FEES: several fees and payment terms are set in "Notes" and footnotes, which are not part of an AIFC Act

Section 26(1)(a) of the AIFC Regulations on AIFC Acts says that "a footnote, endnote or other note" is not part of an AIFC Act, even if inserted by an amending act (section 26(2)). In FEES the application fee for change of control (1 400 USD), the Approved Individual fee (500 USD), the quarterly payment of variable fees and the deferral of some fees to 1 January 2027 appear under "Notes" headings or in footnotes.

Proposed correction

Move these provisions into numbered paragraphs of the Schedules, or state in FEES that the Notes form part of the Rules.

Jurisdiction

Kazakhstan — AIFC

Act

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

Place

AIFC Regulations on AIFC Acts s.26(1)(a)

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.

a footnote, endnote or other note; and

An Authorised Firm applying for change of control must pay to the AFSA an application fee in the amount of 1 400 USD.

will apply from 1 January 2027.

Notes on calculation of annual supervision fees for Regulated Activities with variable

How to check it without Arxo's tools

1. Open AIFC Regulations on AIFC Acts, as amended on 11 January 2019 and find AIFC Regulations on AIFC Acts s.26(1)(a). Compare the text with the quotation above. A copy is kept in this register: 4f25a8539468e034-regulations-on-aifc-acts-2019.pdf (SHA-256 4f25a8539468e034bf728e88a7af90f9c2bcb8c1bc72c22dd126f7edab2486bc, copy of the official file).
2. Open AIFC Fees Rules (FEES), V18, with amendments as of 13 November 2025 and find FEES Schedule 1, block «Notes»: Application fee for change of control; FEES Schedule 6, footnote * to table 6.1; FEES Schedule 6, **Notes to table 6.1. 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).
3. 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-2026-0052, https://arxo.io/findings/ARXO-2026-0052/ (status as of 2026-10-25). Data: ARXO-2026-0052.json.