AIFC · AFSA LICENSING
AFSA Licensing in the AIFC — Complete Guide
This guide sets out the licences of the Astana Financial Services Authority (AFSA) in the Astana International Financial Centre: digital assets, payment services, investment management, banking, insurance, Islamic finance and capital markets. Our partners hold AIFC Registered Legal Adviser status.
AFSA is the independent regulator of financial services in the AIFC. Its 2025 Annual Report records 29 financial services firms authorised that year, with strong interest in fund management, brokerage and advisory services.
Governed by: AIFC Financial Services Framework Regulations; AIFC Conduct of Business Rules; AIFC AML, CTF and Sanctions Rules; AIFC Fees Rules (as amended from 1 December 2025); AIFC Rules on Digital Asset Activities (as amended with effect from 1 January 2026); AIFC Rules on Providing Money Services. Authority: afsa.aifc.kz
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Digital Assets (DASP · DATF · Stablecoin · STO) · Payment Services (MSP · EMI) · Investment Management · Banking & Credit · Insurance · Islamic Finance · Capital Markets
Licence Category Guides
Requirements common to all AFSA licence applications
- AIFC entity — AFSA licences are held by AIFC-registered entities, but the application can be filed before the entity exists. Registration with the AIFC Registrar of Companies comes after AFSA's In-Principle Approval and before the Licence: AFSA issues the Licence once the entity is registered and capitalised and the other conditions are met. AFSA recommends starting the Registrar process when the application is filed, and its FAQ says a company may not register first and seek authorisation later.
- Non-refundable application fees — AFSA does not refund application fees regardless of outcome. The application is not regarded as submitted until the fee is paid in full. AFSA issues an invoice upon receipt of the completed fee request form.
- Approved Individuals — Key personnel (CEO/SEO, Finance Officer, Compliance Officer, MLRO, Deputy MLRO) must be individually approved by AFSA, which assesses each one's fitness and propriety.
- AML/CTF framework — Every firm needs policies that comply with the AIFC AML, CTF and Sanctions Rules before the licence is granted.
- Multiple activities — fee discount — Where an applicant seeks more than one Regulated Activity, the highest fee applies in full and each additional activity is charged at 50%.
Digital Assets
According to AFSA's 2025 Annual Report, IOSCO recognised the AIFC in 2025 among the leading jurisdictions in implementing global standards for crypto and digital asset markets. AFSA supervised 9 Digital Asset Service Providers (DASPs) under the full framework and 19 within the FinTech Lab, with total transaction volume of USD 10.58 billion and about 215,000 users.
| Licence / Activity | Description | Min Capital |
|---|---|---|
| DASP — Digital Asset Service Provider | A firm licensed for one or more Regulated Activities in relation to Digital Assets: Dealing in Investments as Principal or Agent, Managing Investments, Managing a Collective Investment Scheme, Providing or Arranging Custody, Advising on Investments, Arranging Deals in Investments, or Providing Money Services. Covers brokers, custodians, and wallet service providers. Additional AFSA application fee: USD 2,800. | USD 10,000–250,000 depending on activity |
| DATF — Digital Asset Trading Facility | Regulated Activity of Operating a Digital Asset Trading Facility — a centralised digital asset exchange. Variable supervision fee capped at USD 250,000 a year from 1 December 2025. | Higher of USD 200,000 or 12 months' operating expenses |
| Stablecoin Issuer | Issuance of Fiat stablecoins and Commodity stablecoins — Digital Assets whose value purports to be determined by reference to a Fiat Currency or a Commodity. Licensed as Providing Money Services under Part 4 of the AIFC Rules on Digital Asset Activities. Reserve and white paper requirements apply; algorithmic stablecoins are prohibited. Framework effective 1 January 2024. | USD 200,000, plus ongoing capital of 2% of average outstanding stablecoins |
| STO — Security Token Offering | Issuance of security tokens — digital representations of shares, bonds, or fund units. Subject to AIFC prospectus and disclosure rules. Framework effective 1 January 2024. | Per underlying regulated activity |
| FinTech Lab | Regulatory sandbox. A FinTech Lab Licence has effect for 2 years and may be extended, case by case, on a reasoned report (AFSA Notice AFSA-F-NB-2024-0006). A participant that wishes to operate on a broader scale migrates to full authorisation and pays migration fees (FEES 8.1.3). AML/CTF obligations apply from the start. | Reduced — per AFSA FinTech Lab terms |
| AFSA Discontinuance | Voluntary surrender of an AFSA digital asset licence. Requires formal application, wind-down plan, client notification, and regulatory exit documentation. | N/A |
Payment Services
Payment services in the AIFC are regulated under the Providing Money Services activity, which covers money transmission, remittance, currency exchange and electronic money issuance.
