Currency control in Kazakhstan: when a contract needs a registration number

Who is under currency control

The rules apply to residents: companies formed under Kazakh law and based in Kazakhstan, together with their branches. A foreign-owned LLP is a resident like any other. Since 19 March 2026 branches and representative offices of foreign non-financial companies also count as residents, and so does every Kazakh citizen, even one with a residence permit abroad. Branches and representative offices of foreign organisations still don't have to repatriate proceeds: Article 9(2) of the law leaves them out of that duty.

The legal base is the Law “On currency regulation and currency control” No. 167-VI, the National Bank's rules on currency operations and the joint rules on export-import currency control in force since 1 January 2024. Banks act as currency control agents. Whether export proceeds came back is checked by the tax authorities, not the National Bank, since the same date.

When a contract needs a registration number

An export or import contract with a non-resident needs a registration number, called UNK in Russian-language documents, when:

• its amount exceeds $50,000 equivalent, converted at the official rate on the date of signing;
• or it states no amount at all, as many framework agreements do.

Goods, works and services all count, so a software development contract with a US client is an export contract. You apply to the bank that services the contract before either side starts performing. The bank checks the contract and assigns the number within 2 business days, and each contract gets one number. If all payments go through the company's account in a foreign bank, in the cases the law allows, the number comes from the National Bank's regional branch instead.

Banks check for the number. It must be quoted in every payment order under the contract, and an incoming payment the bank can't identify goes back to the sender after 180 days. Both rules come from items 5–6 of the National Bank's Rules of currency operations (Resolution No. 40).

Repatriation: the deadline you set yourself

Repatriation means the money under the contract comes back to the company's account at a Kazakh bank: export proceeds, or an import advance if the foreign supplier didn't deliver. The law sets no single term. The company works out the deadline from the contract's own payment and delivery terms, following Appendix 1 to the export-import rules. So write realistic terms into the contract: a 30-day payment term that the client routinely stretches to 90 days becomes a breach on paper.

The deadline can move because of a supplementary agreement, a court, arbitration or state body decision, the counterparty's liquidation or bankruptcy, or force majeure. Give the documents to the bank by the last day of the month in which the deadline expires with more than $50,000 outstanding. An extension for force majeure, or under a court decision or bankruptcy document that sets no date, is capped at 3 years. When more than $50,000 remains unreturned after the deadline, the case goes to the tax authorities, and a court can fine the company 20% of the unreturned sum.

What to write into a contract with a non-resident

• The amount, or a clear way to calculate it, so you know whether the $50,000 threshold applies.
• Payment and delivery terms that match how the client really pays, because the repatriation deadline is built from them.
• How services are confirmed, with signed acts or invoices, so the date of delivery is clear.
• The currency of the contract and the bank details of both sides, which must match the payment orders.

Loans, investments and foreign bank accounts

Capital movement deals go to the National Bank, not to your bank.

• Loans and investments. A loan from a foreign parent, an investment in the LLP's capital or another capital-flow contract above $500,000, or without an amount, needs a National Bank registration number before money moves. The number is issued within 5 business days, and you can apply at the regional branch or online through the National Bank's portal.
• Foreign bank accounts. An LLP that opens an account abroad, at a US bank or a fintech, must get a registration number for it from the National Bank before the first transaction. Every quarter, by the 10th of the following month, it reports the movement of money on that account, even with zero turnover.

Individuals don't register their foreign accounts this way. But a founder who is a Kazakh tax resident files declaration 270.00 when foreign bank balances exceed 1,000 MCI in total on 31 December, and a stake in a foreign company is a separate reason to file.

Two rules that surprise foreign founders

First, two Kazakh residents generally may not settle with each other in foreign currency. Article 6 of the law bans currency operations between residents, with a closed list of exceptions, so paying a Kazakh contractor in dollars is usually a breach.

Second, the data now moves on its own. Since 1 March 2026 the National Bank, the tax service and banks exchange contract numbers, customs declarations and e-invoices daily. Banks also report companies' foreign currency operations from $50,000 to the National Bank every month. A missing number or an overdue payment now shows up in the tax service's own data. We put contract numbers and repatriation dates into the same calendar as tax returns in our accounting service, and prepare contracts and answers to bank questions as part of our bank account support.

Sources

• Law No. 167-VI “On currency regulation and currency control”: Art. 1 (residents), Art. 6 (operations between residents), Art. 9 (repatriation, contract numbers), Art. 14 and 16 (capital movement, foreign accounts)
• National Bank of Kazakhstan, export-import currency control: joint Rules No. 78 / No. 1054, the $50,000 threshold, 2 business days
• National Bank of Kazakhstan, capital movement: the $500,000 threshold, foreign bank accounts, 5 business days
• Code of Administrative Offences: Art. 244 (procedure breaches), Art. 251 (failure to repatriate)
• Bank CenterCredit, currency law changes from 19 March 2026: new resident rules