Deadlines to Appeal Government Decisions in Kazakhstan, 2026: a Checklist
16.09.2026
A company can be right on the merits and still lose a dispute with a government agency before it ever reaches court: it missed a deadline, counted it from the wrong day or filed the complaint the wrong way. KORGAN, a law firm working since 2014, has put together in one place the deadlines you need to know when a decision from a Kazakhstan government agency arrives.
This is a checklist of deadlines. How the dispute itself works — the complaint, the lawsuit, who has to prove what — is covered in our article “Disputes with Government Agencies in Kazakhstan: How a Business Can Challenge a Decision“.
The 30-second summary
Under the general rule of the Administrative Procedural and Process Code (APPC), a government decision is first challenged by an administrative complaint and only then in court. The key deadlines:
- 3 months for a complaint, from the day you learned of the decision (Art. 92 APPC);
- 6 months if the decision does not say to whom, within what time and how it can be appealed (Art. 92(1-1));
- 20 working days for the complaint to be considered; they cannot be extended unless a law provides otherwise (Art. 99);
- 1 month to file a lawsuit after the decision on the complaint, or after the time for considering it has run out (Art. 136).
Tax notices, public procurement and fines have their own deadlines — see the table below.
This is general information, not legal advice on your specific case. We checked the deadlines against the texts of the codes and laws, linked at the end of the article. It is best to check the deadline for your specific document with a lawyer.
How it works
In a dispute with a government agency you generally cannot go straight to court: first comes an administrative (pre-trial) complaint, unless a law provides otherwise (Art. 91(5) APPC). The complaint is filed through the agency whose decision you are challenging: within three working days it must pass the complaint and the case file to the higher agency, which considers the complaint (Art. 91(3) and (4)). If there is no higher agency, the decision is challenged directly in court (Art. 91(6)). We can prepare the complaint and work out the deadline — see “Disputes with government agencies” — and, if the case goes to court, represent you in court.
Four numbers of the general procedure:
- 3 months — the complaint. The time runs not from the date of the decision but from the day you learned of it (Art. 92(1)). The difference can be several weeks.
- 6 months — if the decision does not explain how to appeal it. A decision must state the higher agency, the deadline and the procedure for appeal (Art. 80(5)). If it does not, you have six months to file a complaint (Art. 92(1-1)). This is the first thing to check in any document from a government agency.
- 20 working days — consideration of the complaint. No extension is allowed except in cases set by law (Art. 99). If there is no decision in time, the complaint is deemed rejected (Art. 100(5)).
- 1 month — the lawsuit. From the day the decision on the complaint is served, or, if there is none, after the time for considering it has expired (Art. 136(1) and (6)).
While the complaint is pending, enforcement of the challenged decision is generally suspended. The exceptions are the need to protect the rights of individuals and legal entities or public or state interests, certain acts of the financial regulator, the National Bank and state audit bodies, and other cases set by law (Art. 96).
