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Obtaining licenses and permits in Kazakhstan

28.02.2022

In Kazakhstan, construction, hazardous waste processing, alcohol trade, education, healthcare and the export and import of certain goods are allowed only with a license, a second-category permit or after notifying a government agency. KORGAN Law Firm determines what your business needs, prepares the company to meet the qualification requirements, files the application and follows it through until the license is issued, and then helps you keep it: reissue it after a reorganization or a change of details, remedy violations, and challenge a refusal, suspension or revocation.

What we do

Licenses — in architecture, urban planning and construction, industry, education, healthcare, transport, environmental protection, alcohol products, export and import and other areas.
License for construction and installation works and design activities of categories I, II and III — on a separate page, “Registration of licenses for construction and installation works“.
License annexes — new sub-types of activity added to an existing license.
Second-category permits and notifications — when no license is required, but you cannot operate without a permit or a notification.
License reissue — after a reorganization or a change of name or address.
License protection — remedying violations after a suspension, appealing a refusal, suspension or revocation.
Support for construction companies — partners holding licenses of the required categories and staff training: “Maintenance of construction activities“.

License, permit or notification

The Law “On Permits and Notifications” divides permits into three types:

License — a first-category permit for activities involving a high level of danger (subparagraph 6 of Article 1 of the Law). The licensing areas are listed in Article 28 of the Law, and the specific licenses and their sub-types in Annex 1 to it.
Second-category permit — issued through a permit procedure; the list is in Annex 2.
Notification — the activity may start right after the notification is sent, unless a law provides otherwise (paragraph 4 of Article 46). The exhaustive list is in Annex 3.

Licenses, permits and notifications are processed electronically through the state digital system of permits and notifications, and an electronic license is equivalent to a paper one (paragraph 1 of Article 48). A license is valid throughout Kazakhstan (paragraph 3 of Article 22) and is issued for an unlimited period unless Annex 1 provides otherwise (paragraph 7 of Article 29). A license cannot be transferred to another person, except for certain licenses for facilities (paragraph 8 of Article 29).

How we obtain a license

We determine the type and sub-types of activity. Using Annex 1 to the Law, we find the license and sub-types that cover your work and the licensor — the government agency that issues it.
We check the company against the qualification requirements. These are specialists, premises, equipment and experience; the requirements differ for each type of activity and must be met not only when the license is issued but for as long as it is valid (subparagraph 2 of Article 1). We tell you in advance, before filing, what is missing.
We prepare the documents. An application, a document confirming payment of the license fee (unless the fee is paid through the e-government payment gateway) and documents confirming compliance with the qualification requirements. A copy of the charter is attached only for the financial sector, the circulation of weapons and narcotic drugs, and security services (paragraph 3 of Article 29). Information available in state databases is obtained by the licensor itself (paragraph 4 of Article 29). The license fee rate is set by the Tax Code (Article 31 of the Law).
We file the application and respond to requests. If the license requires approvals from other government agencies, the licensor requests them itself (Article 25).
We obtain the license. The license or a reasoned refusal is issued within 15 working days. For atomic energy, the financial sector, education and hydrocarbons, the period is up to 30 working days (Article 30). If neither the license nor a refusal is issued on time, the license is, as a general rule, deemed issued, except in cases marked in the annexes to the Law (Article 26).

Why licenses are refused

The grounds for refusing a license are listed in Article 32 of the Law; additional grounds exist only in the financial sector and for the export and import of specific goods:

the activity is prohibited by law for this category of persons;
the license fee has not been paid;
the applicant does not meet the qualification requirements;
an approving government agency has responded that the applicant does not meet the requirements;
there is an effective court decision suspending or prohibiting the activity;
a court, at the request of a bailiff, has temporarily prohibited issuing a license to the applicant-debtor;
the documents or the information in them are unreliable.

A refusal must be reasoned. It can be appealed — first to a higher authority, then in court: “Disputes with government agencies“.

License reissue and reorganization

A license is reissued when the name or location of a legal entity or the details of an individual entrepreneur change, after a reorganization and in other cases listed in paragraph 1 of Article 33 of the Law. The application is filed within 30 calendar days of the change, the license is reissued within three working days, and the qualification requirements are not checked again. A license fee is payable for reissuing a license (Articles 31 and 33). In construction, a license is also reissued when the composition of the founders changes, and then compliance with the qualification requirements is checked (paragraphs 6 and 7 of Article 55 of the Construction Code).

In a reorganization, everything depends on its form (Article 34):

merger and transformation — the license is reissued to the new legal entity; when several licensees with the same license merge, only one is reissued, at the applicant’s choice;
accession — the license of the acceded company is reissued to the company it joined, unless the latter already holds the same license;
spin-off and division — the license is reissued to only one new legal entity and only if that entity itself meets the qualification requirements; a spin-off also requires the consent of the company it was separated from. The application is filed within 30 calendar days after the reorganization is completed, and reissue takes up to 15 working days.

