national currency exchange rate. It is also important to increase the transparency of the ownership structure and governance of the corporate sector, and to introduce advanced standards of corporate governance and information disclosure.

- What measures are needed to strengthen the fight against financial fraud?

- Effective counteraction to financial fraud requires coordinated work of both law enforcement agencies, financial regulators and financial organizations.

To solve this task, last year the National Bank created a special Anti-Fraud Centre, which allows exchanging information in real time between banks and the Ministry of Internal Affairs, maintains «black» and «grey» lists of fraudsters, and blocks funds for suspicious transactions. Since its operation, almost 13,000 incidents worth over 1 bln tenge have been blocked.

In order to strengthen inter-agency coordination, the Roadmap for the implementation of mechanisms to counter financial fraud was approved on 5 December last year, which provides for a number of measures, including the adoption of legislative amendments aimed at countering fraud in the financial market.

Among them is the introduction of a so-called «cooling-off period» when issuing a consumer unsecured loan of more than 150 MCI (more than 589,800 tenge in 2025). That is, now the bank will not immediately transfer the loan amount to you, but will give you a day to think about it. This will allow the borrower to change the decision and refuse the loan within 24 hours.

The power of the Anti-Fraud Centre will also be expanded by involving law enforcement and special agencies, defining the procedure for interaction with mobile operators aimed at timely identification and blocking of mobile numbers involved in fraudulent operations.

Consideration is being given to requiring lenders to conclude a loan agreement with a citizen only in person at a bank or MFI branch if the citizen is applying for a loan for the first time. The bank or MFI would have to verify the identity of the client and obtain confirmation that the loan is indeed being arranged at the client's initiative. This will enable the lender to fully educate and ensure that the client understands the terms of the contract and recognizes the possible risks of defaulting on the loan.

To prevent fraudulent loans to vulnerable categories of citizens (young people under 21 years of age, the older generation and citizens who have not previously entered into loan agreements with a bank or MFI), it is proposed to establish an automatic ban on unsecured consumer loans for these groups with the possibility of cancelling it on the e-Gov portal.

Together with the Ministry of Digital Development and the Aerospace Industry, the creation of a Single Contact Centre with a short number to receive citizens' complaints about telephone fraud is being worked on. The Contact Centre will collect information on fraudulent calls, carry out initial verification and classification, and then take a decision on blocking the mobile number, withdrawing the SIM card from the mobile operator and blocking the messenger account. In addition, it is planned to oblige telecom operators to create mandatory anti-fraud departments, which, among other things, should assess the risks of telephone fraud similar to risk management systems in second-tier banks.

To prevent uncontrolled use of SIM cards, it is planned to introduce a requirement for mandatory biometric identification when registering a mobile phone number, also to consider limiting SIM card registration to one person and prohibiting registration to distributors/legal entities.

In addition to blocking devices used by fraudsters, consideration is being given to tightening regulation to restrict the use of SIM boxes in Kazakhstan.

The roadmap also envisages regular large-scale awareness-raising work among the population on cybercrime, internet fraud and methods of protection against them, training for law enforcement officials, and the creation of a single regulated process of interaction between all involved parties.

All these measures will make it possible to increase the effectiveness of risk counteraction, improve monitoring and ensure greater security in the financial sphere.

– How has the insurance sector developed in 2024? What are the key initiatives planned for the development of the sector this year?

– In 2024, the insurance sector demonstrated significant growth in all key indicators. Insurers' assets increased by 21% over 11 months to 3 trln tenge, which is 2.5 times more than five years earlier. Such growth became possible due to an increase in the number of concluded insurance contracts and active investment activities of insurance organizations.

The number of concluded contracts in 2024 amounted to 21 mln, a 38% increase compared to 2023. Over the past five years, the number of contracts has doubled. The volume of collected insurance premiums exceeded the level of 2023 by 53% and totalled 1.3 trln tenge, a historical maximum. Premiums have tripled over the last five years, which indicates growing confidence in insurance and increasing demand for insurance services.

Insurance payouts for the first 11 months of 2024 totalled 301 bln tenge, up 23% from 2023. The leaders are the mandatory types of insurance, with payouts increasing by 64%. Over the last five years, payouts have increased 1.5 times.

The main trend in the development of the insurance sector is digitalization.

From 2024, insurance payments for all compulsory classes of insurance have been automated. Now it is possible not only to conclude an insurance contract online, but also to send an application and a package of documents for insurance payments via the website or mobile application of an insurance organization.

