FEES Schedules 10 and 11: no start date and no cap for the daily surcharge on unpaid late fees

"Non-payment of the late fee within 30 calendar days incurs a further late payment fee equal to 10% of the late fee for each calendar day" (5% in Schedule 11). The text does not say from which day the 30 days run (the contravention, the end of the 3 or 5 business days, or an invoice) and sets no cap on the surcharge (the AFSA may waive fees under FEES 5.1.3).

Proposed correction

Please state when the late fee becomes payable and when the daily charge starts, and confirm whether an upper limit is intended.

Jurisdiction

Kazakhstan — AIFC

Act

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

Place

Schedule 10, 10.1 (same wording in 10.2)

Record

Question of reading or data

Class

Question of reading or data

Where it arose

The text of the act

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-25

Evidence

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

Non-payment of the late fee within 30 calendar days incurs a further late payment fee equal to 10% of the late fee for each calendar day.

if the Person fails to provide notification, report or return within 3 business days after it has committed a contravention.

Non-payment of the late fee within 30 calendar days incurs a further late payment fee equal to 5% of the late fee for each calendar day.

How to check it without Arxo's tools

1. Open AIFC Fees Rules (FEES), V18, with amendments as of 13 November 2025 and find Schedule 10, 10.1 (same wording in 10.2); Schedule 10, 10.1; Schedule 11. 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-2026-0045, https://arxo.io/findings/ARXO-2026-0045/ (status as of 2026-10-25). Data: ARXO-2026-0045.json.