We handle the reorganization and the license reissue together: “Liquidation and reorganization of LLPs in Kazakhstan“.

Suspension and revocation of a license

A license is suspended so that the licensee can remedy violations. While the license is suspended, you cannot operate under it. If the violations are remedied before the suspension period ends, an application with supporting documents is filed: the agency reviews it within ten working days and reinstates the license. If no application is filed, within ten working days after the period ends the agency initiates revocation, and in that procedure you can still prove that the violation has been remedied (Article 45).

In construction, compliance is checked by an automated register. It sends a notice to remedy violations by itself; failure to comply leads to suspension, failure to comply with the suspension leads to revocation, and two or more violations within a year lead directly to revocation (Article 51 of the Construction Code). The requirements include attested (certified) specialists: they must be part of the company and may not work part-time for other such organizations (paragraph 3 of Article 55 of the Code). More details — “Introduction of an automated register of licenses in the architectural and construction sphere“.

A license terminates, among other cases, when a legal entity is liquidated, at the licensee’s own request and after revocation (Article 35).

License for construction and installation works

A license for design activities and construction and installation works is issued by category (paragraph 2 of Article 55 of the Construction Code; since July 1, 2026 it has replaced the Law “On Architectural, Urban Planning and Construction Activities”):

Category III — facilities of the third level of responsibility; on facilities of the first and second levels — under subcontracts;
Category II — facilities of the second and third levels; on facilities of the first level — under subcontracts;
Category I — facilities of all levels of responsibility.

The licensor determines the category when issuing the license based on the qualification requirements and specifies it in the special conditions of the license. Requirements for category II — experience and completed facilities — in the article “Category II license for construction and installation works“. Requirements for specialists, production base, machinery and experience for each category, documents and procedure — on the page “Registration of licenses for construction and installation works“.

License for hazardous waste operations

Collection, transportation, recovery, neutralization and disposal of hazardous waste is a sub-type of the license to perform work and provide services in the field of environmental protection (Annex 1 to the Law). Operations with non-hazardous waste — collection, sorting, transportation, recovery and destruction — are carried out under a notification of the start or termination of activity (Annex 3).

From our practice

A license for the storage and wholesale of alcoholic products for an LLP with Russian participants.
Category III licenses for construction and installation works for several Kazakh LLPs and a category III license for design activities.
A category II license for construction and installation works — “Category II license for construction and installation works“.
A waste disposal license: obtaining it took about 8–9 months — “Obtained a license for waste disposal“.

Cost

The cost depends on the type of license, the number of sub-types and how far the company already meets the qualification requirements, and is agreed before work begins. The license fee is paid separately.

Frequently asked questions

How long does it take to obtain a license?

By law, the license or a reasoned refusal is issued within 15 working days of the application; for atomic energy, the financial sector, education and hydrocarbons, within up to 30 working days (Article 30 of the Law “On Permits and Notifications”). Preparing the company to meet the qualification requirements takes extra time, depending on what is missing. In our practice, obtaining a waste disposal license took about 8–9 months.

What documents are required for a license?

An application, a document confirming payment of the license fee if the fee is not paid through the e-government payment gateway, and documents confirming compliance with the qualification requirements. A copy of the charter is attached only in the financial sector and for arms, narcotics and security activities. The licensor obtains information from state databases on its own (Article 29 of the Law).

What is the difference between a license, a second-category permit and a notification?

A license is a first-category permit for activities involving a high level of danger; the list is in Annex 1 to the Law. A second-category permit is issued through a permit procedure; the list is in Annex 2. Under a notification, the activity may start right after the notification is sent; the list is in Annex 3.

Which category of construction and installation license do I need?

It depends on the level of responsibility of the facilities. Category III covers facilities of the third level, category II — the second and third levels, category I — facilities of all levels; on facilities above your category you can work under subcontracts. The licensor determines the category based on the qualification requirements (paragraph 2 of Article 55 of the Construction Code). More — “Registration of licenses for construction and installation works”.

Is a license required for waste operations?

For hazardous waste, yes: its collection, transportation, recovery, neutralization and disposal is a sub-type of the environmental protection license (Annex 1 to the Law). Operations with non-hazardous waste are carried out under a notification of the start of activity (Annex 3).

Does a license have to be reissued after a change of name, address or a reorganization?

Yes. The application is filed within 30 calendar days of the change, the license is reissued within three working days, and the qualification requirements are not checked again (Article 33 of the Law). After a spin-off or division, the license is reissued to only one new legal entity and only if it meets the requirements itself, within up to 15 working days (Article 34).

How long is a license valid and where?

A license is issued for an unlimited period unless Annex 1 to the Law provides otherwise, and is valid throughout Kazakhstan. It cannot be transferred to another person, except for certain licenses for facilities (paragraph 3 of Article 22, subparagraphs 7–8 of Article 29 of the Law).

To discuss a license for your company, call us: +7 700 500 05 53, or leave a request on the website.

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