Last year the first digital insurance product Europrotocol was launched. Now car owners involved in minor road accidents can apply for insurance payment in a simplified procedure via a mobile application without calling the traffic police or going to court. Thanks to the Europrotocol, insurance payments under compulsory motor insurance have increased significantly. Last year, 2.3 bln tenge was paid out in 15,276 cases under the simplified procedure. The average payment period was reduced to 15 calendar days, whereas previously this procedure took an average of 2-3 months from the date of the road accident.

An important element of digitalization is the integration of the Unified Insurance Database (UID) with 38 state databases. Today, the Unified Insurance Database generates complete statistics on all insurance contracts. This ensures transparency in the insurance sector and simplifies the process of obtaining insurance services.

Large-scale integration has made it possible to automate the calculation of compulsory motor insurance tariffs in the Unified Insurance Database. Starting from 2024, tariffs are recalculated in the Unified Insurance Database considering current loss rates by region, which allows car owners in regions with low accident rates to pay less for insurance.

From April this year, insurance organizations will be able to give their customers discounts for driving without accidents for 5 years. Scoring of drivers will be carried out automatically with the help of the Unified Insurance Database.

The «bonus-malus» system, which is familiar to every driver, will now consider the severity of the accident and compliance with traffic rules. For example, if there are victims as a result of an accident, the driver was in a drunken state or committed serious violations of driving rules, the coefficient of the ‘bonus-malus’ system will be reduced more, respectively, the cost of insurance for the next year will increase.

In 2025, the development of digital services and increased accessibility of insurance will continue. An important step will be the possibility for insurance organizations to invest in IT companies, which will help to improve the availability and quality of services for population and businesses.

In addition to digitalization, the expansion of insurance types and the emergence of new insurance products contribute to the sector's growth.

From 2024, insurance companies offer products under the State Educational Savings System. This system allows Kazakhstani citizens to save money for their children's education, receiving an annual state premium of 5 to 7% and investment income from the insurance company. To date, more than 3,000 contracts have been concluded for the amount of 670.5 mln tenge.

In addition, at the end of 2024, legislative amendments were adopted to introduce a unified voluntary savings system «Keleshek». Now, for each insurance contract or bank deposit contract concluded within the scope of the State Educational Savings System, the state will accrue start-up capital in favour of a child who turns five years old in the current year. These measures will help citizens save for education and expand the scope of application of savings insurance products.

In order to encourage our citizens to accumulate funds using insurance products, we plan to extend the guarantees of the Insurance Payment Guarantee Fund to all types of accumulative life insurance. Now the Fund's guarantee covers all compulsory classes, pension annuities and State Educational Savings System contracts.

From 1 January 2024, new insurance benefits were introduced in the compulsory occupational accident insurance system. Employees with more than 7 years of service in hazardous industries can retire earlier (from the age of 55), receiving monthly payments from the insurance organization in the amount of 1 living wage until the age of 63. Already 2.9 bln tenge has been paid to more than 10 thousand citizens. From 2025, the Mandatory Accident Insurance will provide rehabilitation payments to injured workers to restore their health and preventive payments to the employer to improve working conditions.

Over the last 7 years, 7 new types of imputed insurance have appeared on the market. These include professional liability insurance for lawyers, legal consultants, private bailiffs, customs representatives, customs warehouse owners and medical insurance for labour migrants.

In 2024, imputed liability insurance for medical professionals was introduced. This type of insurance protects the interests of patients against substandard medical services. As of today, 140,000 employees of medical organizations are insured and this number continues to grow.

In 2025, it is planned to introduce imputed liability insurance for owners of mass gathering facilities against fires.

An important project in the insurance sector is the development of an optimal catastrophic insurance model for Kazakhstan.

This is especially important for the protection of citizens' property in areas with a high risk of natural disasters. At the moment, the coverage of the population with such insurance is extremely low - 3.2% on average in the country.

International experience shows that effective catastrophic insurance systems are always multi-level and include payments from several sources. Kazakhstan will work on the creation of such a system, including public-private partnership and reinsurance of risks from international companies. Consideration is also being given to introducing compulsory home insurance in regions with high catastrophe risk in order to maximize insurance coverage for citizens.

– What results and key changes can be noted in the securities market sector? What are the plans for the development of the securities market for the current year?

– The securities market is actively developing and demonstrates steady growth of key indicators.