| Licence / Activity | Description | Min Capital |
|---|---|---|
| MSP — Money Services Provider | Money transmission, remittance, currency exchange, and cross-border payment services. Primary AFSA vehicle for international remittance companies and payment platforms. | Higher of USD 50,000 or 10% of annual audited expenditure |
| EMI — Electronic Money Institution | Issuance of e-money stored electronically and issued on receipt of funds. Covers e-wallet providers, prepaid card issuers, and digital payment platforms. Client funds must be segregated. | As for MSP, or 1.5% of average daily outstanding e-money where issuance exceeds USD 3 million, if higher |
| Dual MSP + EMI | Combined money transmission and e-money issuance on one application. The second activity is charged at 50% of the standard single-activity fee. | Higher of the two individual requirements |
Investment Management
| Regulated Activity | Description | Min Capital |
|---|---|---|
| Managing Investments | Discretionary management of investment portfolios on behalf of clients. A Single Family Office acting only in that capacity is generally outside it (GEN 1.1.17). Liquid assets must equal at least 25% of annual operating expenditure at all times. | USD 150,000 |
| Managing a Collective Investment Scheme | Establishing, managing, or winding up a Collective Investment Scheme (fund). Covers Exempt Funds (professional investors) and Non-Exempt Funds (full disclosure). Base capital: USD 50,000–500,000 depending on fund type and nature. | USD 50,000–500,000 |
| Advising on Investments | Giving investment advice to clients on buying, selling, holding, subscribing for, or underwriting investments. Covers investment advisers and wealth managers. Additional digital asset fee of USD 2,800 if advice extends to digital assets. | USD 10,000 |
| Arranging Deals in Investments | Making arrangements for another person to buy, sell, subscribe for, or underwrite investments. Covers placement agents, fund distributors, and introducing brokers. | USD 10,000 |
| Dealing in Investments as Principal / Agent | Buying, selling, subscribing for, or underwriting investments as principal (own account) or agent (on behalf of clients). Covers broker-dealers and market makers. Capital adequacy calculated on a risk-adjusted basis. | USD 50,000 (agent, or matched principal); USD 500,000 (principal); plus risk-based requirements |
| Providing Custody / Arranging Custody | Safekeeping and administration of investments (including digital assets) on behalf of clients. Arranging custody means arranging for another authorised firm to provide custody. Frequently combined with Managing Investments or DASP licences. | USD 500,000 (Providing Custody; USD 250,000 for Digital Assets); USD 10,000 (Arranging Custody) |
| Providing Trust Services / Fund Administration | Trust services: acting as trustee or managing trust structures. Fund administration: providing back-office NAV calculation, accounting, transfer agency, and related services to funds. Frequently used by family offices and fund service providers. | USD 200,000 (Trust Services); USD 10,000 (Fund Administration) |
Banking & Credit
High capital requirements apply
Banking and credit licences need substantial capital and governance. Bond Stone advises on the licensing route and the application; these mandates usually also involve specialist prudential advisers.
| Regulated Activity | Description | Min Capital |
|---|---|---|
| Accepting Deposits | Accepting Deposits, which are lent on or used to finance the firm's activity. The core banking activity; Retail Clients may not be accepted as depositors. Subject to extensive prudential requirements, governance obligations, and ongoing AFSA supervision. | USD 10 million base capital |
| Providing Credit | Lending money or extending credit facilities to clients. Covers lending institutions and trade finance companies operating within the AIFC. | USD 2 million base capital |
| Advising / Arranging a Credit Facility | Advising clients on or making arrangements for credit facilities — including syndicated loans, trade finance structures, and debt capital market transactions. Lower capital requirement than direct lending. | USD 10,000 |
| Opening and Operating Bank Accounts | Opening and operating bank accounts. A firm authorised for this activity is a Bank (BBR 1.5), whatever else it does. | USD 10 million base capital |
Insurance
| Regulated Activity | Description |
|---|---|
| Effecting / Carrying on Contracts of Insurance | Underwriting and carrying on insurance contracts — the core insurer activity. Subject to the AIFC Insurance and Reinsurance Prudential Rules, including a USD 7 million Capital Floor for an AIFC-incorporated insurer. |
| Insurance Management | Performing underwriting or administration for an insurer or captive, and arranging its reinsurance. Capital is set by rule 3.2 of the AIFC Prudential Rules for Insurance Intermediaries and Insurance Managers. |
| Insurance Intermediation | Arranging insurance contracts between insurers and clients. Covers insurance brokers and agents operating within the AIFC. |
| Operating a Representative Office | A foreign regulated insurer may market services offered outside the AIFC through a representative office. The office needs its own AFSA Licence, may only market, and cannot hold any other Regulated Activity. |
Islamic Finance
Growing AIFC priority
The AIFC has made Islamic finance a strategic priority — establishing an international Islamic Finance Advisory Board with experts from the UAE, Saudi Arabia, Bahrain, Malaysia, Türkiye and Kazakhstan. A firm conducts Islamic finance under a specific Shari'ah licence condition, as an Islamic Financial Institution or through an Islamic Window, and needs a Shari'ah Supervisory Board of at least three members.
