ARXO-2026-0038 · Reported

FEES Schedule 6, table 6.2 (crowdfunding platforms): no rule for funds raised of exactly 1 million USD

The variable fee is "not applicable" where "the funds raised is less than 1 million USD", and a levy applies to the whole amount where "the funds raised is more than 1 million USD". Funds raised of exactly 1 million USD in a quarter are covered by no branch, while the outcomes on either side differ. The draft in Consultation Paper AFSA-PSRD-CSP-2026-0004 raises the threshold to 5.3, 5.5 and 5.8 million USD for 2027, 2028 and 2029 with the same wording ("less than" and "more than"), so the gap moves to those amounts.

Proposed correction

Please allocate funds raised of exactly the threshold amount in a quarter to one band only, both in the current text (USD 1 million) and in the draft (USD 5.3, 5.5 and 5.8 million).

Jurisdiction: Kazakhstan — AIFC
Act: AIFC Fees Rules (FEES), AIFC Rules No. FR0007 of 2017, V18
Place: FEES Schedule 6, table 6.2, crowdfunding platform rows
Record: Discrepancy
Class: Text of the act
Where it arose: The text of the act
Arxo's conclusion: Confirmed
Official text: Unchanged at last check
Last checked: 2026-10-25

Evidence

Reproduced by execution. Quotations are verbatim from the official material; translations are ours and marked.

where the funds raised is less than 1 million USD, is not applicable;

Normative text · AIFC Fees Rules (FEES), V18, with amendments as of 13 November 2025 · Schedule 6, table 6.2, rows 'Operating a Loan Crowdfunding Platform***' / 'Operating an Investment Crowdfunding Platform***', bullet 1 · retrieved 2026-10-23 · SHA-256 b5e10ace11734eda9e2edf7ab4dc62ef97ee659e460dbcb48ab5c4815f8de8f6 · copy

where the funds raised is more than 1 million USD, a levy of 0.05% p.a. of the funds raised.

Normative text · AIFC Fees Rules (FEES), V18, with amendments as of 13 November 2025 · Schedule 6, table 6.2, same cell, bullet 2 · retrieved 2026-10-23 · SHA-256 b5e10ace11734eda9e2edf7ab4dc62ef97ee659e460dbcb48ab5c4815f8de8f6 · copy

the variable fee is calculated on the basis of the total funds raised during the relevant quarter.

Normative text · AIFC Fees Rules (FEES), V18, with amendments as of 13 November 2025 · Schedule 6, ***Notes on Crowdfunding Platforms (2) · retrieved 2026-10-23 · SHA-256 b5e10ace11734eda9e2edf7ab4dc62ef97ee659e460dbcb48ab5c4815f8de8f6 · copy

How to check it without Arxo's tools

Open AIFC Fees Rules (FEES), V18, with amendments as of 13 November 2025 and find Schedule 6, table 6.2, rows 'Operating a Loan Crowdfunding Platform***' / 'Operating an Investment Crowdfunding Platform***', bullet 1; Schedule 6, table 6.2, same cell, bullet 2; Schedule 6, ***Notes on Crowdfunding Platforms (2). Compare the text with the quotation above. A copy is kept in this register: b5e10ace11734eda-fees-v18.pdf (SHA-256 b5e10ace11734eda9e2edf7ab4dc62ef97ee659e460dbcb48ab5c4815f8de8f6, copy of the official file).
The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.

How this finding was made

AI agents read the official texts, turned the provisions concerned into executable rules and ran the comparison; they also drafted this record. A person at Arxo checked the finding and approved the report before it was sent (2026-10-27).

Responsible institutions

Astana Financial Services Authority (AFSA) — author of the AIFC Rules

Reported to

Date	Institution	Channel	Reference
2026-10-27	Astana Financial Services Authority (AFSA)	e-mail

Date

Institution

Channel

Reference

2026-10-27

Astana Financial Services Authority (AFSA)

e-mail

Responses

No response recorded.

History

2026-10-23Confirmed by Arxo
2026-10-27Entered in the register
2026-10-27Reported to Astana Financial Services Authority (AFSA) (e-mail)

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0038, https://arxo.io/findings/ARXO-2026-0038/ (status as of 2026-10-25). Data: ARXO-2026-0038.json.