Since the beginning of 2024, the capitalization of the equity market has increased by 23% to 32.9 trln tenge, over 5 years this indicator has increased by 72.3%. At the end of 2024, 84 Kazakh companies registered on KASE 99 names of shares.

The corporate bond market also demonstrated strong performance. The volume of corporate debt in circulation on KASE reached 13.7 trln tenge. The trade lists include 511 bond issues from 126 issuers, 29 of which are new issuers.

The capital market has seen significant growth in the number of retail investors. This has become possible due to digitalization of brokerage services and IPOs of large national companies. As a result, the number of accounts in the nominee holding system of the Central Securities Depository (CSD) increased by 40% and reached 3.4 million. Over the last 5 years, this indicator has increased 25 times.

Last year, the Agency continued its work to improve the integration of the stock market infrastructure into the ecosystem of global capital markets. The key innovations were the creation of conditions for the activities of an account operator and a foreign accounting organization.

As part of the first direction, domestic banks have been granted the right to provide management services for depositor accounts opened in the Central Securities Depository in the name of the depositor. This will allow global custodians to directly conduct transactions with Kazakh securities and manage operational risks on the local stock market.

Following the example of the EU countries, Kazakhstan regulation introduces norms allowing a foreign accounting organization to record and confirm the rights to equity securities held on the account in the Central Securities Depository. Now global custodians, such as Euroclear and Clearstream, will be able to confirm ownership of Kazakhstan securities in their nominee holding systems. This will simplify the process of concluding transactions, reduce settlement time, which will reduce their final cost.

At the same time, the Agency continued its efforts to improve the settlement and clearing systems. Last year, measures were taken to expand the activities of the Clearing Centre and the Central Securities Depository.

As a result, the Clearing Centre is vested with the right to carry out brokerage and dealing activities. This measure is aimed at increasing the efficiency of the Clearing Centre's performance of its functions and ensuring the guarantee of execution of trades in the market.

In addition, the functionality of the Central Depository in the OTC market has been significantly expanded, with the possibility of carrying out conversion transactions and maintaining bank accounts for individuals. In addition, the Central Securities Depository can service transactions of retail investors with financial instruments in the OTC market within the framework of its OTC platform.

Thanks to the well-established trading, clearing and settlement infrastructure, in 2024 KASE and the Clearing Centre joined the digital exchange Tabadul Hub (Abu Dhabi), providing access to trading in foreign securities on various international markets.

The measures taken to develop infrastructural institutions are highly recognized by international experts. This year, the British rating agency Thomas Murray assigned the Clearing Centre an A+ rating. The same rating is given to the top 30 central counterparties in the world. The Thomas Murray report also confirmed the compliance of clearing activity regulation with the CPMI-IOSCO PFMI principles.

Thus, today the infrastructure of Kazakhstan's capital market has all the resources and technical capabilities to become a regional hub of Central Asia and EAEU.

The key tasks in the securities market sector in 2025 are the development of the collective investment market and the introduction of a new legislative framework on rating activities.

In accordance with the latest global trends and standards of financial market regulation, last year work was carried out to update the Law «On Investment and Venture Capital Funds» and to develop a new Law «On Credit Rating Agencies».

The main emphasis of the updated Law «On Investment and Venture Capital Funds» is on liberalization of regulation of the collective investment market and expansion of investment opportunities for private investors. The legislative level will provide for the possibility of establishing funds in any organizational and legal form, and a new classification and types of funds will be introduced.

As part of the new Law «On Credit Rating Agencies» the main principles of the operation of rating agencies will be regulated, including the management of conflicts of interest, disclosure of information, and corporate governance.

The implementation of these legislative initiatives will help establish a domestic competence center for independent credit risk assessment. This, in turn, will expand financing for the real sector of the economy and provide the market with high-quality, objective, and accessible rating services. It is expected that the adoption of the new law will reduce the cost of rating services for Kazakh companies, including SMEs, and ensure the protection of the rights of non-qualified investors.

Another important area of capital market development is stimulating institutional demand and expanding the investor base.

To strengthen the potential of the domestic securities market, we are developing legislative amendments aimed at increasing the share of domestic placements of securities by Kazakh issuers when they are simultaneously placed on foreign markets, from 20% to 50%. These changes are intended to increase the liquidity and capitalization of the domestic securities market, as well as expand access for local investors to high-quality financial instruments.

