Variable fees: the payment deadline can expire before the invoice is issued

Variable fees are "paid within 21 days after the issuance of an invoice by the AFSA, but no later than within 1 month following each corresponding quarter". If the invoice is issued late in the following month, or after it, the payer may have fewer than 21 days or the deadline may precede the invoice, and the 1% per month increase under FEES 5.1.2 can start before the invoice arrives.

Proposed correction

Please clarify the payment obligation where an invoice is issued shortly before or after the quarterly long-stop date, and whether a minimum payment period is intended.

Jurisdiction

Kazakhstan — AIFC

Act

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

Place

Schedule 6, **Notes (4) to table 6.1

Record

Question of reading or data

Class

Question of reading or data

Where it arose

The text of the act

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-25

Evidence

Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.

Variable fee is paid quarterly (paid within 21 days after the issuance of an invoice by the AFSA, but no later than within 1 month following each corresponding quarter).

the sum due will be increased by 1% for each month, or part of a month, that it remains outstanding beyond the due date.

How to check it without Arxo's tools

1. Open AIFC Fees Rules (FEES), V18, with amendments as of 13 November 2025 and find Schedule 6, **Notes (4) to table 6.1; FEES 5.1.2. Compare the text with the quotation above. A copy is kept in this register: b5e10ace11734eda-fees-v18.pdf (SHA-256 b5e10ace11734eda9e2edf7ab4dc62ef97ee659e460dbcb48ab5c4815f8de8f6, copy of the official file).
2. 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) — author of the AIFC Rules

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-2026-0051, https://arxo.io/findings/ARXO-2026-0051/ (status as of 2026-10-25). Data: ARXO-2026-0051.json.