Non-passporting licence routeDigital asset service provider licenceNo passporting

DASP Licence in Kazakhstan

Kazakhstan is an AFSA/AIFC route for Digital Asset Service Provider operations. It can support AIFC-based digital asset models, but it requires local substance, audit planning, capital and banking readiness and does not provide EU passporting.

Processing time
From 3 months
Service price
25 100 EUR
Required share capital
100,000 USD
State fee
2 000 USD
Annual supervision fee
3 000 USD
Banking difficulty
Medium
RegulatorAstana Financial Services Authority (AFSA)
Market access
No passporting

Regulatory status should be confirmed by local counsel before relying on this route.

What is a Kazakhstan DASP licence?

Kazakhstan DASP is a Digital Asset Service Provider licence route connected to AFSA and the AIFC. It should be assessed as a regulated AIFC operating setup with a defined provider scope, not as a broad offshore VASP label.

DASP
Jurisdiction
Kazakhstan
Regulator
Astana Financial Services Authority (AFSA)
Regime
DASP
Legal basis
Regulator: Astana Financial Services Authority (AFSA).

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

AFSA/AIFC provider scope boundary

The useful first question is whether the planned activity belongs inside the AIFC DASP perimeter. Exchange, custody, wallet, brokerage-like and payment-adjacent flows can each change the licence file, control framework and banking discussion.

  • Exchange

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • Custody

    Conditional

    Custody may require separate review or additional controls.

  • Brokerage

    Conditional

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • EU market

    Not covered

    EU passporting not available from this route.

  • Startups

    Conditional

    High setup complexity means significant budget is needed.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Kazakhstan DASP market angle

Kazakhstan is most relevant when the business case is AIFC-based digital asset operations with a regulator-facing setup, local presence and operational controls. It is weaker when the commercial goal is EU market access or a light-touch offshore story.

  • Market fit

    Positive: AFSA/AIFC framing gives the route a defined institutional context.

    Positive
  • Operating context

    Practical fit: projects that can maintain office, local staff, audit and capital requirements.

    Caution
  • Regulatory signal

    Boundary: no passporting and no automatic acceptance by EU banks, PSPs or counterparties.

    Caution

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Kazakhstan DASP application bottlenecks

The application can stall if the AIFC operating model, provider scope, local substance or financial crime controls are still abstract when the file is prepared.

  • Unclear boundary between DASP activities and securities, derivatives, investment or payment services.

    High

  • Office, local staff and governance plan not aligned with the proposed activity.

    High

  • AML, sanctions, transaction monitoring and custody controls not documented in operational detail.

    High

  • Capital, audit and ongoing compliance budget treated as one-off setup items.

    High

  • Banking and PSP assumptions left until after the regulatory file is submitted.

    High

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

When Kazakhstan DASP is not enough

Kazakhstan DASP is not the right answer for every crypto project. It should be rejected early when the business needs passporting, an EU regulatory perimeter or activity types outside the DASP scope.

  • The project needs EU/EEA passporting or MiCA/CASP market coverage.

  • The business model includes securities, derivatives, investment advice or regulated payment services.

  • The team cannot maintain AIFC-facing office, staff, audit, compliance and capital commitments.

  • The launch depends on guaranteed banking or immediate institutional counterparty acceptance.

Consider instead

  • Malta (MiCA) MICA — EU/EEA passporting and MiCA/CASP scope
  • Dubai (VASP) VASP — Recognised non-EU regulated route for regional operations
  • El Salvador (DASP) DASP — DASP-specific route for digital asset provider and bitcoin-adjacent models

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Conditional

Exchange activity may require additional scope or separate licensing.

Custody
Conditional

Custody may require separate review or additional controls.

Brokerage
Conditional

Brokerage or OTC activity typically fits within scope.

Wallet provider
Conditional

Exchange activity may require additional scope or separate licensing.

EU market
Not suitable

EU passporting not available from this route.

Startups
Conditional

High setup complexity means significant budget is needed.

Not sure if your model fits? Request a licensing assessment

Business model fit — Kazakhstan

Assess how well this route covers your planned activities.

Fit score

Good fit
0/6
Partial fit
6/6
Poor fit
0/6

Kazakhstan may not cover your primary activities

Consider an alternative route that better matches your activity profile.

Is Kazakhstan DASP authorisation right for your project?

Best for

  • AIFC digital asset service provider operations

Not suitable for

  • EU passporting

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capital100,000 USD
Required
Local staffRequired
Required
Physical officeRequired
Required
AuditRequired
Required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Office, staff, audit and capital

The CSV profile points to a substance-heavy route compared with lighter registrations. A credible file should budget for physical office, local staff, audit, compliance ownership and 100,000 USD required share capital.

Local staff

Required

Required

At least one locally-accountable staff member or director is expected.

Physical office

Required

Required

A genuine office presence is expected, not a nominal registered address.

Audit

Required

Required

External audit is required for ongoing supervision compliance.