The Agency is working to create conditions for the emergence of a new class of institutional investors – endowment funds. After the adoption of the Law «On Target Capital Funds (Endowment Funds)» the Agency will establish the procedures for managing the assets of endowment funds and define the list of financial instruments available for investment by these funds.

We are also planning a number of measures aimed at developing digital financial assets. In 2025, the first tokenized mortgage bonds are expected to be issued on the Kazakhstani securities market.

In addition, the Agency is taking steps to develop new approaches to the regulation of pension asset managers and expand the range of financial instruments available for pension asset investment. Currently, only 5 companies offer pension asset management services – Jusan Invest JSC, Halyk Global Markets JSC, BCC Invest JSC, Halyk Finance JSC, and Centras Securities JSC. These companies manage assets amounting to no more than 63 bln tenge.

To encourage more active transfers of pension savings to private management, a shift to composite indices will be implemented when evaluating the performance of pension asset managers.

This approach will provide depositors with the option to choose an investment portfolio (conservative, moderate, risky) with varying levels of risk and return. Pension asset managers will independently develop investment strategies and set minimum return targets for them. The Agency, in turn, will define the minimum return requirements for benchmark portfolios for each investment strategy.

We expect that the adoption of these measures will not only increase the long-term return on pension assets managed by private managers but also have a positive impact on the raise of liquidity of the securities market.

- What other changes are expected in the financial sector in 2025? What can participants in the financial market expect?

- Firstly, one of the key tasks for this year is the development of a new law on banks, as instructed by the Head of State. Currently, with the participation of relevant government bodies, financial sector participants, and experts, discussions are underway on the key approaches to drafting the new law.

The new law must reflect modern realities and contribute to the dynamic development of the banking sector, as well as increase its potential in financing the economy.

A key approach in developing the new law will be creating conditions for the development of the fintech sector and the safe implementation of innovations in the banking sphere. This will include expanding the ability of banks to participate in the capital of fintech companies and simplifying access to the «regulatory sandbox». It will also establish the principles for the functioning of the National Digital Financial Infrastructure. As part of the associated laws on payments, payment systems, and digital assets, regulation of the circulation of digital financial assets will be introduced.

As part of improving banking regulation, a review of excessive regulatory norms will be conducted. There are plans to establish uniform requirements for the approval of senior management, major shareholders, and other requirements across all financial market sectors, including banking, insurance, and securities, as part of the law on state regulation of the financial market.

To enhance competition in the banking sector and create conditions for the growth of SME lending, based on international experience, the introduction of a basic and universal banking license will be considered. Differentiated regulation will be applied, enabling new banks to emerge by allowing large and stable microfinance organizations to transition to the banking sector.

To develop Islamic finance, it is planned to allow traditional banks, under a single license, to conduct Islamic financing activities. This will attract financial institutions and investments from the Middle East.

To increase the resilience of the banking system, in line with IMF recommendations following the FSAP (Financial Sector Assessment Program), the system for resolving insolvent banks will be reformed, including state involvement in the resolution of insolvent banks and interagency coordination.

One of the Agency's priorities is also to enhance competition in the banking sector. Legislative amendments have been prepared to liberalize requirements for foreign banks to open subsidiaries and branches. This will include reducing the list of required documents and expanding the list of permitted operations for branches.

Additionally, this year, legislative amendments are planned to clarify the functions and responsibilities of the National Bank and the Agency in the area of macroprudential policy.

Secondly, to adapt to the development of the fintech sector and improve behavioral supervision, the Agency will review the legal framework for the existing consumer protection system. The new approach will balance the interests of banks, consumers, and the state based on the responsibility of all parties involved.

To this end, the Agency will strengthen requirements for adhering to strict standards of quality for financial products and services at all stages of interaction. To protect consumer data and assets, the Agency will ensure transparent agreements on responsibility between banks and consumers in cases of consumer harm. On the one hand, responsible banks will not benefit from their mistakes in risk management and internal control systems and will be required to compensate for the damage. On the other hand, consumers will also be held accountable for fulfilling their obligations and for gross negligence leading to harm. This approach will establish a fair balance of duties and responsibilities between the parties.

Furthermore, requirements for an independent and fair complaints and dispute resolution function at the bank level will be strengthened, with the authority to make decisions on compensation based on the bank's internal investigation. If consumers disagree with the bank's decision, they will have the right to appeal to an independent and financially stable financial ombudsman’s office, which will ensure fairness in the financial market as the main mechanism for out-of-court dispute resolution. The establishment of such a mechanism will reduce the burden on the judicial system and improve the quality of regulation and the further development of the financial market by assessing behavior at the sectoral level, within individual financial organizations, and by events from the perspective of the Agency.

