AFSA introduces amendments to the AIFC Fees Rules
Following public consultation conducted from 2 October to 2 November 2025, the Astana Financial Services Authority (AFSA) has introduced amendments to the AIFC Fees Rules, with the majority of them taking effect from 1 December 2025 and some subject to deferred commencement dates.
Since their initial approval in December 2017, the AIFC Fees Rules have undergone a series of targeted updates to reflect evolving regulatory regime and market developments. Notwithstanding these amendments, the original fee levels have largely remained unchanged until these new amendments. Previous adjustments have been introduced only in a limited and proportionate manner, primarily in relation to supervision and registration fees.
Considering that the AIFC ecosystem has reached a more advanced stage of development, the new amendments introduce a substantially broader revision, affecting almost all fee categories. The growth of financial institutions and the increasing sophistication of their activities require AFSA to provide more comprehensive and technologically advanced regulatory and supervisory services, including the enhanced use of SupTech, artificial intelligence, and data-driven tools to strengthen supervisory capacity and improve the overall quality of regulation.
The updated AIFC Fees Rules aim to ensure that AFSA can continue to uphold high regulatory standards while supporting the sustainable development of the AIFC ecosystem.
On 2 October 2025, AFSA issued for public consultation a number of policy proposals on amendments to the AIFC Fees Rules. A substantial volume of feedback was received from a wide range of market participants, who generally recognised the need for an increase while also raising certain concerns and seeking clarification on some proposals. AFSA carefully reviewed and considered all comments received.
The majority of the initial proposals have been retained, as they were confirmed during the review to be proportionate and justified, and in many cases had already addressed a number of concerns raised through the public consultation. However, in light of certain comments and the practical realities faced by regulated entities, AFSA introduced targeted adjustments to a number of proposals.
As a result, the key amendments to the AIFC Fees Rules are as follows:
- The application fees for authorisation of Regulated Activities, Market Activities, Ancillary Services, Recognised Non-AIFC Market Institutions and Foreign Fund Managers have been increased at varying levels, as proposed in the consultation paper, to more accurately reflect the actual regulatory cost at the authorisation stage.
- Under the revised fee structure, firms applying for authorisation of more than one Regulated or Market Activity will pay the highest applicable application fee plus 50% for each additional activity. This better reflects the complexity of multi-activity applications and ensures a fairer allocation of regulatory costs.
- To ensure the recovery of actual supervisory costs, the annual fixed supervision fees for Regulated Activities, Market Activities and Ancillary Services as well as recognition fee for Recognised Non-AIFC Market Institutions have been increased at varying levels, as proposed in the consultation paper, and introduced for a number of Islamic finance licences that were not previously subject to supervision fees. With that recognising that the introduction of supervision fees for Islamic finance licences represents a new requirement for the sector and that firms may need time to adjust AFSA decided to defer the commencement date of supervision fees for these Islamic finance licences for one year.
- For five licence categories of Regulated Activities, including Managing a Collective Investment Scheme, Managing Investments, Dealing in Investments as Agent, Providing Fund Administration, and Providing Money Services, and one licence category of Market Activities (Operating a Crowdfunding Platform) new variable components have been introduced for a more sophisticated and proportionate fee structure. Variable fees will be calculated based on relevant financial indicators, as proposed in the consultation paper, and will apply only above a defined threshold. No changes are made to existing variable fees for certain Regulated and Market Activities at this stage, as these fees were introduced relatively recently.
Following public consultation, the calculation methodology for new variable component was revised for four Regulated Activities from average daily to end-quarter values where the variable component is based on stock values. In addition, given the significant demand from the market for clarification of the methodology for calculating the variable fee for the Providing Money Services licence, particularly regarding which components should be included or excluded from the transaction value, AFSA has decided to defer the commencement date of this new fee by one year. During this period, AFSA will work with market participants to develop practical guidance and align with supervisory reporting requirements.
- With the introduction of new variable fees in addition to the existing ones, AFSA is also introducing a cap on variable fees for all Regulated and Market Activities to which a variable fee applies. Previously, a cap existed only for the Digital Asset Trading Facility licence, set at USD 1 million, which was used as the reference point in the initial policy proposals. Following public consultation, AFSA revised the proposal and decided to reduce the cap to USD 250,000 to ensure predictable costs for market participants and better reflect the current scale of the market.
