AFSA online Market Rules do not contain MAR 1.9.3 and 1.9.4 (Amendments No. 7, 29 June 2022)

The AFSA online Market Rules do not contain MAR 1.9.3 (Expert’s responsibility) and 1.9.4 (Exceptions from liability), which Amendments No. 7 inserted with effect from 29 June 2022. In the online text, 1.9.2 (Limitations on the application of MAR 1.9.1) is followed directly by 1.10 (AIFC ESG Debentures). The consolidated versions V8 to V13 on aifc.kz contain both rules. The online text applied another change made by the same instrument (MAR 2.1(2), which excludes Listed Funds and Exempt Offerors from MAR 2), but not its change to MAR 3.1-1(1), which in the act also excludes an Exempt Offeror from MAR 3. The online Schedule 4, paragraph 1(a)(ii) still refers to "consent under MAR 1.9.3", and the Glossary defines "Expert" by MAR 1.9.3; a reader of the online rulebook cannot find that rule. Our earlier observation on the Glossary entry "Expert" (AIFC-GLO-06) relied on the online text and is withdrawn: the definition resolves in the act. MAR 1.9.4(4)(a) has a separate wrong reference (see AIFC2-MKT-05).

Proposed correction

Please insert MAR 1.9.3 and 1.9.4 in the online Market Rules and apply the change to MAR 3.1-1(1) made by Amendments No. 7.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Market Rules (MAR), V13

Place

MAR V13, 1.9.3(1) (rule), page 23

Record

Discrepancy

Class

Publication and consolidation

Where it arose

The official publication

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-24

Evidence

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

For the purposes of liability under section 79(1) of the Framework Regulations, an Expert

keep a record of any consent received under Rule 1.9.3(1); and

included in the Prospectus with the Expert's consent at the time when the Prospectus was

This section 3 of the MAR will not apply to:

Commencement Date: 29 June 2022

In this document the underlining indicates new text

1.9.3 Expert’s responsibility

1.9.4 Exceptions from liability

This section 3 of the MAR will not apply to:

Has the meaning given in MAR 1.9.3.

How to check it without Arxo's tools

1. Open Market Rules V13., (with amendments as of 7 December 2025, which commence on 1 January 2026) and find MAR V13, 1.9.3(1) (rule), page 23; MAR V13, 1.9.3(3)(a) (rule), page 23; MAR V13, 1.9.4(3) (rule), page 24; MAR V13, 3.1-1(1) (rule), page 37 — A7 wording. Compare the text with the quotation above. A copy is kept in this register: 163c0ad176174003-mar_v13_01.01.2026.pdf (SHA-256 163c0ad17617400321bc039bc3f91829586cbde62fec9a8d37e946d417252e7d, copy of the official file).
2. Open Market Rules A7., with amendments as of 29 June 2022, commence on 29 June 2022 and find MAR Amendments No. 7, cover; MAR Amendments No. 7, legend; MAR Amendments No. 7, page 2 — 1.9.3 inserted; MAR Amendments No. 7, page 2 — 1.9.4 inserted; MAR Amendments No. 7, page 4 — 3.1-1(1). Compare the text with the quotation above. A copy is kept in this register: a8d7aa5caef9a91c-mar_a7_29.06.2022.pdf (SHA-256 a8d7aa5caef9a91ca3e9fb4116ab69592a5539176e4c3a4cf77bea273c3e3a7a, copy of the official file).
3. Open AIFC Glossary (GLO), V23 and find Glossary V23, 'Expert'. Compare the text with the quotation above. A copy is kept in this register: 041617346ad87a9f-glo-v23.pdf (SHA-256 041617346ad87a9ff3634eff95b3b92f65ee5f4965298a2c1137b8b9a8374b45, copy of the official file).
4. 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) — publisher of the AIFC Rules on the AFSA website

Reported to

Responses

No response recorded.

Documents and reproduction

• Market Rules V13., (with amendments as of 7 December 2025, which commence on 1 January 2026)
• Market Rules A7., with amendments as of 29 June 2022, commence on 29 June 2022
• AIFC Glossary (GLO), V23

Related records

• ARXO-2026-0096 — MAR 1.9.4(4)(a): the Expert limb of the correction defence refers to "(2)(c)", which is not about Expert statements; the Expert paragraph is (3)

History

1. 2026-10-24Confirmed 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-2026-0104, https://arxo.io/findings/ARXO-2026-0104/ (status as of 2026-10-24). Data: ARXO-2026-0104.json.