Thirdly, one of the most important directions will be digitalization. It is important to note that over the past five years, the financial market has changed significantly: banks are actively implementing digital technologies, moving services to online formats, and automating internal processes. This has led to the appearance of a large amount of new data, the volume of which is growing exponentially.

Digital products have become the standard in banking services. Along with new opportunities, new types of risks have emerged, and the need to process even more data. These changes require us to transform into a digital financial regulator.

It is important to emphasize that digitalization does not replace traditional supervisory tools but makes them more effective and complements them with new possibilities. Modern technologies allow for the automation of data collection and analysis, speeding up risk identification processes, and improving regulatory compliance monitoring. Currently, the Agency is actively implementing not only classic digitalization tools but also process automation, robotics, and elements of artificial intelligence.

This approach forms the foundation for the development of SupTech within the financial regulator. A key SupTech project is the creation of a Unified Supervisory Platform (USP), which will cover the entire cycle of supervisory activities, including licensing, prudential and behavioral supervision, as well as the fight against financial fraud. At the same time, we aim to reduce the time needed to identify risks and move towards a model of supervision with minimal time lag for more responsive action.

Overall, the implementation of these tasks will enhance the Agency's supervisory activities, provide new opportunities for the development of the financial market, and strengthen the protection of financial services consumers' rights.

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Article by Dauren Salimbayev, Deputy Chairman of the Agency for Regulation and Development of the Financial Market

Since early 2025, extensive and systematic work has been carried out to develop a new Banking Law. This is one of the most significant legislative packages prepared in the financial sector for the past decade.

The law has been developed at the instruction of the Head of State and is a result of a thorough review of the current banking regulations. Approaches to regulation, supervision, licensing, consumer protection, particularly for credit products and ensuring bank stability have been revised. The document rests on best international practices, including recommendations from the International Monetary Fund, as well as experience of leading countries –the United Kingdom, the United Arab Emirates, Malaysia and the European Union.

From January to May 2025, over 30 working meetings, discussions and open consultations were held with participation of banks, experts and international consultants. All key provisions of the draft were openly discussed with detailed feedback from the market. As a result, we have developed a comprehensive, logically structured law covering the entire lifecycle of a bank – from obtaining a license and commencing operations to terminating operations and regulation of insolvency. The law includes 135 articles, 9 sections and dozens of related amendments to other legislative acts. Essentially, it creates a new legal framework for sustainable and technologically advanced financial sector.

One of the central areas is the issue of digitalization. Today, digital technologies are no longer just a tool but a foundation of the banking system. That is why the new Law introduces, for the first time, a legal regime for digital financial assets (DFAs) – the so-called tokenized financial instruments. Three types of DFAs are envisaged: stablecoins backed by money; secured digital assets issued against a specific underlying asset; and digital financial instruments – stocks, bonds and other securities in token format. Such assets are considered financial instruments and are regulated in the same way as traditional ones, with mandatory platform registration, oversight of operations, internal control requirements, information disclosure and investor protection.

To create a sustainable, technologically neutral and competitive financial environment, the National Bank will establish technical standards for operation of digital platforms and infrastructure. The National Bank will also regulate issue and circulation of stablecoins and oversee their integration into a unified legal system. The Agency, in turn, will focus on the investment side of the market, regulating issue and circulation of digital securities and other financial instruments, establishing requirements for issuers, monitoring information disclosure and ensuring investor protection. Together, both bodies will determine operating rules for key infrastructure – platforms, registrars, and exchanges – to enable development of a transparent and secure digital asset market.

Legal status of the digital tenge is also fixed as a new form of national currency that can be used in the digital environment – through mobile apps, internet services and other technologies. It will become an important element of the fast and secure payment system. Furthermore, it is proposed to tighten requirements for payment institutions. Specifically, these relate to registration of payment institutions and grounds for removal from the register of payment institutions.

Digitalization is impossible without updating the very model of access to the banking market. One of the key innovations of the new Law is introduction of a two-tier bank licensing system: basic and general licenses. This model allows for creation of a more flexible and competitive environment in which not only large banks but also new participants, including small regional banks and microfinance organizations, can develop. This is particularly important to stimulate financial inclusion, foster entrepreneurship and reduce territorial and digital gaps in banking services.

