On 12 June 2026, the President of Kazakhstan signed Law No. 311-VIII of 12 June 2026 “On Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Anti-Corruption Issues” and Law No. 312-VIII of 12 June 2026 “On Amendments and Additions to the Criminal Code of the Republic of Kazakhstan, the Criminal Procedure Code of the Republic of Kazakhstan and the Code of the Republic of Kazakhstan on Administrative Offences on Anti-Corruption Issues”.
The amendments cover several key areas of anti-corruption regulation:
Conflict of Interest
One of the central elements of the new regulation is the improvement of mechanisms for identifying conflicts of interest. In particular, a new chapter is being introduced into the Labour Code on the specifics of managing HR processes in state institutions and quasi-public sector entities through the digital HR system “E-qyzmet”.
This system must contain data on the employee, the individual identification numbers of the employee’s spouse and close relatives, as well as, where available, the business identification numbers of organisations and the individual identification numbers of individual entrepreneurs for whom the employee previously worked. If the employee is unable to provide such information independently, the employer obtains it from digital systems for the purpose of identifying conflicts of interest.
At the same time, the law restructures the mechanisms for preventing and managing conflicts of interest. It introduces the concept of personal interest and establishes three types of conflict of interest: potential, actual and realised. A potential conflict is one in which personal interests may come into conflict with official powers; an actual conflict is one in which such a contradiction has already arisen; and a realised conflict is one in which, under such circumstances, contracts or transactions have been concluded, acts or other decisions have been adopted.
A response procedure is established for each case. A conflict of interest may be identified through declarations of personal interests, anti-corruption monitoring, corruption risk analysis, complaints, inspections, audits, judicial and administrative proceedings, as well as monitoring of the digital HR system. In the event of an actual conflict of interest, the official must report it no later than within 2 working days, while the authorised person or unit must prepare an opinion no later than within 3 working days. Measures to manage the conflict must be taken no later than within 10 working days. If the conflict cannot be managed, transfer to another position or dismissal is provided for.
In addition, certain categories of officials are expressly required to take measures to prevent and manage conflicts of interest, and to immediately inform management and/or authorised state bodies of any known cases of corruption offences being prepared, committed or already committed.
Other Anti-Corruption Standards
The amendments expand the range of persons treated as equivalent to persons authorised to perform state functions. This category will include, in particular, persons involved in the selection, financing, implementation or monitoring of projects and programmes funded from the state budget and/or the National Fund, as well as members of collegial bodies that make decisions on such projects and programmes.
The restrictions related to the joint service and employment of relatives and other connected persons have also been substantially revised.
First, the circle of connected persons itself is clarified. In addition to close relatives and spouses, the law separately takes into account in-laws and other connected persons. These include, in particular, spouses of children, spouses and children of brothers and sisters, brothers and sisters of parents and their children, persons maintaining a joint household, dependants, former spouses, as well as legal entities in which an official or the official’s close relatives, spouse or in-laws hold shares or participatory interests, and legal entities in whose management they participate.
Second, the basic prohibition on direct subordination is preserved. Persons holding responsible public positions, persons authorised to perform state functions, persons treated as equivalent to them and officials will not be allowed to have close relatives, spouses, in-laws or other connected persons in their direct subordination, or themselves be directly subordinate to such persons.
Third, the restrictions go beyond direct subordination. Close relatives, spouses, in-laws and other connected persons will not be allowed to hold positions in structural units of state bodies, national managing holdings, national holdings, national companies, national and regional development institutions and their subsidiaries if such units are overseen or headed by the relevant official.
A separate prohibition is established for managerial positions. Close relatives, spouses and in-laws of the first head of a state body, organisation or quasi-public sector entity, or of another official authorised to make appointments, as well as other persons connected with them, will not be allowed to hold positions as heads of independent structural or territorial units or as heads of subordinate organisations.
Special restrictions are also introduced for HR, control and audit functions. If an official heads the HR management service, own or internal security service, internal audit service or another internal control unit, the official’s close relatives, spouse, in-laws and other connected persons will not be allowed to hold managerial positions in controlled territorial units or subordinate state bodies.
