FEES 3.1.2 and 3.1.4(b): the initial supervision fee runs from "the grant of the Licence", which recognised Non-AIFC bodies never receive

Before Amendments No. 17 the due date ran from "the commencement of operations", which fitted every payer. Since then the initial annual supervision fee is due "within 21 days of the date of the grant of the Licence" and is pro-rated from that date. FEES 3.1.1 also makes Recognised Non-AIFC Market Institutions and Members pay the fee, but they are recognised by an order under the Framework Regulations, not licensed under Part 3, so the specific due date and the pro-rating do not fit them.

Proposed correction

For recognised Non-AIFC institutions and members, please name the effective date of recognition as the trigger for the initial supervision fee and its pro-rating.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Fees Rules (FEES), AIFC Rules No. FR0007 of 2017, V18

Place

V18 FEES 3.1.1

Record

Discrepancy

Class

Amendments

Where it arose

The amending act

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-23

Evidence

Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.

Recognised NonAIFC Market Institution or Recognised Non-AIFC Member must pay to the AFSA:

The initial annual supervision fee must be paid in full to the AFSA within 21 days of the date of the grant of the Licence.

over the whole months remaining between the date of the grant of the Licence and the end of the year.

How to check it without Arxo's tools

1. Open AIFC Fees Rules (FEES), V18, with amendments as of 13 November 2025 and find V18 FEES 3.1.1; V18 FEES 3.1.2; V18 FEES 3.1.4(b). 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).
2. 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

Responses

No response recorded.

History

1. 2026-10-23Confirmed by Arxo
2. 2026-10-27Entered in the register
3. 2026-10-27Reported to Astana Financial Services Authority (AFSA) (e-mail)

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0042, https://arxo.io/findings/ARXO-2026-0042/ (status as of 2026-10-23). Data: ARXO-2026-0042.json.