Basic license is intended for small banks focused on a limited range of operations. Such organizations are subject to simplified minimum capital requirements and restrictions on types of activities. Specifically, lending to affiliates and non-residents is prohibited, volume of risky investments and large transactions is limited, and a limit is set on deposits from individuals. These restrictions help mitigate potential risks without overburdening participants with excessive regulatory burdens.

However, availability of a basic license does not exempt such banks from supervisory requirements. They will undergo regular inspections, including a sustainability assessment procedure under the SREP (Supervisory Review and Evaluation) supervisory model. It is a comprehensive methodology to assess bank's stability that encompasses corporate governance, capital adequacy and other indicators. Thus, reliability and integrity of new participants will be ensured on par with universal banks, but with due consideration for the scale of their operations.

General license is retained for existing large banks and allows for a full range of operations, from traditional lending to investment banking. This approach, on the one hand, increases competition and attracts new players, and on the other, maintains stability of the system and differentiates requirements depending on the nature and volume of operations.

Creation of conditions for occurrence of small but stable banks is an important step toward increasing the financial inclusion, emergence of new business models, including digital ones and overall improvement of the competitive environment. In the long term, this will allow clients, both individuals and SMEs, to receive a wider choice of banking products, including with the use of innovative technologies.

The next major focus area was implementation of behavioral supervision. We have shifted from an approach where supervision was limited to financial indicators to a model where client protection is the key priority. The new law introduces requirements for honest advertising, disclosure of product terms, prohibition of solicitation and assessment of service suitability. Financial institutions have to verify suitability of a particular product for a particular individual. Responsible lending standards are being introduced to prevent excessive debt burdens, especially among vulnerable groups.

The complaint handling system is structured in two stages: first, complaint is reviewed by the service provider itself, then by a unified financial ombudsman service. This institution will combine all existing ombudsman functions and will become primary pre-trial mechanism for resolution of disputes between clients and financial institutions. We have also established the obligation of banks and microfinance organizations to implement initiatives to improve financial literacy. This is especially important against the background of digitalization and emergence of new complex products – clients must understand their choices.

Considerable attention has been paid to resilience of banks and their preparedness for potential crises. The law includes a three-stage anti-crisis regulation system: enhanced supervision, recovery mode and regulation mode. Banks are required to develop recovery plans in advance in case of deterioration in their financial condition. If the situation continues to deteriorate, the regulation mode is initiated. At this stage, a temporary administration is appointed, bank's viability is assessed, and, if necessary, special measures are implemented: from transfer of some or all assets and liabilities to another financial institution to creation of a transition bank or write-off of debt to shareholders and investors.

The law provides for specific regulation instruments consistent with the international practice. These first of all include write-off or conversion of capital and debt obligations, sale of businesses, transfer of assets, creation of a temporary organization (bridge bank), and separation of bank functions into \"good\" and \"problem\" assets (asset separation). Such measures ensure continuity of critical services, protect interests of depositors and maintain confidence in the financial system.

Backbone banks are required to establish a safety margin – the TLAC (Total Loss Absorbing Capacity) mechanism. This means that the bank must have sufficient capital and debt instruments prepared in advance for possible write-offs or conversion to equity in case of significant losses. Thus, losses are first of all covered by shareholders and investors without resorting to budgetary funds.

Direct government participation in regulation is now possible only in the most extreme cases – if the use of all market instruments has proven insufficient, and the bank poses a systemic risk to the country's financial stability. Even in such cases, government assistance is permitted only under strict conditions: transparency of decisions must be ensured, minimal intervention in market mechanisms, and mandatory compliance with the NCWO (No Creditor Worse Off) principle. This means that no creditor must suffer losses during the regulation process greater than they would have suffered under a standard bankruptcy procedure. This eliminates the possibility of arbitrary redistribution of losses and guarantees protection of rights of bona fide creditors.

The new system completely eliminates automatic or politically motivated provision of the state aid. The approach to regulation has become predictable, economically justified and fair. This fundamental change is designed to eliminate moral hazard, increase responsibility of bank owners and protect interests of depositors and taxpayers.

We have also strengthened corporate governance requirements, as bank’s stability and protection of client interests depend on quality of management decisions. The new law establishes clear standards for all levels of management, from shareholders to specialized functions within the bank.