In addition, connected persons are prohibited from simultaneously holding positions in the same management body, supervisory board or executive body of a quasi-public sector entity.
If a violation of these requirements is identified, it must be remedied voluntarily within 3 months. Otherwise, the connected persons must be transferred to positions that exclude the relevant subordination, control relationship or joint work in the same management body. If such transfer is impossible, one of the officials or employees is subject to dismissal or release from the relevant functions.
The amendments also clarify the obligations of certain officials to declare information on connected persons in relation to inspected entities. For example, officials of the National Bank and the financial market regulation authority will be required to report close relatives, in-laws, spouses and other connected persons who are senior executives of inspected entities or work in such entities.
Restrictions for Persons Who Have Committed Corruption Offences
The prohibition on employing persons who have committed a corruption crime is expanded. Such persons will no longer be allowed to hold positions in the National Bank and its agencies, in the authorised body for the regulation, control and supervision of the financial market and financial organisations, or in authorised organisations in the field of civil aviation and the investigation of aviation accidents.
In addition, the prohibition applies to positions involving managerial functions in state organisations and quasi-public sector entities, as well as to positions not lower than the head of an independent structural unit, if they are related to decision-making on the organisation and conduct of procurement, including public procurement, or to the selection, financing, implementation or monitoring of projects and programmes funded from the state budget and/or the National Fund.
A separate prohibition applies to positions in the State Corporation “Government for Citizens” if they involve the direct provision of public services, are related to the provision of such services or provide access to personal data of individuals or other restricted-access information.
A restriction is also introduced for persons held administratively liable for a corruption offence: an administrative penalty imposed within 3 years before employment will prevent appointment to the above positions.
Anti-Corruption Compliance
A separate set of amendments concerns anti-corruption compliance in the quasi-public sector.
Partnerships and joint-stock companies that are quasi-public sector entities, as well as the National Welfare Fund and state enterprises operating under the right of economic management with a supervisory board, must designate a structural unit or responsible person performing anti-corruption compliance functions. Organisations outside the quasi-public sector are granted the right to establish the compliance function voluntarily.
Depending on the organisational and legal form, the supervisory board, board of directors or another independent governing body determines the staffing level of the compliance function, appoints its head or responsible person, and sets the term of office, official salary and remuneration conditions.
The law also establishes guarantees of independence for the compliance function. The head and employees of the anti-corruption compliance unit, as well as the responsible person performing its functions, may not be members of the supervisory board, board of directors, executive body or other collegial bodies of the relevant organisation. The compliance function exercises its powers independently of the executive body and officials of the organisation, is accountable to an independent governing body and interacts with the authorised body for anti-corruption policy.
The competence, organisation and operating procedure of the compliance function must be determined by an internal act of the organisation; for quasi-public sector entities, such an internal act must be based on the model regulation on anti-corruption compliance function approved by the authorised body for anti-corruption policy.
Criminal Liability
The adopted laws significantly change the criminal law regulation of bribery.
First, liability will arise not only for receiving but also for demanding a bribe, personally or through an intermediary, in the form of property or property-related benefits for oneself or other persons in exchange for actions or inaction in favour of the bribe-giver or persons represented by them, if such actions fall within the official powers of the relevant person or if that person, by virtue of their official position, can facilitate such actions, as well as for general patronage or connivance.
Second, the offer and promise of a bribe are criminalised in relation to a person authorised to perform state functions, a person treated as equivalent to such a person, a person holding a responsible public position, an official, as well as an official of a foreign state or an international organisation.
At the same time, the amendments clarify the approach to minor cases involving the transfer, receipt, demand, offer or promise of gifts and remuneration. In particular, the first-time receipt of a gift or remuneration by a person specified in Article 366 of the Criminal Code will not be considered a criminal offence and will be prosecuted under administrative procedure if there was no prior agreement for previously performed lawful actions or inaction, and the value of the gift or the amount of remuneration does not exceed 2 monthly calculation indices (MCIs; in 2026, 1 MCI in Kazakhstan is 4,325 tenge).