Planning notes

  • Physical office: required.
  • Local staff: required.
  • Audit: required.
  • Required share capital: 100,000 USD.
  • Annual supervision fee: 3000 USD, with a separate 2000 USD state fee in the CSV snapshot.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
25 100 EUR EURFixed
State fee
2 000 USDFrom
Annual supervision feeRecurring annual cost after authorisation.
3 000 USDFrom
Required share capitalMust be held, not an expenditure.
100,000 USDFrom
Medium ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — Kazakhstan

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€25,100
State fee€2,000
Required share capitalMust be held, not an expenditure.€100,000

Summary

One-off costs
€127,100
Annual (year 1)
€0
Total year 1
€127,100

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Kazakhstan — From 3 months.

Total timelineFrom 3 months

  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in Kazakhstan

    2–6 weeks

    Establish legal entity, appoint local staff and set up local operating structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to Astana Financial Services Authority

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 3 months

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and payment provider readiness

Banking difficulty and payment provider availability are both marked as medium. Treat this as a preparation workstream, not a post-licence afterthought.

Banking difficulty
Medium

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Medium PSP availability
Medium

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Prepare transaction flow diagrams, source-of-funds logic, token policy and customer risk segmentation.
  • Document custody, fiat rails, treasury controls and counterparty screening before approaching banks or PSPs.
  • Avoid promising bank account opening or payment provider onboarding as an automatic result of the DASP licence.

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure
  • Required
    Annual external audit engagementRequired for ongoing supervision compliance.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 12 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Regulator profile

Regulatory authority · Kazakhstan

Astana Financial Services Authority (AFSA)

Regulatory reputation
Medium

Moderate reputation; assess banking and partner acceptance case by case.

Setup complexity
Medium

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
Medium

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Risk assessment

Main risk dimensions for the Kazakhstan route.

Regulatory reputation
High

Route risk rating — regulatory reputation: Medium to high.

Regulatory risk
Medium

Route risk rating — regulatory risk: Medium. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

Banking difficulty
Medium

Route risk rating — banking difficulty: Medium. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

Setup complexity
Medium

Route risk rating — setup complexity: Medium.

Maintenance cost
Medium

Route risk rating — maintenance cost: Medium. Budget for ongoing compliance, fees and supervision separately.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

Kazakhstan DASP vs alternatives

Compare Kazakhstan with MiCA/CASP where EU access matters, Dubai VASP for a higher-profile non-EU route, and El Salvador DASP where bitcoin-adjacent positioning is the main driver.

Current

Kazakhstan

DASP

Price
25 100 EUR
Timeline
From 3 months
Passporting
No passporting
Banking
Medium
Reputation
Medium to high

Malta (MiCA)

MICA

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium
Reputation
High

+ EU/EEA passporting and MiCA/CASP scope

− Higher EU compliance and substance burden

View route

Dubai (VASP)

VASP

Price
22 300 EUR
Timeline
From 6 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Recognised non-EU regulated route for regional operations

− Higher setup and ongoing regulatory workload

View route

El Salvador (DASP)

DASP

Price
17 800 EUR
Timeline
From 3 months
Passporting
No passporting
Banking
Medium to high
Reputation
Medium

+ DASP-specific route for digital asset provider and bitcoin-adjacent models

− Weaker fit for conservative banking-dependent projects

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Kazakhstan vs other DASP routes

Compare digital asset service provider routes by scope, timing and banking friction.

Sort by:
KazakhstanCurrent
Price25 100 EUR
TimelineFrom 3 months
BankingMedium
ReputationMedium to high
Malta
Price20 700 EUR
TimelineFrom 6 months
BankingMedium
ReputationHigh
Dubai
Price22 300 EUR
TimelineFrom 6 months
BankingMedium
ReputationHigh
El Salvador
Price17 800 EUR
TimelineFrom 3 months
BankingMedium to high
ReputationMedium

Check your readiness for Kazakhstan DASP licensing

Documented AML/CFT policies, risk assessment, compliance officer.

Share capital

100,000 USD minimum capital required.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Local substance plan

Local staff and office in Kazakhstan.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

No. Kazakhstan DASP is a local AFSA/AIFC route and should not be used as a substitute for MiCA/CASP where EU/EEA market access is required.

It can be suitable for AIFC digital asset service provider operations, including exchange, custody, wallet or brokerage-like models, if the exact scope, controls and banking assumptions are reviewed first.

Yes. The CSV profile marks physical office, local staff and audit as required, with required share capital of 100,000 USD.

Common blockers are unclear provider scope, weak AML or custody documentation, incomplete local substance planning, unresolved audit and capital arrangements, and banking or PSP readiness left too late.

Do not assume that it can. Securities, derivatives, investment products, regulated payments and similar activities need separate legal review before they are positioned under this route.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

Your dedicated specialists

  • Enrico Kärvinen

    Enrico

  • Rein Tammik

    Rein

  • Jurata Žukaitė

    Jurata

  • Andrej Kazlauskas

    Andrej

  • Marta Värna

    Marta

  • Katrin Lepik

    Katrin

  • Inga Stankavičiūtė

    Inga

Request a Kazakhstan DASP assessment

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