Kazakhstan AFSA Stablecoin Issuer License

The Astana International Financial Centre (AIFC) in Kazakhstan is one of the few jurisdictions outside the EU and US with a fully enacted, operational regulatory framework specifically for fiat-backed stablecoin issuance. The AFSA Stablecoin Framework, which came into effect on 1 January 2024 as part of the AIFC Rules on Digital Asset Activities, was developed in alignment with recommendations from the Financial Stability Board, IOSCO, the Basel Committee, CPMI, FATF, and the Bank for International Settlements. It is not a light-touch registration — it is a substantive licensing framework covering reserve management, redemption rights, capital adequacy, independent audits, and AML/CFT compliance, designed to international financial centre standards rather than offshore minimalism.

The AIFC operates as an independent jurisdiction within Kazakhstan with its own legal system based on English common law, its own court (the AIFC Court) modelled on English commercial courts, and its own financial regulator (AFSA). AIFC participants benefit from tax exemptions through 2066 — a 50-year statutory guarantee covering corporate income tax, VAT, and other levies. Over 4,000 firms from 84 countries are registered in the AIFC, including banks, insurers, investment firms, and a rapidly growing digital asset sector. As of Q3 2025, 29 licensed Digital Asset Service Providers operate in the AIFC, including 12 digital asset exchanges, with total trading volumes on AIFC-licensed platforms reaching USD 6.8 billion in the January to September 2025 period — up from a significantly smaller base in 2024. The number of users in the AIFC digital asset ecosystem grew from 141,000 in 2024 to over 192,000 by Q3 2025.

The AFSA Stablecoin Framework — What It Covers

The AFSA Stablecoin Framework governs the Regulated Activity of Providing Money Services in relation to Digital Assets as the Issuer of a Fiat Stablecoin. Any entity wishing to issue a fiat-backed stablecoin in or from the AIFC must obtain AFSA authorisation under this framework before commencing operations. The framework covers two categories of stablecoin:

Fiat Stablecoins — digital assets whose value is determined by reference to a fiat currency or a basket of fiat currencies. The AFSA framework permits issuance of stablecoins pegged to G10 currencies (Australian Dollar, British Pound Sterling, Canadian Dollar, Euro, Japanese Yen, New Zealand Dollar, Norwegian Krone, Swedish Krona, Swiss Franc, and United States Dollar), as well as the Chinese Yuan (RMB), and any other currency agreed with AFSA on a case-by-case basis. Only single-currency peg structures are permitted under the framework — algorithmic or unbacked stablecoins cannot be authorised.

Commodity Stablecoins — digital assets backed by a physical commodity such as gold or other recognized commodities. The reserve asset rules and independent audit requirements apply to commodity stablecoins in the same manner as fiat stablecoins.

The First Stablecoin Issuer License — June 2025

In June 2025, AFSA granted its first stablecoin issuer license to AnchorX.KZ Limited, authorizing it to carry on the Regulated Activity of Providing Money Services in relation to Digital Assets as the Issuer of a Fiat Stablecoin. The license was granted under the AFSA Stablecoin Framework and represents the first completed stablecoin authorization in the AIFC. AnchorX CEO Hill Wang described AFSA's framework as "forward-looking" and highlighted the strategic importance of the AIFC for cross-border financial solutions targeting Kazakhstan's growing regional economic relationships.

Following the AnchorX license, AFSA confirmed significant interest from additional applicants — particularly from businesses in Southeast Asia — in issuing proprietary stablecoins within the AIFC. The framework's combination of a transparent regulatory structure, 0% tax, English common law, and CIS market access has made the AIFC a serious consideration for operators building USD, EUR, and other currency-pegged payment stablecoins for cross- border trade corridors in Central Asia, the Middle East, and East Asia.

Reserve Requirements — 100% Backing, Independent Annual Audit

The AFSA framework imposes strict reserve requirements on all stablecoin issuers. The core principle is straightforward: the value of reserve assets must at all times be at least equal to the nominal value of all outstanding stablecoin units. Partial reserve or fractional reserve structures are not permitted under the framework. Key reserve requirements include:

• •Full reserve backing — reserve assets must equal or exceed the total outstanding stablecoin supply at all times, valued at mark-to-market on the more prudent side of bid and offer
• •Reserve asset composition — reserves must be held in qualifying assets as defined by AFSA, with custodianship arrangements meeting AFSA-prescribed standards or, for non-AIFC custodians, equivalent protections acceptable to AFSA
• •Independent annual audit — the reserve must be audited by an independent third party annually, no later than four months after the close of the financial year. Audit results must be submitted to AFSA without delay (within 4 weeks of the valuation reference date) and published within three weeks of AFSA submission
• •AFSA examination rights — the issuer must make reserve assets available for examination and verification by AFSA on request
• •Recovery and redemption plans — issuers must maintain documented recovery arrangements and redemption procedures, with AFSA having authority to delay audit publication if a recovery arrangement is being implemented

