REGULATORY LICENSING · KAZAKHSTAN

Architectural Design Licensing in Kazakhstan

Design organisation licences, engineering surveys, State Expert Examination, and author's supervision obligations under Kazakhstan law.

Kazakhstan separates the regulated design function from construction activity. An architectural or engineering design organisation must hold its own licence before it may prepare project documentation for submission, and it remains legally responsible for that documentation throughout the construction cycle — including an obligation to supervise the works against the approved design. This article sets out the licensing framework, qualification requirements, and procedural steps relevant to both domestic and foreign design firms operating in Kazakhstan.

Legal Framework

Architectural and design activity in Kazakhstan is regulated primarily by the Construction Code (No. 253-VIII of 9 January 2026), in force since 1 July 2026, which replaced the Law on Architectural, Urban Planning and Construction Activities (No. 242 of 16 July 2001), and the Law on Permits and Notifications (No. 202-V of 16 May 2014). The list of licensed sub-activities is in Annex 1 to the Law on Permits and Notifications, and the qualification criteria for design organisations are set by Order No. 197 of the Acting Minister of Industry and Construction of 22 April 2026. Urban planning norms, construction rules, and technical regulations applicable to project documentation are adopted by the same ministry and updated periodically; compliance is verified at the State Expert Examination stage.

Activities That Require a Licence

Annex 1 to the Law on Permits and Notifications provides two licences in this field: a design licence (item 5) and a separate survey licence (item 4). The principal activities are:

Licensed activities

Architectural design — preparation of architectural and structural sections of project documentation for buildings and structures of all functional types and responsibility levels. This covers concept design, detailed design, and working documentation.

Engineering surveys — geodetic, geological and hydrogeological work required to establish site conditions before and during design work. This work needs the survey licence, not the design licence. Survey results form a mandatory input to project documentation submitted for State Expert Examination.

Urban planning activity — preparation of urban planning documentation, master plans, detailed planning schemes, and territorial planning documents. This work falls under the design licence and is mainly relevant to firms working for municipal authorities and major development sponsors.

A single design licence may cover multiple design sub-activities provided the applicant demonstrates the required qualified personnel and technical capacity for each. EPC contractors who wish to perform design work in-house must obtain a design licence separately from their construction licence; the two are not interchangeable.

Licence Categories and Complexity Levels

As with construction licences, design licences are issued in categories that correspond to the complexity and responsibility level of the facilities for which the design organisation may prepare documentation. Category I authorises work on facilities of all responsibility levels, including technically complex, unique, and critical infrastructure projects. Category II covers facilities of second and third responsibility levels, and first-level facilities only under subcontract, while Category III covers third-level facilities, and first and second-level facilities only under subcontract (Article 55 of the Construction Code). A design firm must hold a licence of the appropriate category for the project it is engaged on; underqualified design activity is a regulatory violation regardless of whether the resulting documentation appears technically adequate.

Qualification and Staffing Requirements

The minimum staffing requirement for a design licence under Order No. 197 is at least one attested engineering and technical worker in the relevant design discipline, employed on a permanent basis as chief project engineer, chief project architect, chief designer or lead design engineer. Attestation is carried out by accredited attestation centres; from 1 July 2028 it is replaced by certification. The applicant must also have office premises with workplaces and the software needed for the work. Category II additionally requires at least five years of licensed experience and at least five completed second or third-level projects as general contractor, or ten first or second-level projects as subcontractor. Category I requires at least ten years of licensed experience (seven for offshore oil and gas projects, or five as a Category II licensee) and at least ten completed first or second-level projects as general contractor, or twenty as subcontractor. For foreign applicants, an equivalent foreign licence counts towards experience. Foreign design firms should identify their attested specialists in the licence application. The requirement is for attested staff employed on a permanent basis, so specialists working for the group abroad should not be assumed to meet it.

Licensing Procedure

Applications for design licences are submitted electronically through the government e-services portal to the licensing authority: the local executive body of the capital, region or city of republican significance that carries out state architectural and construction control and supervision (Article 55 of the Construction Code). The licence or a reasoned refusal must be issued within 15 working days (Article 30 of the Law on Permits and Notifications). The application comprises the application form, proof of payment of the licence fee, and the forms evidencing compliance with the qualification requirements: attested specialists, premises, software and, for Categories I and II, experience and completed projects. The design licence is a first-category permit under the Law on Permits and Notifications, a term not to be confused with the licence's own Categories I to III, so there is no notification route. The licensing authority assigns the licence category when it issues the licence. Allow four to eight weeks for preparation of the full application package, in particular for the identification and engagement of attested personnel where the firm does not yet have a local team in place.