Deadlines by category: summary table
| Category | Deadline for the first step | Where and how | Next |
|---|---|---|---|
| General procedure (APPC) | 3 months from the day you learned of it (Art. 92(1) APPC) | Through the agency whose decision is challenged; the higher agency considers it (Art. 91(3)–(4)) | Consideration: 20 working days (Art. 99); lawsuit: 1 month (Art. 136) |
| Decision that does not explain how to appeal | 6 months from the day you learned of it (Art. 92(1-1)) | Same | Same |
| Tax audit notice | 30 working days after the day the notice is served (Art. 192(1) Tax Code) | To the authorized body, with a copy to the tax authority that ran the audit (Art. 192(1)) | Consideration: no more than 30 working days, 45 for taxpayers under tax monitoring, not counting extensions and suspensions (Art. 195); lawsuit under the APPC (Art. 191) |
| Objection to a preliminary tax audit report | Set by the authorized body; the Tax Code itself does not give a number (Art. 169(2)) | To the tax authority running the audit | Then the audit report and the notice |
| Order issued after an inspection | 3 months from the day you learned of it (Art. 92(1) APPC) | Through the agency that issued the order, to the higher agency (Art. 91(4) APPC, Art. 157(1) Entrepreneurial Code) | An application to cancel it for gross violations during the inspection is considered by the higher agency within 10 working days (Art. 156(1) Entrepreneurial Code) |
| Refusal to issue a licence | 3 months from the day you learned of it (Art. 92(1) APPC) | Through the licensor to the higher agency | Consideration: 20 working days; lawsuit: 1 month |
| Results of public procurement by tender or auction | 3 working days from the day the results protocol is posted (Art. 25(1) Public Procurement Law) | Through the web portal — against actions and decisions of the customer, organiser or expert commission | Decision on the complaint within 3 working days after the filing deadline (Art. 25(2)); then court (Art. 25(3)) |
| Listing in the register of bad-faith participants for avoiding signing a contract | 10 working days from the day you learned of the listing (Art. 8(6) Public Procurement Law) | Petition to the conciliation commission | On other grounds, suppliers are listed only by a court decision (Art. 8(5)) |
| Fine: ruling in an administrative offence case | 10 days from the day a copy of the ruling is served; for violations found by a tax audit, 30 days (Art. 829-4(1)–(2) Code of Administrative Offences) | To a higher body (Art. 826-1, 826-2(1) Code of Administrative Offences, same deadlines) or straight to the court (Art. 829-2(4)) — through the body that issued the ruling or directly (Art. 829-3(1) and (3)) | This is the Code of Administrative Offences procedure, not the APPC; a prior appeal to a higher body is not required (Art. 829-2(5)) |
The shortest deadline is 3 working days in public procurement — less than a working week. More on such disputes — in our article “Public Procurement Disputes: Disqualification and Cancelled Results“, on tax disputes — in our guide “How to Appeal a Tax Audit Notice“, on orders — in our article “Appealing a Regulator’s Order“.
Fines are listed separately for a reason. The administrative procedures of the APPC do not apply to relations governed by the legislation on administrative offences (Art. 3(4)(1) APPC). A fine has its own deadlines and its own court, and the APPC deadlines do not apply to it.
7 mistakes that cost time and the right to protection
Mistake 1. Going straight to court. If the pre-trial procedure is mandatory and can still be used, the court returns the claim (Art. 138(2)(1) APPC). That alone is not the end: after the complaint, the claim can be filed again (Art. 138(3)). But time is lost, and after the complaint the lawsuit must be filed within a month.
Mistake 2. Counting from the date of the decision instead of the day you learned of it. Under the APPC, the complaint deadline runs from the day you learned of the decision (Art. 92(1)). For a tax audit notice and a fine ruling, however, it runs from the day of service (Art. 192(1) Tax Code, Art. 829-4(1) Code of Administrative Offences).
Mistake 3. Not checking whether the decision explains how to appeal it. If the document does not name the higher agency, the deadline and the procedure, you have six months for a complaint instead of three (Art. 92(1-1)).
Mistake 4. Applying APPC deadlines to a fine. A fine ruling is appealed under the Code of Administrative Offences: 10 days from service of a copy, 30 days for violations found by a tax audit (Art. 829-4). There are no three months here.
Mistake 5. Waiting for an official letter while the clock was running. Under the APPC the complaint deadline runs from the day you learned of the decision, not from the day the letter arrived. If you saw the decision in your online account or on a portal, count from that day.
Mistake 6. Filing the complaint the wrong way. As a rule, the complaint is filed through the agency whose decision is challenged, and the higher agency considers it (Art. 91(3)–(4) APPC). For a tax audit notice — to the authorized body, with a copy to the tax authority that ran the audit (Art. 192(1) Tax Code). For public procurement — through the web portal (Art. 25(1) Public Procurement Law).
Mistake 7. Skipping the objection to the preliminary tax audit report. The preliminary report is served before the audit report, and you may file a written objection to it (Art. 169(1) Tax Code). The deadline for the objection is set by the authorized body (Art. 169(2)), so check it as soon as the report is served. At this stage you can put your arguments on record before the audit ends.
From our practice: how one receipt changed the outcome
A client received an order from the urban development control authority. One of the alleged violations was that no notification of the start of construction works had been filed.