Capital Requirements and Financial Thresholds

The minimum capital required to obtain AFSA authorisation as a stablecoin issuer is USD 200,000. Where an entity is applying for the stablecoin issuer authorisation alongside another regulated activity that carries a higher capital requirement, the highest applicable capital requirement prevails. Capital must be maintained on an ongoing basis as part of the going-concern requirement — AFSA assesses financial soundness both at licensing and in ongoing supervision.

Application fees are approximately USD 70,000 for the standard licensing pathway. Entities applying through the AFSA FinTech Lab sandbox pathway benefit from a substantially reduced application fee of approximately USD 7,000 — making the sandbox route commercially meaningful for early-stage issuers that qualify. The annual supervisory fee payable to AFSA after licensing is approximately USD 25,000 to USD 35,000 per year. A registration fee of approximately USD 300 is also payable at incorporation.

The In-Principle Approval Process

A defining feature of the AFSA licensing process is the requirement for an In-Principle Approval (IPA) before a new company is formally incorporated in the AIFC. The IPA is a preliminary regulatory assessment that gives AFSA the opportunity to evaluate the proposed business model, licence type, management team, and compliance framework before the applicant commits to full incorporation and fee payment. The IPA outcome establishes the specific conditions that must be satisfied before the full licence is issued — covering company formation, charter capital deployment, policy development, and management personnel qualification submission.

The IPA process involves submission of a full application package including approximately seven internal corporate policies, a detailed business plan with three-year financial projections, AML/CFT and KYC policies, cybersecurity and IT risk management frameworks, internal governance policies (conflict of interest, business continuity, reporting), and due diligence documentation for all key management personnel. The AFSA conducts a comprehensive risk analysis evaluating the proposed stablecoin model, reserve structure, transparency, and traceability mechanisms. Recommendations are then reviewed by an AFSA collegial committee before approval is granted or refused.

AML/CFT, KYC, and AIFC Compliance Framework

AIFC stablecoin issuers are subject to AFSA's AML/CFT requirements, aligned with FATF Recommendation 15 and the broader AIFC regulatory framework. The compliance programme must be tailored to the stablecoin's distribution channels, user base, and cross-border transaction flows — generic AML templates will not satisfy AFSA's review standard. Key compliance requirements include: a designated AML/CFT Compliance Officer; KYC and Enhanced Due Diligence (EDD) procedures for stablecoin holders and redemption requestors; transaction monitoring for unusual patterns or sanctioned counterparties; Travel Rule compliance for transfers above threshold; and Suspicious Activity Reporting.

AFSA's digital asset supervisory posture has been evolving rapidly. Amendments to the AIFC Rules on Digital Asset Activities were published in December 2025 and came into force on 13 October 2025 (from the April 2025 amendment version), expanding capital market, digital assets, and crowdfunding frameworks. AFSA has also introduced SupTech capabilities and opened a consultation on regulatory fee updates in October 2025, signalling ongoing framework maturation.

2025 Milestone: AFSA Accepts Stablecoin Fee Payments

In October 2025, AFSA received its first-ever regulatory fee payment in stablecoins — a milestone for the AIFC and for the broader legitimization of stablecoins as a payment instrument in a supervised regulatory context. The payment was made by SkyBridge Digital Finance Ltd., a licensed DASP and FinTech Lab participant in the AIFC, using USD-pegged stablecoins. The pilot programme, launched during Astana Finance Days 2025 in September, enables AIFC participants to pay regulatory fees using USD-pegged stablecoins including USDT and USDC. Bybit Kazakhstan is the designated licensed provider for the payment infrastructure, offering a QR Pay system and stablecoin wallet for AFSA fee settlement.

AFSA's decision to accept stablecoin fee payments is not merely symbolic. It signals that AFSA treats compliant, fiat-pegged stablecoins as a legitimate financial instrument within its regulatory perimeter — a position that materially strengthens the commercial case for issuing stablecoins under the AFSA framework. Settlement times under the stablecoin payment infrastructure reduce from the 48–120 hours typical of traditional cross-border banking to under 15 minutes on-chain, with transaction cost reductions of up to 90% compared to traditional correspondent banking transfers.