State Expert Examination of Project Documentation

Project documentation prepared by the design organisation must pass comprehensive non-departmental expert examination, still commonly called the State Expert Examination, before the project can be approved and built (Article 105 of the Construction Code). The examination is an integrated technical, legal, and cost review conducted by the state expert organisation or, for projects outside its monopoly, an accredited expert organisation. It covers all sections of the project documentation — architectural and structural, fire safety, engineering systems, environmental compliance, and cost estimate — against applicable technical regulations, construction norms, and sanitary standards. The examination is mandatory, and cannot be waived by agreement of the parties, for all projects except the simple third-level facilities listed in Article 98(4) of the Construction Code. The test is the facility's responsibility level and source of financing, not its cost or floor area: the state expert organisation handles first and second-level projects and state-funded new third-level buildings (Article 104), and accredited expert organisations handle privately financed third-level projects (Article 109). Where a project has no state investment, the customer may choose not to have the cost estimate examined.

Key examination parameters

Maximum review periods: 30 working days for third-level facilities; 45 working days for first and second-level facilities (Order No. 240 of the Minister of Industry and Construction of 15 May 2026). The periods run from the start of the examination work and include the customer's time to answer comments.

Unique and national facilities: Up to 60 working days for unique facilities and facilities of national or interstate significance.

Outcome: A positive expert conclusion is a prerequisite for approval of the project and the start of works. A negative conclusion must be addressed by the design organisation and the documentation resubmitted; additional review fees and time apply.

Responsibility: The design organisation bears primary regulatory and civil liability for errors and omissions in project documentation that are not identified at the examination stage but cause harm or delay during construction.

Where the project involves a potentially significant environmental impact, an environmental impact assessment must be completed and its conclusions integrated into the project documentation before it is submitted for State Expert Examination. Bond Stone coordinates both the environmental and technical examination processes for clients on major infrastructure and industrial projects.

Author's Supervision

The design organisation's responsibility does not end with the positive expert conclusion. Article 53 of the Construction Code makes author's supervision mandatory throughout the construction period on all facilities except the simple third-level facilities that the customer accepts itself. It is carried out by the project's author under a contract, funded from the design documentation budget. The author may delegate it to a certified specialist, or to the customer, who then selects a certified provider. In practice, author's supervision involves periodic site visits by the design organisation's representatives, review of construction works against the approved documentation, approval of any deviations or design changes, sign-off on hidden works before they are covered, and maintenance of a dedicated author's supervision journal. Where changes to approved project documentation become necessary during construction, the design organisation must prepare and submit amendment documentation for review, and, for material changes, a further State Expert Examination may be required before the amended works may proceed.

Foreign Design Firms and International Architects

Foreign architectural and engineering firms wishing to perform design work in Kazakhstan face a structured entry decision. The options are direct licensing — where the foreign entity applies for and holds a Kazakhstan design licence in its own name — or indirect participation through a locally incorporated entity (LLP). A branch cannot hold the licence itself: the foreign parent holds it. Direct licensing requires the foreign firm to demonstrate Kazakhstan-attested specialists in its application, which in practice means recruiting or seconding attested professionals locally. Indirect participation through a local subsidiary is more common for firms entering the market for the first time, as it allows the local entity to build a licensed team while the parent firm provides technical resources and oversight.

We found no simplified attestation route for specialists from CIS states in the Construction Code or Order No. 197, so any such route should be confirmed with the attestation centre. Foreign specialists should otherwise plan for attestation through an accredited attestation centre, and for certification from 1 July 2028. Foreign architects and engineers should allow several months for the process and should not assume that international professional registration — including RIBA, AIA, or European equivalents — confers any right to practise in Kazakhstan without local validation.

Urban Planning Approvals and the Architectural Planning Task

Before detailed architectural design work begins on a major project, the developer typically obtains an architectural planning task, a document that sets the permitted parameters for development on the specific site, including height, footprint, setbacks, permitted uses, and urban planning requirements. This document is issued by the local urban planning authority and provides the mandatory baseline within which the design organisation must work. Designs that deviate from the parameters in the architectural planning task should be expected to fail State Expert Examination. For large-scale mixed-use or industrial development, a detailed planning scheme for the relevant zone may need to be amended before the architectural planning task can be issued, adding a preliminary public consultation and approval stage to the project timeline.