| Regulated Activity | Description |
|---|---|
| Islamic Banking Business | Financing or investing under Islamic Financial Contracts, funded by accepting funds or placements or by managing Unrestricted Profit Sharing Investment Accounts. Governed by the AIFC Islamic Finance Rules and Islamic Banking Business Prudential Rules. Base capital is USD 9 million from 1 November 2026 and USD 10 million from 1 May 2027 (AFSA Notice AFSA-Q-OA-2023-0007). |
| Providing Islamic Financing | Financing under any Islamic Financial Contract. An Islamic Financing Company may not manage Unrestricted Profit Sharing Investment Accounts. Base capital is USD 2 million, phased under AFSA Notice AFSA-Q-OA-2024-0019. |
| Managing a Restricted Profit Sharing Investment Account | Managing investment accounts where returns are based on profit-sharing (Mudaraba) arrangements rather than fixed interest. Shari'ah-compliant alternative to discretionary investment management. Base capital USD 200,000. |
| Takaful Business | Shari'ah-compliant insurance — participants contribute to a pool that provides mutual indemnity. The AIFC Takaful and Retakaful Prudential Rules cover Family and General Takaful, with a USD 7 million Capital Floor for an AIFC-incorporated Takaful Operator. |
Capital Markets
Trading venues and AIX listings
Operating an Exchange and Operating a Clearing House are Market Activities, regulated separately from Regulated Activities. Operating an MTF, an OTF, or a DATF is a Regulated Activity. The Astana International Exchange (AIX) is the AIFC's licensed exchange, hosting listings of bonds, equities, and green finance instruments.
| Regulated Activity | Description |
|---|---|
| Operating a Multilateral Trading Facility (MTF) | Operating a non-discretionary trading system that brings together multiple buyers and sellers of financial instruments. Alternative to a regulated exchange — used for OTC bond trading, equity trading, and alternative investment platforms. |
| Operating an Organised Trading Facility (OTF) | Discretionary trading system for non-equity instruments — bonds, structured finance instruments, and derivatives. OTF operators may exercise discretion in order execution within defined parameters. |
| Operating a Digital Asset Trading Facility (DATF) | See the Digital Assets section above. DATF is a Regulated Activity under Schedule 1 of the AIFC General Rules. |
Selected AFSA Licensing Experience
Bond Stone has advised on AFSA licensing mandates across digital assets, payment services, and investment management. Client confidentiality is maintained across all mandates.
DATF · AIFC · 2026
International Digital Asset Exchange — AFSA Licence Discontinuance
Full AFSA discontinuance mandate — AFSA liaison, wind-down plan, regulatory exit documentation, and post-discontinuance confirmation.
MSP + EMI · AFSA · 2026
International Investment Bank — Dual MSP + EMI Application
Dual payment services AFSA application — Money Services Provider and Electronic Money Institution combined mandate with full AML/CTF framework and Approved Individual registrations.
DASP · Multi-jurisdiction · 2026
Fintech Platform — Multi-jurisdiction AFSA Licensing
Multi-phase AIFC digital asset licensing mandate — AIFC entity structuring, AFSA application strategy, and cross-border regulatory advisory across multiple jurisdictions.
Why Bond Stone for AFSA Licensing
- AIFC RLA — eight specialisations including Digital Assets & Blockchain, Banking & Finance, and Regulatory & Compliance
- Active across all major licence categories — DASP, DATF, MSP, EMI, investment management, and discontinuance
- Licensing cost analysis based on the AIFC Fees Rules
- Entity formation and AFSA application on one mandate
- Ranked Legal 500 EMEA and IFLR1000 — offices in Almaty and Astana, with direct access to AFSA and the AIFC Registrar
Primary authority: afsa.aifc.kz · aifc.kz
Bond Stone Kazakhstan offices: Almaty · Astana
Discuss your AFSA licence
Contact Bond Stone for a confidential discussion about AFSA licensing, application preparation and compliance.
info@bondstonelaw.com
+7 (701) 729 76 72 — Almaty
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