License Refusal and Revocation in Kazakhstan: How to Challenge the Decision

02.08.2026

A license is often the company’s very right to operate. A refusal, a suspension or a revocation hits the business at once: contracts stop and deals fall through. But the licensing authority’s decision is not the end. It can be challenged, and in the case of a refusal you can get a court to order the authority to issue the license. Here are the grounds the law allows for refusing and revoking a license in Kazakhstan, and how to appeal each decision.

The 30-second summary

• A license may be refused only on the grounds listed in Article 32 of the Law of the Republic of Kazakhstan “On Permits and Notifications” — there are seven. The refusal must be reasoned and is issued within the time limit for issuing the license: as a rule, 15 business days (Article 30, Article 32(3)).
• If neither the license nor a reasoned refusal is issued on time, the license is, as a general rule, deemed issued (Article 26).
• A refusal is appealed under the Administrative Procedural and Process Code (APPC): a complaint no later than 3 months after learning of the decision (Article 92 of the APPC), review within 20 business days with no extension unless a law provides otherwise (Article 99), then a court claim within one month (Article 136).
• If the license was suspended or revoked as an administrative penalty under the Code of Administrative Offences (CAO), the ruling in the case is appealed within 10 days (Article 826-2 of the CAO). The APPC procedure does not apply to such cases.
• When a license is refused, ask the court not only to cancel the refusal but to order the authority to issue the license: this is a claim to compel (Article 133 of the APPC).

This is general information, not legal advice on your specific case. We checked the provisions against the texts of the laws, linked in the text. It is best to show the actual decision to a lawyer.

Three situations, three ways to appeal

First, establish exactly what happened and what document it was recorded in: both the deadline and the procedure depend on it.

Situation	Main provision	How to appeal	Complaint deadline
Refusal to issue a license	Article 32 of the Law on Permits	complaint to the higher authority, then a claim under the APPC	3 months
Suspension or revocation by the licensing authority’s decision under a law	Article 45 of the Law on Permits and the sector law	complaint, then a claim under the APPC	3 months
Suspension or revocation as an administrative penalty	Article 47 of the CAO	complaint against the ruling in an administrative offence case under the CAO	10 days

All three scenarios are governed by the Law of the Republic of Kazakhstan “On Permits and Notifications” No. 202-V of 16 May 2014, and the appeal by the Administrative Procedural and Process Code or the Code of Administrative Offences.

Refusal to issue: on what grounds

A license or a reasoned refusal is issued no later than 15 business days. For atomic energy, the financial sector, education and hydrocarbons the period is 30 business days (Article 30). The refusal is given on paper or as an electronic document within the same period (Article 32(3)).

A license may be refused only in seven cases (Article 32(1)):

1. the activity is prohibited by law for this category of persons;
2. the license fee has not been paid;
3. the applicant does not meet the qualification requirements;
4. an approving state body has replied that the applicant does not meet the requirements;
5. there is a court decision (verdict) in force suspending or prohibiting this activity;
6. a court, at the request of a bailiff, has temporarily prohibited issuing a license to the applicant as a debtor;
7. the documents submitted or the information in them have been found to be false.

Additional grounds exist only for the financial sector and for the export and import of controlled goods (Article 32(1)). If the refusal cites none of these grounds, or the ground is not supported, this is the main argument of the complaint. Typical grounds for a dispute are a refusal for “non-compliance with requirements” without saying which ones, and a reference to documents that were in fact submitted.

If the authority stays silent. If neither the license nor a reasoned refusal is issued within the set period, the license is deemed issued from the day the period expires and is entered in the state digital register of permits and notifications (Article 26(1)). The authority must issue it within 5 business days; if it does not, the document confirming acceptance of the application serves as proof that the activity is lawful (Article 26(2)). The rule does not apply to permits marked with a relevant note in Annexes 1 and 2 to the Law (Article 26(3)).

How to file for a license properly is covered on our service page “Obtaining licenses and permits in Kazakhstan“.

Suspension and revocation of a license

Under the Law on Permits. Suspension and revocation are applied in the manner and on the grounds provided by laws (Article 45(1) and 45(5)). So the ground has to be found in the law governing your sector, and its absence is an argument for a dispute. What the Law on Permits itself says:

• while the license is suspended, you may not operate under it unless a law provides otherwise (Article 45(2));
• the purpose of a suspension is to remove the causes of the violation (Article 45(2-1));
• having remedied the violations, the licensee files an application with supporting documents before the suspension period ends; the authority checks it within 10 business days and, if confirmed, reinstates the license (Article 45(3));
• if no application is filed, within 10 business days after the suspension period ends the authority starts the revocation procedure, but the licensee may still prove that the violation has been remedied (Article 45(4));
• revocation terminates the license (Article 35(1)(3)): from that moment the activity may no longer be carried out under it (Article 35(3)).

