NSFR required stable funding: unencumbered HQLA securities with a residual maturity of one year or more fall within the descriptions of two RSF categories

Under BPG Chapter 9 paragraph 177(a) each asset is assigned to one of the eight RSF categories, and BBR 9.19(2) requires the NSFR to be calculated in accordance with Chapter 9 of the BPG (it refers to Section E; the NSFR methodology is in Section H). Paragraph 179 assigns unencumbered Level 1 HQLA to Category 2 (5%), paragraphs 181 and 182(a) assign Level 2A and 2B HQLA to Categories 4 and 5 (15% and 50%), and paragraph 184(c) assigns 'unencumbered securities with residual maturity of 1 year or more' to Category 7 (85%). Unlike paragraph 184(d) and row 24 of the disclosure template Table 13, paragraph 184(c) does not exclude securities that qualify as HQLA, and no rule sets which description prevails. For a bank with available stable funding of USD 1,000 million, other required stable funding of USD 700 million and an unencumbered five-year Level 1 government bond of USD 500 million, the NSFR is 137.9% under paragraph 179 and 88.9% under paragraph 184(c). Form 201 in the Manual for Preparation of Returns repeats both lines (10.1 and 15.3), and IBB Appendix 1 paragraphs 131 and 136(c) repeat the same overlap (for an Islamic Bank, for example a Level 1 sovereign sukuk).

Proposed correction

Please consider assigning HQLA securities to one category unambiguously, for example by excluding securities that qualify as HQLA from BPG Chapter 9 paragraph 184(c), as paragraph 184(d) and Table 13 row 24 do, and from IBB Appendix 1 paragraph 136(c), and aligning Form 201 line 15.3.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Banking Business Prudential Rules (BBR), V6

Place

BPG Chapter 9 para 177(a), p.120

Record

Discrepancy

Class

Text of the act

Where it arose

The text of the act

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-25

Evidence

Reproduced by execution. Quotations are verbatim from the official material; translations are ours and marked.

assign each of the Bank’s assets to 1 of the 8 categories set out in paragraphs 178 to 185 of this Chapter of the BPG

unencumbered level 1 HQLA (except assets that receive a 0% RSF factor under paragraph

unencumbered securities with residual maturity of 1 year or more;

exchange-traded equities that are not in default and do not qualify as HQLA;

A Bank must calculate its NSFR using the following formula and in accordance with the methodology, formulae, parameters and guidance set out in Section E of Chapter 9 of the BPG issued by the AFSA.

unencumbered level 1 HQLA (except assets that receive a 0% RSF factor under paragraph

unencumbered securities with residual maturity of 1 year or more;

How to check it without Arxo's tools

1. Open AIFC BANKING PRUDENTIAL GUIDELINE and find BPG Chapter 9 para 177(a), p.120; BPG Chapter 9 para 179 (Category 2, 5%), p.121; BPG Chapter 9 para 184(c) (Category 7, 85%), p.122; BPG Chapter 9 para 184(d). 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 9.19(2), p.85. 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 Islamic Banking Business Prudential Rules and find IBB Appendix 1 para 131, p.189 (sister rule); IBB Appendix 1 para 136(c), p.189 (sister rule). Compare the text with the quotation above. A copy is kept in this register: e8b3c15b1ff574fd-aifc-islamic-banking-business-prudential-rules.pdf (SHA-256 e8b3c15b1ff574fd59504ade7cc9e0488ed5fa6ecfdc7816e3dc603bf4caedeb, 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) — 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 Islamic Banking Business Prudential Rules

History

1. 2026-10-25Confirmed 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-2026-0146, https://arxo.io/findings/ARXO-2026-0146/ (status as of 2026-10-25). Data: ARXO-2026-0146.json.