Kazakhstan's digital services regime entered a new phase in early 2025. Amendments to the country's technology legislation introduced mandatory registration, localisation, and algorithmic accountability obligations for a broad range of technology companies operating in or targeting the Kazakhstani market. Companies that have not yet assessed their exposure risk enforcement action, suspension of access, and software liability claims under the updated rules.
Kazakhstan's digital services regulation now requires qualifying technology companies to register with the relevant state authority, appoint a local representative, and comply with data localisation and algorithmic accountability standards. The changes took effect progressively through 2025, with the principal compliance deadline set for the end of the second quarter of 2025. International companies providing digital services to Kazakhstani users – whether through platforms, applications, or AI-driven tools – are directly affected.
This alert identifies which business categories are caught by the new rules, the threshold criteria that trigger compliance obligations, and the five immediate actions that international companies should take now.
What changed – the regulatory development and effective date
Kazakhstan's information and communication technology legislation was amended to extend the reach of digital services obligations beyond domestic providers. The changes align, in part, with regulatory directions taken by other CIS jurisdictions and reflect the country's stated intention to build a structured digital economy.
The core amendments introduce three categories of obligation. First, technology licensing requirements now apply to companies offering digital services, including software-as-a-service products, marketplace platforms, and AI-driven applications. Second, digital services providers above defined user thresholds must appoint a local legal representative and maintain a registered point of contact within Kazakhstan. Third, algorithmic accountability rules require that automated decision-making systems affecting Kazakhstani users be documented and, in certain cases, subject to audit by the competent authority.
Localisation rules were also tightened. Personal data of Kazakhstani users must be stored on servers physically located within Kazakhstan. This obligation existed previously in a narrower form. The amendments extend it to a wider range of service categories, including fintech platforms, e-commerce operators, and AI-assisted services.
The amendments came into force in stages. Localisation and representative appointment obligations applied from the first quarter of 2025. Technology licensing requirements and algorithmic accountability documentation became enforceable from the second quarter of 2025. The effective compliance deadline for the full suite of obligations is 30 June 2025.
For companies with parallel operations in Russia, a separate alert covers digital services regulation developments in Russia and the compliance contrasts between the two CIS markets.
Who is affected – threshold criteria and business categories
The rules apply to both domestic and foreign technology companies. Foreign companies are caught if they actively direct digital services at users in Kazakhstan. Passive availability of a website or application is not sufficient to trigger obligations on its own. Active targeting – such as Kazakh-language interfaces, local currency pricing, or advertising directed at Kazakhstani users – is the primary threshold indicator.
The following business categories are directly affected:
- Social media platforms and content-sharing services with a material Kazakhstani user base
- E-commerce marketplaces facilitating transactions between Kazakhstani buyers and sellers
- Fintech and payment service providers processing transactions in the local currency
- Software-as-a-service companies providing tools to Kazakhstani businesses or consumers
- AI-driven services using automated decision-making that affects Kazakhstani users
A secondary threshold applies to user volume. Companies exceeding a defined number of monthly active users in Kazakhstan. a figure set by the relevant regulatory body and subject to periodic revision. face the full range of obligations. This includes representative appointment and algorithmic accountability documentation. Smaller operators may face a reduced set of requirements, but data localisation applies regardless of user volume once active targeting is established.
Companies providing AI Act compliance advisory services or operating AI-enabled tools should note that Kazakhstan's algorithmic accountability rules are distinct from the EU AI Act regime. Compliance with one does not substitute for compliance with the other. International companies managing multi-jurisdictional AI deployments must assess each market separately.
For companies requiring guidance on AI and technology law in Kazakhstan, the obligations described above form the core of a rapidly developing regulatory system that demands prompt attention.
To receive an expert assessment of your company's exposure under Kazakhstan's digital services rules, contact us at info@ferrazwhitmore.com.
What to do now – immediate actions and timeline
International technology companies should treat the 30 June 2025 deadline as the outer limit of a compliance window that has already narrowed. The following five actions should be initiated without delay.
1. Map your Kazakhstani user base and service scope. Determine whether your products or services actively target users in Kazakhstan. Review interface language settings, pricing structures, and marketing spend directed at the Kazakhstani market. This mapping exercise informs every subsequent step.
2. Audit data flows and storage infrastructure. Identify all categories of personal data collected from Kazakhstani users. Determine where that data is currently stored. If storage is outside Kazakhstan, begin the technical process of establishing local data residency or engage a certified local cloud provider. Data localisation under Kazakhstan's technology legislation is not discretionary once the threshold is met.
3. Appoint a local legal representative. The representative must be a legal entity or individual registered in Kazakhstan. They serve as the point of contact for the competent authority and bear defined responsibilities under the legislation. Selecting and onboarding a representative takes time. This step should begin immediately.
4. Document algorithmic decision-making systems. Compile technical and operational documentation for any automated systems that make or materially influence decisions affecting Kazakhstani users. This includes recommendation engines, credit scoring tools, content moderation systems, and AI-driven pricing algorithms. Algorithmic accountability requirements under the amendments demand that this documentation be available for regulatory review.
5. Review technology licensing status. Assess whether your software products or digital services require a technology licence under the updated rules. Software liability exposure increases materially for unlicensed operators. Where a licence is required, begin the application process now. Processing times at the relevant authority can extend several weeks.
Companies with intellectual property assets in Kazakhstan – including software, databases, and proprietary algorithms – should also review their registration and protection status. Our colleagues advising on intellectual property matters in Kazakhstan can assist with this parallel workstream.
A lawyer in Kazakhstan with experience in digital services compliance can help structure these workstreams efficiently. Engaging a law firm in Kazakhstan with cross-border technology experience reduces the risk of gaps between local regulatory requirements and international compliance programmes.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our practice covers AI and technology law, digital services regulation, and software liability matters across CIS markets, including Kazakhstan. The firm combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions for technology companies managing multi-jurisdictional compliance. Our CIS practice group includes practitioners with direct experience advising on Kazakhstani regulatory requirements, algorithmic accountability obligations, and technology licensing processes. We work with international entrepreneurs, technology businesses, and in-house legal teams who need results-oriented counsel in high-growth and emerging markets. To discuss your situation under Kazakhstan's digital services regime, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.