As an administrative penalty. The CAO provides for revoking or suspending a permit for an offence committed while carrying out the activity under that permit (Article 47(1) of the CAO). The penalty is imposed by a judge or the authorised body (Article 47(1-1)). A suspension lasts from 1 to 6 months (Article 47(2)). If the violation concerns a sub-type of the licensed activity, the penalty applies only to that sub-type (Article 47(7)) — a common error by authorities that is worth checking.

Proportionality: the authority must choose the milder measure

The APPC requires an administrative act to be proportionate: suitable, necessary and proportional. An act is necessary if it restricts the rights of the person concerned to the least possible extent (Article 10(1)–(2) of the APPC).

If the harshest measure was applied straight away, although the aim could have been achieved more gently — for example, by a suspension with the option to remedy the violations instead of a revocation — this is a strong argument for cancelling it.

Pre-trial complaint under the APPC

For a refusal, and for suspension or revocation decisions made under the APPC, the pre-trial procedure is mandatory:

• Where. The complaint is filed with the authority whose decision is being appealed. Within 3 business days it forwards the complaint with the file to the higher authority, which reviews it (Article 91(3)–(4) of the APPC). If the authority itself makes a decision within those 3 days that fully satisfies the complaint, it may not forward it (Article 91(4)).
• Court only after the complaint, unless a law provides otherwise (Article 91(5)). If there is no higher authority, the decision can be challenged in court directly (Article 91(6)).
• Filing deadline. No later than 3 months after learning of the decision, or no later than 6 months if the decision does not state how it can be appealed (Article 92(1) and 92(1-1)). A deadline missed for a valid reason can be restored (Article 92(2)), and a missed deadline is not in itself a reason to refuse to accept the complaint (Article 92(3)). But relying on this is risky.
• Enforcement is suspended. Filing a complaint suspends enforcement of the decision, except where needed to protect the rights of citizens and legal entities or public or state interests, for certain acts of the financial regulator and the National Bank, and in other cases provided by law (Article 96(1)). If an exception is applied, the authority must state it in the decision itself and justify it (Article 96(2)).
• Review period. 20 business days from registration of the complaint. It may not be extended except in cases established by law (Article 99).

If you go to court without a complaint, the claim will be returned as long as the pre-trial procedure is still available (Article 138(2)(1)). That is lost time.

Appeal under the CAO

If the license was suspended or revoked by a ruling in an administrative offence case, the procedure is different: the APPC does not apply to such cases (Article 3(4) of the APPC).

• A complaint against an authority’s ruling is filed within 10 days of receiving a copy of the ruling — through the authority that issued it, or directly with the higher authority (Article 826-2(1)–(2) of the CAO).
• A complaint against a court ruling is also filed within 10 days of its delivery (Article 832(1) of the CAO).
• A complaint filed on time suspends enforcement of the ruling until it is decided (Article 826-2(4) of the CAO).

10 days instead of 3 months — so the first thing to check is what the document you received is called.

Deadlines at a glance

Step	Deadline	Provision
Issue of a license or a reasoned refusal	15 business days (30 for atomic energy, finance, education, hydrocarbons)	Law on Permits, Article 30
Complaint against a refusal or an authority’s decision under the APPC	3 months from learning of the decision	APPC, Article 92(1)
Same, if the decision does not state how to appeal	6 months	APPC, Article 92(1-1)
Review of the complaint	20 business days, no extension unless a law provides otherwise	APPC, Article 99
Court claim after the complaint	one month from receipt of the decision on the complaint or after the review period expires	APPC, Article 136(1) and 136(6)
Check of an application to lift a suspension	10 business days	Law on Permits, Article 45(3)
Complaint against a ruling under the CAO	10 days from receipt of a copy	CAO, Articles 826-2 and 832

Choosing the right claim decides the outcome

The APPC offers several types of claim, and what you get depends on the choice:

Type of claim	When it applies	What it achieves
To challenge an act (Article 132)	suspension, revocation	cancels the decision in full or in part
To compel (Article 133)	refusal to issue, or inaction by the authority	orders the authority to adopt the required decision — to issue the license; no separate challenge to the refusal is needed
To perform an action (Article 134)	the license is deemed issued under Article 26 but the document has not been issued	orders the authority to provide the document (Article 134(2))

Claims to challenge and to compel are filed within one month of receiving the decision on the complaint (Article 136(1)); a claim to perform an action is filed within one month of learning of the action or of the deadline for it expiring (Article 136(2)).

