LEGAL GUIDE · 2026 EDITION
AIFC Legal Guide
Astana International Financial Centre — 2026 Edition
The AIFC is a financial centre in Astana with its own law based on English common law, its own companies registry, a court whose justices include former senior judges of England and Wales, an arbitration centre, and activity-based exemptions from Kazakhstani CIT, VAT and IIT until 2066. By the end of 2025 it had 4,954 participants from 91 countries, USD 6 billion raised through the Centre in 2025, and USD 10.58 billion in digital asset transaction volume.
This guide is written for international investors, financial institutions, fintech companies, and legal counsel deciding whether and how to use the AIFC framework. It explains what the AIFC is, what it is not, what changed in 2025 and 2026, and what Bond Stone, whose partners hold AIFC Registered Legal Adviser status, can do.
Bond Stone AIFC practice — firm profile → · AIFC legal services →
AIFC — Key Facts 2026
4,954
Participants from 91 countries — end 2025
USD 6B
Raised through AIFC in 2025
2066
Tax exemption horizon — qualifying services and income only
4,600+
AIFC Court and IAC cases completed and enforced, as of 24 December 2025
The five decisions every AIFC participant faces
1. AIFC entity or Kazakhstan civil law entity?
An AIFC entity is governed by AIFC law, based on English common law, registered with the AIFC Registrar, subject to AFSA regulation (if providing financial services), and eligible for activity-based tax exemptions until 2066. A Kazakhstan civil law entity (LLP/JSC) is governed by Kazakhstani law and subject to standard Kazakhstani tax. Many international investors consider an AIFC holding layer, even for non-financial investments, for governance and dispute resolution reasons and for the exemption on dividends and gains. Whether it helps depends on the structure.
2. Which AIFC entity type?
AIFC Private Company (equivalent to English private limited company), AIFC Public Company, AIFC Limited Liability Partnership, AIFC Foundation (for private wealth and family office structures), or AIFC Branch (for foreign companies establishing a presence). Each has different governance requirements, capital rules, and AFSA licensing implications. Choice depends on activity, ownership structure, and intended use of the AIFC framework.
3. AFSA licence — which category?
Regulated financial services in or from the AIFC require an AFSA licence. The main areas are banking and credit, capital markets (brokerage, dealing, advisory, underwriting), investment management (fund and portfolio management), insurance, Islamic finance, payment services and digital assets. Each has its own capital, personnel, systems and compliance requirements. A firm that holds the wrong activity, or omits one it needs, is exposed to regulatory action.
4. FinTech Lab or full licence?
The AFSA FinTech Lab allows digital asset and fintech firms to test products and services within the AIFC regulatory framework before committing to full authorisation. 19 DASPs operated under FinTech Lab supervision in 2025. The Lab is a route to authorisation, not a substitute for it. Bond Stone advises on FinTech Lab entry and on migration to full authorisation.
5. AIFC Court or IAC arbitration?
The AIFC Court offers litigation in English before judges of international standing, led by a former Lord Chief Justice of England and Wales, with former Court of Appeal and High Court judges among its justices. The International Arbitration Centre (IAC), a separate institution, provides institutional arbitration under its own IAC Arbitration and Mediation Rules 2022, with awards enforceable under the New York Convention. AIFC Court judgments are enforced across Kazakhstan on the same terms as Kazakhstani court judgments, without re-litigation; the New York Convention does not cover them. The AIFC Court is not, at present, a route for awards made outside the AIFC: it so held in Posco (27 May 2026) and Naftogaz v Gazprom (7 July 2026), and the Court of Appeal's judgment was awaited at 6 November 2026. See AIFC Court proceedings. The choice between Court and IAC depends on the nature of the dispute, confidentiality requirements, enforcement needs, and counterparty jurisdiction. For AIFC-governed contracts, the Court is generally preferable for certainty and enforceability within Kazakhstan.
What changed in 2025–2026
AFSA regulatory amendments — effective 1 January 2026
AFSA introduced amendments to three core frameworks — capital markets, digital assets, and crowdfunding — effective 1 January 2026, following public consultation from 21 July to 15 September 2025. Participants and prospective participants should review their licences and activities against the amended frameworks.
4,954 participants — 25% growth in 2025
AFSA registered 1,467 new companies in 2025, 25% more than in 2024, bringing total AIFC participants to 4,954 from 91 countries, an average of 28 new registrations a week.
