PMS 2.4.2(1)(c): stablecoin criteria "in subrules (4) or (5)": (5) is a prior notice, and the reserve test in (4)(c) covers only Fiat stablecoins

PMS 2.4.2(1)(c) requires, for a Fiat or Commodity stablecoin, that "all of the requirements in subrules (4) or (5) as applicable are met". Subrule (4) gives reserve criteria, but its reserve-adequacy test in (4)(c) speaks only of "reserves in respect of Fiat stablecoins". Subrule (5) requires the provider to notify the AFSA at least 10 days before admission; it can be read as a condition of admission, but the text does not say when (5) applies instead of (4). No reserve-adequacy test is stated for Commodity stablecoins. DAA 2.8.2(1)(c) has the same wording (AIFC2-DAA-04).

Proposed correction

Please clarify when subrule (5) applies instead of subrule (4), and state the reserve test for Commodity stablecoins.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Providing Money Services (PMS)

Place

PMS 2.4.2(1)(c)

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.

for a Fiat or Commodity stablecoin, all of the requirements in subrules (4) or (5) as applicable are met

the Money Service Provider is required to notify the AFSA at least 10 (ten) days prior to the date of the admission

How to check it without Arxo's tools

1. Open AIFC Rules on Providing Money Services (with amendments as of 13 April 2025, which commence on 13 October 2025 and on 13 January 2026) and find PMS 2.4.2(1)(c); PMS 2.4.2(5). Compare the text with the quotation above. A copy is kept in this register: 333935eb310b57bc-pms-rulebook-25.05.2025_-v.1.pdf (SHA-256 333935eb310b57bcba51ab477b3e11e65a88e7ccf094eda06bc4e023e4fdac1a, 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 Providing Money Services (with amendments as of 13 April 2025, which commence on 13 October 2025 and on 13 January 2026)

Related records

• ARXO-2026-0152 — DAA 2.8.2(1)(c): stablecoin admission criteria "in (4) or (5)": (5) is a notice after admission, and the reserve test in (4)(c) covers only Fiat stablecoins

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-2026-0161, https://arxo.io/findings/ARXO-2026-0161/ (status as of 2026-10-24). Data: ARXO-2026-0161.json.