In a claim to compel, the court orders the authority to adopt a decision and may itself set its content and the time limit for adopting it (Article 157(1)–(2) of the APPC). That is why, in the case of a refusal, an experienced lawyer does not stop at asking to “cancel” it but immediately asks the court to order the authority to issue the license.

Who proves what in court

In the administrative court the burden of proof is allocated by law (Article 129(2) of the APPC):

• in a claim challenging a suspension or revocation, the authority that made the decision must prove it was lawful;
• in a claim to compel, the authority proves the facts that served as grounds for the refusal, and the company proves the facts on which its right to the license is based, such as compliance with the qualification requirements.

The authority may rely only on the grounds stated in the decision itself (Article 129(3)): new reasons for the refusal will not help it in court. The court is not passive — if the evidence is insufficient, it collects evidence on its own (Article 130(2)).

Step-by-step defence plan

1. Identify the document. A refusal, a suspension or revocation decision under the Law on Permits, or a ruling under the CAO — this determines the deadline (3 months or 10 days) and the procedure.
2. Check the ground. Is it in Article 32 of the Law on Permits or in the sector law, is it supported by documents, were the deadlines and procedure followed, is the measure proportionate.
3. File the complaint. On time, and so that it suspends enforcement and lays the groundwork for court.
4. Gather evidence. Compliance with the qualification requirements, removal of violations, procedural errors by the authority.
5. Court. Choose the type of claim: to challenge, to compel or to perform an action.

When you need a lawyer

What is at stake is the business’s ability to operate, and the details decide the outcome. It is especially important to bring in a lawyer if:

• the license has already been suspended and every day of downtime means losses;
• it is unclear whether to appeal a decision under the APPC or a ruling under the CAO — the deadlines differ many times over;
• a refusal calls for an immediate claim to compel;
• the measure seems disproportionate, but proving it on your own is difficult.

How KORGAN helps in license disputes

KORGAN Law Firm has been working since 2014. In license disputes we:

• review the refusal, suspension or revocation and assess the prospects;
• determine the appeal procedure and the type of claim — up to compelling the authority to issue the license;
• prepare a complaint with suspension of enforcement in mind;
• prove that the measure is disproportionate and that the authority breached the procedure;
• handle the case at every stage, from the complaint to court.

More on the service pages “Obtaining licenses and permits in Kazakhstan” and “Disputes with government agencies: appealing inspections, orders and tax notices“. The general APPC appeal procedure is covered in our article “Disputes with Government Agencies: How a Business Can Challenge a Decision“, and all deadlines are collected in our checklist of appeal deadlines.

The first consultation is free.

To discuss your license decision: +7 700 500 05 53 or WhatsApp.

Frequently asked questions

Can a court force a government authority to issue a license it refused?

Yes. This is done through a claim to compel (Article 133 of the APPC): there is no need to challenge the refusal separately, and the court may order the authority to adopt a decision and set its content and time limit (Article 157 of the APPC). Unless a law provides otherwise, a complaint to the higher authority comes first.

What is the deadline for appealing a license refusal?

The complaint is due no later than 3 months after learning of the refusal, or 6 months if the refusal does not state how to appeal it (Article 92 of the APPC). The court claim is filed within one month of receiving the decision on the complaint (Article 136 of the APPC).

What is the deadline if the license was suspended under the CAO?

If the suspension or revocation was imposed by a ruling in an administrative offence case, the complaint is filed within 10 days of receiving a copy of the ruling (Article 826-2 of the CAO). The APPC procedure does not apply to such cases.

Is the decision suspended while it is being appealed?

Under the APPC, filing a complaint suspends enforcement of the decision, except in the cases listed in Article 96, and if an exception is applied the authority must state and justify it in the decision. Under the CAO, a complaint filed on time suspends enforcement of the ruling (Article 826-2 of the CAO).

Who has to prove that a license revocation was lawful?

In a claim to challenge it, the authority that made the decision, and it may rely only on the grounds stated in the decision itself (Article 129 of the APPC). In a claim to compel after a refusal, the burden is shared: the authority proves the grounds for refusal, and the company proves its right to the license.

What if the authority issued neither the license nor a refusal on time?

As a general rule, the license is deemed issued from the day the period expires, and the authority must issue it within 5 business days (Article 26 of the Law “On Permits and Notifications”). If the document is still not issued, you can file a claim to perform an action — to provide the document (Article 134(2) of the APPC).

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