Kazakhstan (AIFC) — Money Service Provider Authorization (AFSA) 2026

What is the AIFC and Why Does It Matter?

The Astana International Financial Centre (AIFC) is Kazakhstan's dedicated financial hub — a special economic zone operating under English common law with its own independent financial regulator (AFSA), its own court system, and a tax regime guaranteed at zero percent until 2066 by constitutional statute. Established in 2018, the AIFC has grown to host over 4,000 firms from more than 85 countries — making it the premier financial regulatory hub for the Eurasian corridor and a genuinely significant global financial centre.

For payment companies, money service operators, EMIs, and fintech businesses, the AIFC MSP authorization provides a uniquely compelling combination: FATF-aligned regulation, zero tax for over four decades, English common law legal infrastructure, explicit digital asset payment service authorization, and direct access to Central Asian and CIS payment markets that few other jurisdictions can match.

Why the AIFC Matters for Payment Operators

Authorized Activities Under the PMS Rules (2026)

Under the new PMS Rules, "Providing Money Services" covers a comprehensive range of payment activities — significantly broader than the previous Rule 21 framework.

1. 1
   Currency Exchange: Buying and selling foreign currencies — including arranging currency exchange for clients. Covers spot FX, multi-currency conversion, and currency exchange intermediary services.
2. 2
   Payment Instruments: Selling or issuing payment instruments — covering prepaid cards, vouchers, digital payment tokens used as payment instruments, and similar stored value products.
3. 3
   Stored Value: Selling or issuing stored value — electronic money held in accounts, e-wallets, and digital stored value instruments.
4. 4
   Payment Transaction Execution: Executing payment transactions including transfers via bank/settlement accounts, direct debits, and payments via card or similar devices. Covers standard payment execution services including credit transfers, direct debits, and card payment processing.
5. 5
   Credit-Line Backed Payments: Executing payment transactions backed by a credit line — covering buy-now-pay-later (BNPL) type payment structures and credit-facilitated payment execution.
6. 6
   Money Remittance: Domestic and cross-border money remittance — including international wire transfers, mobile remittance platforms, and cross-border payment services. The PMS Rules explicitly authorize cross-border fund transfers including royalty payments, merchant settlements, and client remittances.
7. 7
   Telecom/Digital Network Initiated Transactions: Transactions initiated through telecommunications networks, digital networks, or IT systems — covering mobile payment platforms, app-initiated payments, and digital-channel payment initiation.
8. 8
   Digital Asset Payment Services (NEW — October 2025): Digital asset remittances and digital asset acquiring. Licensed MSPs can provide remittance services denominated in or settled via digital assets, and can accept digital assets as payment on behalf of merchants.
9. 9
   Non-Custodial Digital Asset Payment Initiation (NEW — October 2025): Non-custodial payment initiation services involving digital assets — covering business models comparable to MetaMask-type and Trust Wallet-type payment initiation. The entity does not hold client digital assets but initiates payment transactions on behalf of clients.

Phase 2 Compliance Requirements (January 2026)

The Phase 2 requirements represent the most significant compliance obligations ever imposed on AIFC MSP holders. Any firm applying now must build these into their compliance framework from the outset.

Digital Asset Payment Services: The Two New Models

The October 2025 Phase 1 update introduced two specific business models for AIFC MSPs seeking to integrate digital assets into payment services. These are codified frameworks — not case-by-case approvals.

Capital Requirements Under the New PMS Rules

The April 2025 PMS Rules introduced a revised capital requirements framework that is more formally structured than the previous Rule 21 provisions.

• •The capital floor is now formally set under the PMS Rules with additional working capital buffer obligations
• •AFSA assesses capital adequacy relative to the scope of money services activities and projected transaction volumes
• •Firms providing digital asset payment services under the new models may face additional capital expectations reflecting the risk profile of those activities
• •Capital must be maintained throughout the authorization period — not just at application stage
• •Annual financial statements demonstrating capital adequacy are required

AIFC MSP vs. Other Global Payment Licenses

Why 2026 Is the Right Time to Apply

The AIFC MSP framework has matured significantly since 2018. The combination of factors in 2026 creates a compelling window for payment operators.

• •PMS Rules now provide clarity and predictability that Rule 21 lacked — operators know exactly what is authorized
• •Digital asset payment service authorization (October 2025) opens commercial opportunities not previously available
• •4,000+ AIFC-registered firms create an ecosystem of potential commercial partners and counterparties
• •AFSA's 2026–2028 roadmap signals continued regulatory development — early entrants build ahead of further framework expansion
• •Zero tax until 2066 — each year of delay reduces the total duration of the tax advantage
• •Phase 2 compliance (January 2026) is now a known requirement — firms building now incorporate it from the outset rather than retrofitting

How Zitadelle AG Assists

• Pre-application structure assessment — activity scope selection, capital adequacy, Phase 2 compliance readiness
• AIFC entity incorporation — company formation in the AIFC under the AIFC Companies Regulations
• Full PMS Rules-compliant application preparation — business plan, AML/CFT framework, cybersecurity policies, client protection framework, SCA implementation plan, complaints handling procedures, safeguarding arrangements
• AFSA submission and regulatory liaison — all AFSA correspondence managed by Zitadelle AG
• Digital asset payment service model advisory — assessment of whether your specific digital asset payment model qualifies under Model 1 (remittance/acquiring) or Model 2 (non-custodial initiation)
• Phase 2 compliance documentation — complete Phase 2-required policies and frameworks prepared as standard
• Key personnel sourcing — AFSA-approvable payment professionals via HRFinEase
• Post-authorization compliance support — AFSA reporting, IT audit coordination, annual capital adequacy, SCA compliance maintenance
• AFSA regulatory roadmap monitoring — tracking 2026–2028 framework developments affecting MSP holders