Heads of risk management, internal control and compliance departments are now officially recognized as key management personnel. This means that they are subject to the same strict requirements as members of the management board: experience, relevant education, business reputation and transparent professional history. Their independence and powers are fixed at the legislative level, allowing these functions to effectively influence decision-making and prevent violations at an early stage.

Requirements for composition of boards of directors have also been tightened. Members of the board of directors, especially independent ones, must meet a number of criteria, including lack of affiliation with the bank, business reputation and qualifications. Term limits are being introduced to prevent excessive closeness to management and maintain an independent view. Annual verification of compliance with independence criteria will become mandatory, both by the bank itself and with the possibility of subsequent assessment by the regulator. This is necessary to ensure that boards of directors truly perform an oversight function, rather than merely formally approve decisions.

Additionally, the law expands regulator's tools of reasoned judgment. This means that the authorized agency will be able to assess not only formal but also factual circumstances – for example, actual independence of a board member or a shareholder's influence on operations, even if all regulations are met on paper. This approach will help identify potential conflicts of interest and mitigate risks of abuse.

To improve efficiency of asset management, a limit has been set for a period during which recovered assets can remain on a bank's balance sheet – no more than three years. This is important to prevent banks from turning into the so-called \"real estate holdings\" or \"factory owners,\" and to focus on their core business – financial intermediation. This requirement will encourage rapid realization of collateral, return of assets to the real economy and reduction of non-core risks.

Finally, an important part of the new law is development of the Islamic finance. A flexible \"Islamic windows\" model is being introduced, allowing traditional banks to provide Islamic services within their existing license without establishment of a separate structure. All such operations will be conducted separately, with separate accounting, internal barriers, and mandatory presence of a Shariah compliance council. This will ensure compliance with the principles of the Islamic law while integrating such services into the existing banking system.

This model is already being successfully applied in countries with developed Islamic markets, including the UAE, Malaysia and Pakistan. It makes Islamic products more accessible, reduces costs for banks and opens up new opportunities for clients who prefer ethical or religiously oriented products, as well as for attracting investment from Islamic countries. Introduction of this model will be an important step toward development of an inclusive and diversified financial system in Kazakhstan.

All these innovations are more than just regulatory updates. They represent a comprehensive legislative reform that opens a new chapter in development of the banking sector. The new Banking Law is a systemic document that zeroes in on sustainability, fairness, technological advancement and protection of interests of consumers of financial services.

It is the result of joint and transparent efforts of the government, market participants and the expert community. The law establishes clear and predictable rules of the game, enhances confidence in the financial system, increases responsibility of all its participants and creates foundation for its sustainable, competitive and inclusive development.

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Interview for Forbes.kz.

The new Law on Banks and Banking Activities introduces a modern system for regulation of insolvent banks that complies with international standards and takes into account national characteristics of Kazakhstan's financial market. This reform is designed to protect interests of depositors, reduce systemic risks and minimize use of budgetary funds in crisis situations.

Timur Abilkassymov, First Deputy Chairman of the Agency for Regulation and Development of the Financial Market, explains what the new regulation mechanism will be, how it will work in practice, and why it is important for long-term stability of the country's financial sector.

– Timur Bokeikhanovich, Kazakhstan has experienced several cases of troubled banks in the past. How will the new law help prevent recurrence of such situations?

– In the past, our financial system faced situations where individual banks lost their stability and became insolvent. To maintain market stability, the state was forced to allocate budgetary funds to support them. I believe this approach was a temporary measure, and I am confident that responsibility for mistakes of bank owners and management should not be shifted to the society. The new law fixes a different principle. Primary strain of bank's recovery is put on its shareholders, creating a fairer and more sustainable model.

To ensure operation of these principles in practice, the law improves the early response system. This means the regulator has more tools to work with the bank even at the stage of initial challenges. If indicators begin to deteriorate, supervision is enhanced and the bank is obligated to take measures to rectify the situation. Each bank is required to have a recovery plan agreed upon with the regulator, clearly outlining the measures which its shareholders and management will take to improve financial stability. If they default on their obligations to restore stability, a regulation mechanism will be kicked off to protect interests of depositors. In other words, the new law fixes the principle that shareholders bear primary responsibility for recovery of a bank. This mechanism mitigates the risk of sudden crises and increases predictability for the entire market.

– You have mentioned enhancement of shareholder responsibility. How does the new law strengthen responsibility of bank shareholders and management?

