Investment in securities for public officials of the Republic of Kazakhstan

Updated 22.09.2026

Правила и ограничения для госслужащих при инвестировании в ценные бумаги.

The material was prepared on the basis of the laws of the Republic of Kazakhstan On Public Service, On Corruption Prevention and explanations of the Agency of the Republic of Kazakhstan for public service affairs.


Who is considered a public official?

According to Article 1 of the Law of the Republic of Kazakhstan On Public Service, a public official is a citizen of the Republic of Kazakhstan who holds an administrative or political public position and performs work on a permanent basis paid from the government budget.


The public officials subject to restrictions include:

  • Employees of ministries, agencies, akimats and other government bodies;
  • Akims and their deputies;
  • Secretaries of maslikhats, members of Parliament;
  • Members of the Government, the Constitutional Council, judges;
  • Employees of anti-corruption and law enforcement agencies;

Military and law enforcement personnel are not considered public officials under this law, but may be subject to other departmental restrictions.


Rights and restrictions when investing in securities:

Public officials are allowed to invest in securities provided that they comply with the restrictions established by law. The restrictions depend on the category of the position.



Category
Restrictions and Permissions
Obligations
Category 1: Senior officials of the financial system
  • Chairman of the National Bank of the Republic of Kazakhstan and his Deputies;
  • Heads and Deputies of the authorized body for regulation of the financial market;
  • Officials of the National Bank of Kazakhstan and its departments.
  1. It is prohibited to purchase any securities (shares, bonds, mutual fund units);
  2. It is permitted to gain income from property transferred to trust management.
  1. Transfer existing property (including securities) to trust management within 30 calendar days from the date of taking the office;
  2. Notarize the agreement and transfer a copy to the HR department within 10 days.
Category 2: Political public officials and members of key bodies
  • Members of the Government of the Republic of Kazakhstan;
  • Chairman and members of the Constitutional Council;
  • Judges.

Note: special statutory regulations apply to judges, members of the Constitutional Council and political public officials, which may completely prohibit the holding of securities. It is recommended to clarify the legal regime taking into account current regulations.
1. It is permitted to purchase:
  • Bonds on the recognized market;
  • Units of open and interval mutual funds;
  • Common shares on the recognized market (no more than 5% of the voting shares of one company);
2. Holding of assets outside the recognized market and participation in the management of business structures are prohibited.
  1. Transfer the securities purchased into trust management within 30 days;
  2. Provide a copy of the notarized agreement to the HR department within 10 days.
Category 3: Other public officials and candidates
  • Deputies of maslikhats on a non-permanent basis;
  • Candidates for Presidency, deputies of Parliament and maslikhats;
  • Candidates for Akims and elective bodies;
  • Candidates for quasi-public sector bodies.
  1. It is permitted to purchase any securities without restrictions;
  2. It is not required to transfer assets into trust management.



General requirements for all public officials:

  • It is prohibited to purchase more than 5% of the voting shares of one company;
  • It is prohibited to use insider information;
  • It is prohibited to participate in the management of business structures;
  • It is permitted to invest through a recognized market and licensed brokers;
  • It is required to notify the HR department about the existence of securities.


Normative references:

  1. Law of the Republic of Kazakhstan On Public Service dated November 23, 2015 No. 416-V ЗРК
  2. Law of the Republic of Kazakhstan On Corruption Prevention dated November 18, 2015 No. 410-V ЗРК
  3. Law of the Republic of Kazakhstan On the Securities Market
  4. Clarifications of the Agency of the Republic of Kazakhstan for Public Service Affairs



This material is prepared for reference. In each particular case, we recommend that employees seek clarification from the legal department or HR department at their place of work.

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Owning securities and other financial instruments is always associated with risks: the value of securities and other financial instruments can both rise and fall. Past investment results do not guarantee future income. In accordance with the law, the company does not guarantee or promise future returns on investments, nor does it provide guarantees regarding the reliability of potential investments or the stability of potential income.

Freedom Finance Global PLC provides brokerage (agency) services in the securities market on the territory of the Astana International Financial Center (hereinafter referred to as AFSA) in the Republic of Kazakhstan. Subject to compliance with requirements, conditions, restrictions and/or directions of the Acting Law of the AFSA, the Company is authorized to conduct the following Regulated Activities under License No. AFSA-A-LA-2020-0019: Dealing in Investments as Principal, Dealing in Investments as Agent, Managing Investments, Advising on Investments, Arranging Deals in Investments.

S&P Global ratings – “BB-”, outlook “Positive”.

Ownership of securities and other financial instruments always involves risks: the cost of securities and other financial instruments may rise or fall. Past investment results do not guarantee future returns. In accordance with the legislation, the company does not guarantee or promise the profitability of investments in the future, does not guarantee the reliability of possible investments and the stability of the amount of possible income.

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