Digital assets — USD 10.58 billion transaction volume, first stablecoin licence
DASPs generated USD 10.58 billion in transaction volume in 2025 across a client base of 215,000 users. In June 2025 AFSA granted its first licence for fiat-backed stablecoin issuance. AFSA also joined IOSCO's I-SCAN fraud alert network.
AFSA Fees Rules amended from 1 December 2025
After a consultation from 2 October to 2 November 2025, AFSA amended the AIFC Fees Rules, mostly with effect from 1 December 2025, in what it calls a substantially broader revision affecting almost all fee categories. Application and fixed supervision fees rose, new variable fees apply to several activities, and variable fees are capped at USD 250,000 a year. From 1 January 2027, a firm with several activities pays the highest fixed fee plus 50% for each additional activity. Participants should update their 2027 operating budgets.
AFSA 2026 regulatory priorities
AFSA's published 2026 regulatory agenda includes: Appointed Representative Framework (new category allowing AFSA-licensed firms to appoint representatives); Derivatives Framework amendments; Asset Management Framework review (Call for Evidence launched); Multilateral and Organised Trading Facility amendments; and updates to Fitness and Propriety Guidance. Check each item against AFSA's current notices.
The AIFC framework — what you need to know
Legal system
AIFC Acts, such as the AIFC Contract Regulations and AIFC Companies Regulations, may be based on the law of England and Wales. The AIFC Court applies AIFC law and the law the parties agree, guided by its own decisions and those of other common law jurisdictions. Kazakhstani law applies to matters that the Constitutional Statute and AIFC Acts do not regulate.
AIFC legal services →Tax environment
AIFC participants are exempt from Kazakhstani CIT and VAT on qualifying AIFC services, and the foreign employees of such participants from IIT, until 1 January 2066. Dividends from, and gains on, shares of AIFC-registered companies are exempt for all recipients until the same date. Currency contract registration and notification do not apply to currency operations by participants in the AIFC.
AIFC tax residency programme →AIFC Court
Its justices include former senior judges of England and Wales. Judgments are enforced across Kazakhstan on the same terms as Kazakhstani court judgments, without re-litigation. By 24 December 2025 the Court and the IAC together had completed and enforced more than 4,600 cases since they began operating. Parties that are not AIFC participants can opt in by agreement.
AIFC Court proceedings →AFSA regulation
510 financial ecosystem entities at the end of 2025. Licences cover banking, capital markets, investment management, insurance, Islamic finance, payment services and digital assets. The FinTech Lab is the sandbox route. Amended frameworks for capital markets, digital assets and crowdfunding took effect on 1 January 2026, and amended Fees Rules on 1 December 2025.
AFSA licensing advisory →Who uses the AIFC
International investors using the AIFC as a holding structure for Kazakhstan and Central Asia investments. Fintech and digital asset companies seeking regulated market access in the CIS. Fund managers establishing investment vehicles. Banks and insurance companies establishing AIFC presence. Professional services firms (legal, accounting, consulting) serving the AIFC ecosystem. Chinese, Gulf, European and US companies entering Central Asia.
AIFC entity formation →What the AIFC is not
The AIFC does not replace Kazakhstan civil law for activities outside the AIFC territory. A company registered in the AIFC conducting business in Kazakhstan (outside the AIFC) remains subject to Kazakhstani law and taxes for those activities. The tax exemption applies to qualifying AIFC activities — not to all activities of an AIFC-registered entity. Correct structuring of the boundary between AIFC and Kazakhstan activities is essential.
AIFC compliance advisory →Bond Stone — AIFC Registered Legal Adviser
Bond Stone's partners hold AIFC Registered Legal Adviser status.
Registered Legal Adviser status is an individual registration with the AIFC Legal Services Board (AIFC Legal Services Regulations 2022, s 17). Appearing before the AIFC Court requires registration with the AIFC Court Registry. Bond Stone is ranked Legal 500 EMEA Top Tier and IFLR1000 Market Leader, and clients receive both Kazakhstani law and AIFC/English common law advice on a single mandate without coordinating separate counsel.
Bond Stone advises on AIFC entity formation, AFSA licensing across all categories, AIFC Court proceedings, AIFC regulatory compliance, and AIFC investment tax residency — from the Almaty and Astana offices, the latter adjacent to the AIFC.
AIFC legal services
Discuss your AIFC matter
Contact Bond Stone for a confidential discussion about AIFC entity formation, AFSA licensing, or AIFC Court proceedings.
info@bondstonelaw.com
+7 (701) 729 76 72 — Almaty
+7 702 808 11 58 — Astana (adjacent to AIFC)
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