Sanctions for Unlicensed Design Activity

Performing design activity without the required licence or in excess of a licence's scope is an administrative violation under the Code of Administrative Offences of the Republic of Kazakhstan. Sanctions can include administrative fines, and the construction control authority may suspend or prohibit the activity (Article 50 of the Construction Code). Where unlicensed design work results in harm during construction or operation of the facility, the design organisation may face civil liability claims from the developer, contractor, and third parties. The design organisation's licence is part of the file for State Expert Examination (Order No. 240), so documentation from an unlicensed organisation cannot be expected to pass that stage. The resulting delay can cost far more than licensing at the outset.

Frequently Asked Questions

Does a foreign architectural or design firm need a Kazakhstan licence?

Yes. Any organisation preparing architectural project documentation or performing engineering surveys for construction projects in Kazakhstan must hold the relevant licence: a design licence for project documentation, or a survey licence for engineering surveys. Foreign firms may hold the licence directly or operate through a locally incorporated entity. The design organisation's licence is part of the file for State Expert Examination.

What is covered by the State Expert Examination of project documentation?

The State Expert Examination reviews complete project documentation — architectural, structural, engineering systems, fire safety, environmental, and cost estimate sections — for compliance with technical regulations, construction norms, sanitary standards, and urban planning requirements. The examination is mandatory before the project can be approved and built, except for the simple third-level facilities listed in Article 98(4) of the Construction Code. The maximum review period is 30 working days for third-level facilities, 45 for first and second-level facilities, and 60 for unique or nationally significant facilities.

What is the author's supervision obligation?

The design organisation must monitor compliance with the approved design throughout construction, verify and sign off on hidden works before they are covered, approve any deviations, and maintain a site supervision journal. It is mandatory under Article 53 of the Construction Code and is performed under a contract; the author may delegate it to a certified specialist, or to the customer, who then selects a certified provider.

How long does it take to obtain an architectural design licence?

The statutory processing period is 15 working days from submission of a complete application. In practice, preparation of documentation — including confirmation of attested specialists, premises, and technical resources — typically takes four to eight weeks. Applications are submitted through the government e-services portal.

Can an EPC contractor perform design work under its construction licence?

No. Design and construction need separate licences in Kazakhstan. An EPC contractor must either hold a separate design licence, engage a licensed design subcontractor, or establish a separately licensed design entity. This is a common structuring issue for international EPC contractors and should be addressed before project mobilisation.

Experience

Bond Stone has advised design organisations, EPC contractors, and international architectural practices on licensing and regulatory compliance in Kazakhstan since 2007. Client confidentiality is maintained across all matters.

Design Licence — Chinese EPC Contractor

Advising a Chinese EPC contractor on the design licence requirement for a major industrial facility — structuring a compliant design subcontract with a licensed Kazakhstani design organisation and managing State Expert Examination timelines.

Architectural Planning Task — Mixed-use Development

Advising a Gulf-based developer on the architectural planning task requirement and local executive authority approval procedure for a mixed-use development in Almaty — coordinating between the licensed design firm and local regulatory authorities.

Author's Supervision Dispute — Infrastructure Project

Acting for a foreign design firm in a dispute over scope and fees for author's supervision services on a state-funded infrastructure project — analysis of statutory obligations under the Architecture Law and the design contract, and preparation of a claim.

Foreign Design Firm — Market Entry Structure

Advising a European architectural practice on market entry into Kazakhstan — analysis of licensing pathways, comparison of branch versus subsidiary structures, and design of a joint venture arrangement with a locally licensed design organisation.

State Expert Examination — Energy Facility

Advising the developer of a renewable energy facility on the State Expert Examination process for project documentation — scope of mandatory review, timeline, deficiency response procedure, and liaison with the authorised expert organisation.

Design Organisation Licence — Technology Park

Assisting a newly established design organisation in obtaining a first-category design licence for a technology park project — qualification assessment, specialist attestation, documentation preparation, and e-services submission.

Why Bond Stone

18+ years advising international businesses on regulatory licensing in Kazakhstan

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