DAA 4.7.2: annual reserve audit may end 4 months after year end, but its result is due 4 weeks after the 'reference date of the valuation'

DAA 4.7.2(1) requires the issuer to "mandate an independent third party audit of the reserve assets annually but not later than four months after the close of its financial year"; 4.7.2(2) requires the result to be provided "at the latest within 4 weeks of the reference date of the valuation". "Reference date of the valuation" is not defined, and (1) does not say whether the four months apply to commissioning or to completing the audit. If the reference date is the financial-year end, the result could be due before the audit has to be done.

Proposed correction

Please define the reference date of the valuation and clarify whether the four-month period concerns commissioning or completing the audit.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Digital Asset Activities (DAA), V5

Place

DAA V5, 4.7.2(1)

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

2026-10-24

Evidence

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

Issuer of a Fiat stablecoin or Commodity stablecoin must mandate an independent third party audit of the reserve assets annually but not later than four months after the close of its financial year.

The result of the audit conducted under (1) must be provided to the AFSA without delay, at the latest within 4 weeks of the reference date of the valuation.

How to check it without Arxo's tools

1. Open AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026) and find DAA V5, 4.7.2(1); DAA V5, 4.7.2(2). Compare the text with the quotation above. A copy is kept in this register: 4a5174f747a66c22-daa_v5_01.01.2026.pdf (SHA-256 4a5174f747a66c222093a9cbd075c58816f1761b7a3b2807f86f9b98ccf28557, 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.

Documents and reproduction

• AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026)

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-2026-0153, https://arxo.io/findings/ARXO-2026-0153/ (status as of 2026-10-24). Data: ARXO-2026-0153.json.