The notification had been filed, and the client had a receipt confirming it was accepted. In court, the authority argued that the notification was not in its electronic database. Our position: a business is not responsible for how a government agency keeps its database. The court agreed: that item of the order was struck out, and the demand to dismantle the fence was cancelled as disproportionate.
Keep everything: receipts, payment slips, screenshots showing acceptance. Under the APPC, documents you submit are considered reliable until the agency establishes otherwise (Art. 15), but you need to have them in hand.
What to do as soon as a government decision arrives
- Record the date you learned of or received the decision — the deadline runs from it.
- Check whether the decision names the higher agency, the deadline and the procedure for appeal (Art. 80(5) APPC).
- Find your category in the table above: general procedure, taxes, procurement or a fine.
- Do not file a lawsuit straight away if the law requires a complaint first.
- Gather documents confirming what you did: applications, receipts, correspondence.
- See a lawyer before the first deadline expires, not after.
If the deadline has already passed
It is not always the end.
- Complaint deadline. A missed deadline is not a ground for refusing to accept the complaint: the reasons are examined when it is considered and may become a ground for rejecting it (Art. 92(3) APPC). If the reason is valid — illness, force majeure or anything else that made filing impossible — the body considering the complaint may restore the deadline on a petition (Art. 92(2)). File the complaint together with the petition and supporting documents.
- Lawsuit deadline. A deadline missed for a valid reason is restored by the court; the reasons are examined at the preliminary hearing (Art. 136(7)). Missing it without a valid reason is a ground for returning the claim (Art. 136(8)), and the same claim cannot be filed again (Art. 138(3)).
- Tax audit notice. The complaint deadline is restored for one reason only — temporary incapacity for work of the head of the company, the chief accountant or the audited individual — and only if no one in the company can stand in for them; the petition must be filed no later than 10 working days after the incapacity ends (Art. 192(2)–(4) Tax Code).
Building your plan on restoring a deadline is risky: “we did not know” or “we did not find a lawyer in time” are usually not accepted as valid reasons.
Work with KORGAN
KORGAN has been working since 2014. We handle disputes with government agencies: tax audit notices, orders issued after inspections, licence refusals and public procurement.
- we tell you which deadline applies to your document and whether it has expired;
- we prepare the complaint through the agency whose decision you are challenging, or to the authorized tax body;
- if the complaint does not help, we represent the company in court — see representation in court.
How we handle these cases is described on the service page “Disputes with government agencies in Kazakhstan“.
The first consultation is free.
Phone and WhatsApp: +7 700 500 05 53
Or message us on WhatsApp. Other contacts are on our contacts page.
We checked the deadlines against the Administrative Procedural and Process Code, the Tax Code, the Entrepreneurial Code, the Law “On Public Procurement” and the Code of Administrative Offences of the Republic of Kazakhstan.
Frequently asked questions
When does the deadline to appeal a government decision start?
Under the APPC — from the day you learned of the decision, not from the date on the document (Art. 92(1)). For a tax audit notice and a fine ruling, it runs from the day of service.
What happens if I go to court without filing a complaint first?
If the pre-trial procedure is mandatory and can still be used, the court returns the claim (Art. 138(2)(1) APPC). After the complaint the claim can be filed again, but time will be lost.
How long do I have to appeal a fine?
10 days from service of a copy of the ruling, or 30 days for violations found by a tax audit (Art. 829-4 Code of Administrative Offences). A fine is appealed to the court under that Code; APPC deadlines do not apply.
Is it bad for me if the decision does not explain how to appeal it?
Quite the opposite: you have six months for a complaint instead of three (Art. 92(1-1) APPC). A decision must name the higher agency, the deadline and the procedure for appeal (Art. 80(5)).
Can a missed deadline be restored?
Yes, if the reason is valid: the complaint deadline is restored by the body considering the complaint (Art. 92(2) APPC), the lawsuit deadline by the court (Art. 136(7)). You need a petition and documents confirming the reason.
Which dispute has the shortest deadline?
Public procurement: a complaint about the results of a tender or auction is filed through the web portal within 3 working days of the results protocol being posted (Art. 25(1) Public Procurement Law).