The issue of compliance with public procurement legislation is one of the key areas of state audit and financial control. The practice of desk control shows that a significant portion of violations is related not only to the incorrect application of specific norms of the Republic of Kazakhstan's legislation on public procurement but also to insufficient development of tender documentation, incorrect choice of procurement method, and non-compliance with the principles of fair competition.
Desk control is conducted on an ongoing basis remotely, without visiting the state audit object, by comparing information from various sources, including data from the public procurement web portal and the risk management system. Its main goal is the timely identification and prevention of violations before the expenditure of budget funds.
As of May 20, 2026, the Department of Internal State Audit for the Zhambyl Region covered 15,021 public procurement procedures with desk control. In 1,407 cases, or 9.4% of the total volume, notifications to eliminate identified violations were sent to customers. Analysis of the control results shows the presence of a number of the most common violations.
One of the most frequent violations at the beginning of the financial year is the unjustified extension of contracts through the single-source method. In accordance with subparagraph 35) of paragraph 3 of Article 3 of the Law of the Republic of Kazakhstan "On Public Procurement," procurement from a single source is allowed for a period until the results of the main procurement are summed up and the contract comes into force, if there is a daily or weekly need of the customer. However, this norm is applied only in case of the previous year's supplier's refusal to extend the contract and exclusively within the first month of the year, or during the creation or reorganization of the customer.
Nevertheless, cases have been identified where such contracts were concluded in subsequent months of the financial year or without documents confirming the supplier's refusal to extend the contract.
Violations related to the splitting of procurement volumes remain widespread. When conducting procurement through the request for price quotations method, facts were established where the annual volume of homogeneous goods, works, or services exceeded the legally established threshold, but the procurements were artificially divided into parts to apply a more simplified method.
A significant number of violations are related to non-compliance with the procedure for centralized public procurement. When established threshold values are exceeded, procurements must be conducted through a single organizer. However, some customers carried out such procurements independently.
Facts of unjustified use of the single-source procurement method through direct contract conclusion were also identified. In some cases, this method was used when the permissible annual volume of homogeneous goods, works, and services was exceeded, despite the presence of similar procurements in the annual plan.
Violations in the development of tender documentation and technical specifications are systemic. During control, cases were identified where national or interstate standards for the procured goods, works, and services were not specified. Furthermore, some technical specifications did not contain descriptions of characteristics in the state language, which also violates legal requirements.
One of the most sensitive problems remains the establishment of qualification requirements that restrict the participation of potential suppliers. Some tender documentation included requirements for having offices and production facilities in a specific locality, labor requirements not stemming from the subject of the procurement, as well as having diplomas from foreign universities or professional retraining obtained exclusively outside the CIS countries. Such conditions create unjustified barriers and violate the principles of fair competition and equal opportunities.
Violations were also identified during the consideration of potential suppliers' comments in the preliminary discussion of tender documentation. In a number of cases, organizers provided formal explanations without actual analysis of the participants' arguments and proper legal justification for retaining controversial qualification requirements. There were also instances of references to norms of the 2015 Public Procurement Law, which is no longer in force.
Special attention during desk control is paid to compliance with legislation on permits and notifications. It has been established that when procuring services subject to licensing or requiring a notification procedure, customers did not set mandatory requirements for potential suppliers to have the relevant licenses or notifications.
Cases of violating the procedure for making changes to concluded public procurement contracts are not uncommon. Additional agreements to increase the contract amount were concluded without documents confirming an increase in the volume of work required, in the absence of local estimates, defect reports, and other supporting materials, which made it impossible to confirm the unchanged unit price of the works.
Control practice also shows the presence of violations when canceling public procurements after summarizing results and determining the winner. Procurements were canceled without proper documentary and legal justification. Cases of cancellation due to incorrect indication of technical characteristics have been recorded, which is not provided for by current legislation after the results are summarized.
It should be noted that failure to comply with notifications to eliminate violations identified as a result of desk control entails liability measures provided for by law. In accordance with paragraph 1 of Article 32 of the Law of the Republic of Kazakhstan "On State Audit and Financial Control," if a notification is not complied with within the established period, measures are taken to suspend expenditure operations on the accounts of state audit objects. Furthermore, officials are held administratively liable in accordance with part 3 of Article 462 of the Code of the Republic of Kazakhstan "On Administrative Offenses" for failure to comply with lawful demands and instructions of state control and supervision bodies. Based on materials from the Department of Internal State Audit for the Zhambyl Region, courts held 31 state audit objects administratively liable in 2026.
The identified violations indicate the need to strengthen the legal and methodological training of organizers and customers. Correct formation of tender documentation, ensuring equal conditions, and preventing restriction of competition are the most important conditions for effective and transparent expenditure of budget funds.
Desk control remains an effective tool for preventing violations, allowing for their timely elimination without conducting on-site inspections. Improving the quality of procedure organization will reduce the number of violations and ensure compliance with the principles of openness, legality, and efficiency in public procurement.