For a first-time demand for a bribe under similar conditions, an exemption from criminal liability on grounds of insignificance is also provided, but such conduct will be subject to disciplinary proceedings. The offer or promise of a gift or remuneration worth no more than 2 MCIs, in the absence of a prior agreement, will also not be considered a criminal offence due to insignificance.
The offence of receiving illegal remuneration by employees of organisations is also clarified. It concerns the receipt, by an employee of a state body, state organisation or quasi-public sector entity who is not a person authorised to perform state functions or a person treated as equivalent to such a person, as well as by an employee of a non-governmental organisation who does not perform managerial functions, of property or property-related benefits for performing work or providing a service falling within the scope of their duties. If such an act is committed on a large scale or through extortion, it may entail a fine, correctional labour, community service, restriction of liberty or imprisonment for up to 3 years.
Liability is also introduced for providing illegal remuneration to such employees. The basic penalty provides for a fine of up to 80 MCIs, correctional labour, community service or arrest for up to 20 days. In the event of repeated commission, the fine may increase to up to 120 MCIs, and in the case of illegal remuneration on a large scale – to up to 2,000 MCIs; restriction of liberty or imprisonment for up to 2 years may also be imposed.
In addition, entrapment into receiving illegal remuneration, a bribe or commercial bribery is criminalised: such an offence is punishable by imprisonment for a term of 3 to 8 years with deprivation of the right to hold certain positions or engage in certain activities for up to 5 years.
Administrative Liability
Amendments have also been made to the Code of Administrative Offences. In particular, the limitation period for bringing individuals to administrative liability for corruption offences has been increased from 1 year to 3 years from the date of commission of the offence. At the same time, a person may not be held liable after 2 months have passed from the date on which the administrative corruption offence was detected.
A new article is also introduced on the provision of illegal material remuneration, gifts, benefits or services by an individual. The provision of such remuneration, gifts, benefits or services to a person authorised to perform state functions, a person treated as equivalent to such a person, an official, a person holding a responsible public position, or an official of a foreign state or an international organisation, where the act does not contain elements of a criminal offence, will entail a fine of 200 MCIs.
The receipt of illegal material remuneration, gifts, benefits or services by the above persons, personally or through an intermediary, for themselves or other persons, in exchange for actions or inaction in favour of the persons providing them, if such actions fall within their official powers or if they can facilitate such actions by virtue of their official position, will entail a fine of 600 MCIs.
The liability of legal entities for providing illegal material remuneration, gifts, benefits or services is also clarified. If the act does not contain elements of a criminal offence, it entails a fine equal to 30 times the amount of the illegal remuneration, but not less than 750 MCIs. For a significant amount, the fine increases to 40 times the amount of the illegal remuneration; for a large amount, to 50 times; and for an especially large amount, to 60 times. A significant amount is defined as an amount from 50 to 3,000 MCIs, a large amount as more than 3,000 and up to 10,000 MCIs, and an especially large amount as more than 10,000 MCIs.
In addition, administrative liability is provided for:
- failure to take, or late taking of, measures to manage known cases of conflict of interest, where this resulted in a violation of the rights and legitimate interests of individuals or legal entities, the state, or legally protected interests of society; such a violation will entail a fine of 80 MCIs;
- failure to report information on corruption crimes being prepared, committed or already committed to a higher-level manager, the management of a state body, organisation or quasi-public sector entity, or authorised state bodies; this will entail a fine of 100 MCIs;
- failure to respond to a report of a corruption violation; this will entail a fine of 200 MCIs.
The main amendments to criminal, criminal procedure and administrative legislation will enter into force 10 calendar days after the first official publication of the law. Some provisions will enter into force after 60 calendar days, while the provisions concerning anti-corruption compliance, digital tools for identifying conflicts of interest, as well as the offer, promise and demand of a bribe, will come into effect on 1 January 2027.