FEES Schedule 1, 1.1-1: the exception for Operating a Digital Asset Trading Facility is printed but was never enacted

Amendments No. 14.1 (9 December 2023) inserted 1.1-1 (additional application fee for Digital Assets activities) without an exception; the same instrument put an exception for Operating a Digital Asset Trading Facility only into 6.1-1. Consolidated versions V15 to V18 print the exception in 1.1-1 as well, and we could not find it in any of the published amending instruments Nos. 12 to 17. Whether a Digital Asset Trading Facility applicant owes the additional fee (now 2 800 USD) depends on which text is right; a consolidated version cannot change legal effect (section 19(2) of the AIFC Regulations on AIFC Acts). The draft in Consultation Paper AFSA-PSRD-CSP-2026-0004 amends 1.1-1 again (the fixed amount is replaced by a table) and prints the words "except for the Regulated Activity of Operating a Digital Asset Trading Facility" as existing text, not as an insertion.

Proposed correction

Since the draft amends 1.1-1 in any case, please either enact the exception expressly in the amending instrument, as new text, or remove it, and identify the instrument that supports it for the period since V15.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Fees Rules (FEES), AIFC Rules No. FR0007 of 2017, V18

Place

FEES Schedule 1, rule 1.1-1 (Amendments No. 14.1 of 9 December 2023)

Record

Discrepancy

Class

Publication and consolidation

Where it arose

The consolidated text

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-25

Evidence

Traced through the amending instruction. Quotations are verbatim from the official material; translations are ours and marked.

An applicant seeking to conduct Regulated Activities in relation to Digital Assets must pay to the AFSA an additional application fee in the amount of 2 000 USD.

except for the Regulated Activity of Operating a Digital Asset Trading Facility, must pay to the AFSA an additional annual supervision fee in the amount of 2 000 USD.

except for the Regulated Activity of Operating a Digital Asset Trading Facility, must pay to the AFSA an additional application fee in the amount of 2 000 USD.

How to check it without Arxo's tools

1. Open AIFC Fees Rules, Amendments No. 14 and No. 14.1 (2023) and find A14 merged PDF p.8 (Amendments No. 14.1 of 09.12.2023), Schedule 1, new 1.1-1 (underlined); A14 merged PDF p.13, Schedule 6, new 6.1-1 (contrast: exception present). Compare the text with the quotation above. A copy is kept in this register: bd11d229dfdd3138-fees-a14.pdf (SHA-256 bd11d229dfdd313809a02cb41a0326bfdae66d26cb01aa3d4d4a206fc54b647e, copy of the official file).
2. Open AIFC Fees Rules, V15 and find V15 Schedule 1, 1.1-1. Compare the text with the quotation above. A copy is kept in this register: 4bb51cd71bb9b068-fees-v15.pdf (SHA-256 4bb51cd71bb9b06876ec794341df17dda22fe9d7646ce970eb111ab71f4d71f9, copy of the official file).
3. The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.

How this finding was made

AI agents read the official texts, turned the provisions concerned into executable rules and ran the comparison; they also drafted this record. A person at Arxo checked the finding and approved the report before it was sent (2026-10-27).

Responsible institutions

• Astana Financial Services Authority (AFSA) — publisher of the AIFC Rules on the AFSA website

Reported to

Responses

No response recorded.

History

1. 2026-10-23Confirmed by Arxo
2. 2026-10-27Entered in the register
3. 2026-10-27Reported to Astana Financial Services Authority (AFSA) (e-mail)

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0041, https://arxo.io/findings/ARXO-2026-0041/ (status as of 2026-10-25). Data: ARXO-2026-0041.json.