- Amendments have also been introduced to the initial supervision fee and to the calculation of subsequent supervision fees for firms holding multiple licences. Specifically, the initial annual supervision fee now will be payable within 21 days from the date of the grant of licence, rather than from the date of commencement of operations, in order to cover the Risk Mitigation Programme (RMP) period, which requires substantial supervisory resources. As to the subsequent annual supervision fee, under the new approach, the fee will be calculated as the highest applicable fixed annual supervision fee plus 50% for each additional licensed activity. For activities subject to variable fees, 100% of the variable component will be payable for each such activity.
Having reviewed the extensive feedback on the latter proposal given its direct impact on the overall amount of supervision fees payable by firms holding multiple licences and concerns that a certain combination of licences is a result of closely interrelated or overlapping activities, AFSA decided to defer the commencement date of the new approach for one year. For the 2026 supervision year, firms will continue to pay only the highest applicable fixed annual supervision fee and, in addition, the highest variable component if applicable. This transition period will allow market participants to adjust and plan for the resulting supervisory costs. Prior to implementation, AFSA will issue additional guidance outlining its approach to a combination of licences for supervision fee calculation.
- AFSA has also revised its approach to fees for licence modification for Regulated and Market Activities and Ancillary Services, as proposed in the consultation paper, which mostly amount to a full authorisation process, requiring the same level of analysis and assessment as an initial application.
- The application and modification fees for Approved Individuals have been also revised and increased to reflect the actual regulatory effort involved and to help reduce the frequency of changes among key individuals appointed. After reviewing the market feedback, the proposed increase to USD 1,000 have been reduced to USD 500 for full regime, and to USD 200 for FinTech Lab applications, taking into account current market constraints.
- As to the other FinTech Lab fees, application and supervision fees within the FinTech Lab have been increased as proposed in the consultation paper, as well as new fees for change of control and admission of Digital Assets to trading are introduced.
- In addition, AFSA introduces changes to some other fees related to authorisation and supervsion, including application fees in relation to Digital Assets, application fee for change of control, registration or notification for Non-Exempt and Exempt Funds, amendments to the Constitution or Offering Materials of Non-Exempt Funds, which have been increased, as proposed in the consultation paper. Furthermore, an additional category of fees for individual appointments within Ancillary Service Providers, covering changes of Money Laundering Reporting Officers (MLROs) and changes or new appointments of Audit Principal have been introduced.
- Registration and recognition fees payable to the Registrar of Companies have also been revised across a range of legal entity types, with adjustments reflecting both the general fee revision and targeted corrections, while certain categories such as Special Purpose Companies and Investment Funds required targeted decreases to reflect their role as investment vehicles with diverse potential uses. Amendments have also been introduced to the administrative services fees and annual report filing fees payable to the Registrar of Companies, as proposed in the consultation paper.
- Late fees payable to AFSA and the Registrar of Companies have been also increased, while those applicable to FinTech Lab participants remain unchanged.
The commencement date is 1 December 2025, with the exception of the deferred provisions specified in the AIFC Fees Rules.
The relevant amendments to the AIFC Fees Rules are available here: https://orderly.myafsa.com/articles/feesrules.
A dedicated Q&A section, developed on the basis of questions and concerns raised during the public consultation, is also available here: https://afsa.aifc.kz/31302-2/.
Should firms have further questions regarding their feedback, they may contact us at [email protected] or reach out to their respective supervisor.
AFSA is available to arrange a call or meeting if a firm wishes to discuss any points in more detail.
Reference:
The Astana Financial Services Authority (AFSA) is the independent regulator of the Astana International Financial Centre (AIFC), which is established in accordance with the Constitutional Law of the Republic of Kazakhstan “On the Astana International Financial Centre” for the purposes of regulating financial services and related activities in the AIFC. AFSA administers the AIFC Regulations and Rules and is responsible for the authorisation, registration, recognition and supervision of financial firms and market institutions in the AIFC.
Over 4,700 firms from 88 countries are registered in the AIFC. These firms provide banking, insurance, investment, professional and other services. The range of financial services offered at the AIFC is comparable to the list of services available in long-established financial centers of the world, such as London, Hong Kong, Singapore, Dubai and others. www.afsa.kz
The Astana International Financial Centre (AIFC) is an independent jurisdiction with a favourable legal and regulatory environment and a developed infrastructure for starting and doing business, attracting investment, creating jobs and developing Kazakhstan’s economy. https://aifc.kz/
Contact information:
Public Relations and Communications Division of AFSA: +7 (717) 264 73 43; +7 7172 61-37-45 email: [email protected]
