BPG not updated: it says Credit Providers are not Banking Business firms and excludes them from the leverage ratio, which BBR 4.36 has applied to Providing Credit since December 2022

BPG paragraph 6 says: "Credit Providers as defined in BBR 1.7 are not included in Banking Business firms according to BBR 1.4." BBR 1.4(3) has said since 2018 that a Banking Business firm may be a Credit Provider, and BPG paragraphs 2, 4 and 5 themselves include Credit Providers. The BPG tables also exclude Credit Providers from Section 4F (Rules 4.36-4.37, leverage ratio). That matched BBR 4.36 until the version with amendments as of 9 December 2022, which applies Section 4F to firms licensed for "Accepting Deposits" or "Providing Credit". The BPG (28 January 2019) has not been updated. The BBR prevail, so the problem is misleading guidance.

Proposed correction

Please delete BPG paragraph 6 and remove the Credit Provider exclusion from Section 4F (Rules 4.36-4.37) in the BPG tables.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Banking Business Prudential Rules (BBR), V6

Place

BPG Ch.1 para 6

Record

Discrepancy

Class

Amendments

Where it arose

The amending act

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.

Credit Providers as defined in BBR 1.7 are not included in Banking Business firms according to BBR 1.4.

Section 4F, Rules 4.36 &

A Banking Business firm may be a Bank or a Broker Dealer or a Credit Provider.

The rules in this section apply only to Authorised Firms licensed by the AFSA to conduct the Regulated Activities of “Accepting Deposits” or “Providing Credit”.

(with amendments as of 9 December 2022,

The rules in this section apply only to Authorised Firms licensed by the AFSA to conduct the Regulated Activities of “Accepting Deposits” or “Providing Credit”.

The rules in this section apply only to Banks. For the sake of clarity, the rules in this section apply only to Banks licensed by the AFSA to conduct the Regulated Activity of “Accepting Deposits”.

A Banking Business firm may be a Bank or a Broker Dealer or a Credit Provider.

all the Rules with reference to a Bank or applying to a Bank are applicable also to Credit Providers and Broker Dealers.

How to check it without Arxo's tools

1. Open AIFC BANKING PRUDENTIAL GUIDELINE and find BPG Ch.1 para 6; BPG Ch.1 table, Chapter 4 row, Credit Provider column; BPG Chapter 1, para 5. Compare the text with the quotation above. A copy is kept in this register: c0ab57e226481347-aifc-banking-prudential-guideline.pdf (SHA-256 c0ab57e226481347e28c09650f905debc948a442ad7b65fa2db2d196d0b22009, copy of the official file).
2. Open AIFC Banking Prudential Rules_V6 (with amendments as of 13 April 2025, which commence on 13 October 2025) and find BBR 1.4(3); BBR 4.36. Compare the text with the quotation above. A copy is kept in this register: 6384caa7b1938818-bbr_v6_13.10.2025_ma.pdf (SHA-256 6384caa7b19388180b780ec19044e1261cae3021c63c670f14ceb35285107022, copy of the official file).
3. Open AIFC Banking Business Prudential Rules No. FR0023 of 2018 and find BBR with amendments as of 9 December 2022 (V5), cover; BBR with amendments as of 9 December 2022 (V5), 4.36. Compare the text with the quotation above. A copy is kept in this register: 1187cdd64a39a84a-aifc-banking-business-prudential-rules-no.-fr0023-of-2018-1-1.pdf (SHA-256 1187cdd64a39a84a473544bf619bcff39fe26c0a29b864a12448dba8fe1b4b58, copy of the official file).
4. Open AIFC Banking Business Prudential Rules (with amendments as of 12 December 2021, which commence on 12 December 2021) and find BBR with amendments as of 12 December 2021, 4.36. Compare the text with the quotation above. A copy is kept in this register: 32ee1e4f68f9d79d-aifc-banking-business-prudential-rules-with-amendments-as-of-12-december-2021-which-commence-on-12-december-2021.pdf (SHA-256 32ee1e4f68f9d79d95328ac2485e7e97664a048f44849b746e4b138da060ee8e, copy of the official file).
5. Open AIFC Banking Business Prudential Rules (initial release) and find BBR initial release (30.07.2018), 1.4(3). Compare the text with the quotation above. A copy is kept in this register: 98b7b073c608c478-aifc-banking-business-prudential-rules-initial-release.pdf (SHA-256 98b7b073c608c47878220496c5eb68a691787f91338a1486f44a3e991b164e90, copy of the official file).
6. 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.

Documents and reproduction

• AIFC BANKING PRUDENTIAL GUIDELINE
• AIFC Banking Prudential Rules_V6 (with amendments as of 13 April 2025, which commence on 13 October 2025)
• AIFC Banking Business Prudential Rules No. FR0023 of 2018
• AIFC Banking Business Prudential Rules (with amendments as of 12 December 2021, which commence on 12 December 2021)
• AIFC Banking Business Prudential Rules (initial release)

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-2026-0130, https://arxo.io/findings/ARXO-2026-0130/ (status as of 2026-10-24). Data: ARXO-2026-0130.json.