– In my opinion, the key change is in the philosophy of the approach itself. While previously, when problems arose, the main strain was put on the state, now shareholders must change their approach to potential crises. They must not only maintain capitalization, but also constantly confirm their readiness to maintain stability under any circumstances. This means that shareholders must have a realistic financial and management action plan, rather than limiting themselves to formal promises.

For large, backbone banks, we have reinforced capital requirements. This is what is known as the loss-absorbing capacity or TLAC. To put it more simply, such banks must have a safety margin that will allow them to survive tough time without government assistance.

We have also significantly revised our approach to corporate governance. From members of the board of directors, we now expect less formal participation and more genuine engagement and professionalism. It is important that the board be comprised of independent and competent people who know how to ask tough questions and make informed decisions. Additional requirements to the senior management as regards their experience, qualifications and risk awareness have also been established.

I would like to specifically mention supervisory practices. We are expanding the use of motivated judgment as a key tool in risk-based supervision. This approach will make supervision more meaningful and focused on problem prevention.

Taken together, these measures create a more mature system in which each participant understands his responsibilities, and key decisions are made given actual risks and interests of depositors.

– One of the most discussed elements of the law is the mechanism for collective bank contributions to a fund to be used in regulation of backbone banks. Market participants fear that this could serve as an \"insurance policy\" for unscrupulous owners. Why was it necessary to create such fund?

– It's important to understand that we're not talking about establishment of a new fund in the traditional sense. The idea is completely different. We want to establish a mechanism whereby banks contribute to covering the losses only if the state incurs actual losses during the regulation process.

This is necessary to establish a transparent and fair procedure in case of a crisis. Previously, such situations were regulated on an one-off basis, often with the use of the budget. Now the state only intervenes in relation to backbone banks and only in exceptional circumstances. The remaining banks will have to rely on themselves and their shareholders.

If losses arise during regulation of backbone banks, they are compensated by the market, that is, by the banks themselves, proportionally to their shareholding. In practice, such scenario is extremely unlikely because the new law rests on the principles of early response, enhanced capital requirements and shareholder responsibility. All these make a situation in which the country's budget suffers losses extremely unlikely.

Along with that, it is important to understand that such mechanism allows for maintaining a balance between sustainability and development. To cover all risks, it would be possible to continually increase capital and liquidity requirements, but this would entail excessively stringent regulation and restrict lending. For example, to support lending to small and medium-sized businesses, we have now introduced a reduced risk-weighting of assets, although calculations indicated the need for an increase. Such decisions may be possible precisely because in the future a mechanism will be in place that allows the system to compensate for risks without the use of budget funds. This creates space for more flexible regulatory policy.

– Is this approach to bank regulation unique to us, or are there similar mechanisms worldwide? What international practices have you relied on when developing the law, and what have you taken into account from your own experience in previous years?

– This approach is not unique. Similar mechanisms are in place in many countries, for example, the European Union, the United Kingdom, South Korea, Canada and other jurisdictions. They rest on common international principles fixed in G20 and Basel Committee documents.

For several years, we have consulted with international experts, including representatives of the IMF, ECB, World Bank, EBRD and national regulators who have undergone similar reforms. We also closely studied our own experience and bank regulation cases in recent years with international experts. Combined efforts have helped us determine which elements of the international models are truly applicable in Kazakhstan and which require adaptation to our market structure and the scale of our banking system. As a result, the new regulation mechanism combines best international practices and lessons learned from our experience.

Overall, the new law reflects our vision for consistent development and enhancement of the financial sector. International organizations and rating agencies agree that quality of banking supervision in Kazakhstan has significantly improved in recent years. This suggests that the banking system is ready to enter a new stage of development and become even more efficient, open to innovation, and, most importantly, resilient. Therefore, it is important to consolidate the achieved progress and move on to the next stage – development of a modern regulatory system that combines sustainability, development and trust.

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Address	21, Koktem-3 Microdistrict, Almaty, Kazakhstan
Call center	1459 (free call within Kazakhstan from all mobile operators) +7 727 237 1000 Working Hours: Monday–Friday, 09:00–18:30
General Office (Registry)	+7 727 237 1241
General Email	info@finreg.kz (not for inquiries)
Human Resources Department	+ 7 727 237 1234
For Public Inquiries	https://eotinish.kz
Press Service	+ 7 727 237 1089
Media Inquiries	press@finreg.kz
Reports on Corruption	+ 7 727 237 14 43 antifraud@finreg.kz

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