Tax Position — 0% Until 2066

AIFC participants, including licensed stablecoin issuers, are exempt from Kazakhstani corporate income tax, VAT, and most other levies until 1 January 2066— a statutory guarantee of approximately 40 years remaining from 2026. This is one of the longest-horizon statutory tax exemptions available from any regulated financial centre globally. The exemption applies to income earned within the AIFC framework and requires that the entity meets the AIFC's substantial presence requirements — physical office in the AIFC, genuine operational activity, and compliance with AFSA's substance rules.

Employees of AIFC participants benefit from a simplified visa and work permit regime, with foreign specialists able to enter Kazakhstan under a special 5-year visa without requiring a standard foreign worker permit. Kazakhstan has established an Expat Center providing over 500 services to foreign citizens, making talent relocation for stablecoin operations in Astana materially more straightforward than in many competing jurisdictions.

The AFSA FinTech Lab — Sandbox Pathway for Early-Stage Issuers

AFSA operates a dedicated FinTech Lab regulatory sandbox that allows innovative digital asset projects — including stablecoin issuers — to test their products and services in a controlled regulatory environment before applying for full licensing. The FinTech Lab pathway carries a substantially reduced application fee of approximately USD 7,000 versus the ~USD 70,000 standard pathway, and provides time-limited authorization to operate while building toward full AFSA compliance. The sandbox is designed for genuinely innovative business models where AFSA wishes to assess the product in a live but supervised environment before granting permanent authorization. SkyBridge Digital Finance — which made the first stablecoin regulatory fee payment in October 2025 — was operating as a FinTech Lab participant at that time.

Kazakhstan AIFC Stablecoin vs Mauritius VAITOS and Other Jurisdictions

For stablecoin issuers choosing a regulated jurisdiction in 2026, the AIFC sits alongside the Mauritius FSC ITO/Stablecoin license as one of the only two offshore-adjacent jurisdictions with a fully enacted, operationally live stablecoin issuance framework. The key differentiators:

The AIFC's CIS market positioningis unique — no other stablecoin jurisdiction offers comparable access to Central Asian cross-border trade corridors, the Kazakhstan domestic market (which has a significant and growing digital asset user base), and Eurasian Economic Union (EAEU) trading partners. Kazakhstan's bilateral trade with China reached USD 43.8 billion in 2024, and the AIFC's geographic and regulatory positioning makes it a natural infrastructure layer for regional cross-border stablecoin payments.

Mauritius offers stronger African and Asian banking relationships through its 46 DTAA network and deeper correspondent banking infrastructure developed over two decades. For stablecoin projects targeting African payment corridors or requiring extensive treaty-based banking relationships, Mauritius may provide better banking access than the AIFC.

For EU-facing stablecoin projects requiring MiCA e-money token (EMT) or asset-referenced token (ART) authorization, neither the AIFC nor Mauritius provides EU passporting — a Cyprus MiCA CASP or EU EMI authorization is required for EU retail distribution. AIFC and Mauritius stablecoin licenses are appropriate for global non-EU distribution strategies, CIS market operations, and institutional cross-border payment infrastructure.

Corporate Structure and Substance Requirements

To operate as a stablecoin issuer in the AIFC, the entity must be incorporated as a Centre Participant — a company registered within the AIFC framework under AIFC company law. The entity must maintain a physical office presence in the AIFC and employ qualified management and compliance personnel. Key required roles include a Chief Executive Officer, Chief Financial Officer, Compliance Officer (AML/CFT), and depending on scale, potentially also an Internal Auditor, Risk Manager, and IT Security Officer. A corporate bank account in Kazakhstan is required to hold reserve assets and manage operational funds. All senior management appointments must be approved by AFSA prior to commencing regulated activities.

How Zitadelle AG Assists with Kazakhstan AFSA Stablecoin Licensing

Zitadelle AG provides end-to-end support for AIFC stablecoin issuer licensing — from initial feasibility assessment and stablecoin model design (reserve structure, currency peg, redemption mechanics), through AIFC company incorporation, In-Principle Approval preparation and AFSA submission management, AML/CFT policy drafting, cybersecurity framework preparation, business plan and financial projections, management team sourcing and due diligence pack assembly, Kazakh bank account introduction, reserve custodian coordination, and post-licensing annual audit management and ongoing compliance. For operators evaluating the AIFC alongside Mauritius or other stablecoin jurisdictions, we provide honest comparative analysis of which structure best fits the specific target market, reserve management model, and distribution strategy.