ARXO-2026-0098 · Reported
MAR 2.4.5(b) refers to "a Takeover Offer under the Takeover Rules": which Takeover Rules apply?
MAR 2.4.5(b) lifts the closed-period dealing ban for "undertakings to accept, or the acceptance of, a Takeover Offer under the Takeover Rules". The Glossary defines "Takeover Rules" as Rules prescribed by the AFSA under section 88(1)(a) of the Framework Regulations, which says that the AFSA "may prescribe" such Rules. We did not find any Takeover Rules among the acts published on aifc.kz or in the AFSA online rulebook. Chapter 11 of Part 7 of the AIFC Companies Regulations ("Protection of Minorities in Takeovers") is part of the Regulations, not Rules made by the AFSA under section 88(1)(a). If no Takeover Rules have been made, exemption (b) has nothing to apply to, and a Restricted Person would need clearance under MAR 2.4.4.
Proposed correction
Please identify the Takeover Rules that apply for MAR 2.4.5(b), or confirm that this exemption currently has no application. If it is meant to apply now, please consider referring simply to "a Takeover Offer", which the Glossary defines.
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC Market Rules (MAR), V13
- Place
- MAR V13, 2.4.5(b) (rule), page 35
- 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
- 2026-10-24
Evidence
Contradiction within the text. Quotations are verbatim from the official material; translations are ours and marked.
undertakings to accept, or the acceptance of, a Takeover Offer under the Takeover Rules;Rules prescribed by the AFSA pursuant to section 88(1)(a) of the FrameworkThe AFSA may prescribe by RulesCHAPTER 11–PROTECTION OF MINORITIES IN TAKEOVERS
How to check it without Arxo's tools
- Open Market Rules V13., (with amendments as of 7 December 2025, which commence on 1 January 2026) and find MAR V13, 2.4.5(b) (rule), page 35. Compare the text with the quotation above. A copy is kept in this register: 163c0ad176174003-mar_v13_01.01.2026.pdf (SHA-256
163c0ad17617400321bc039bc3f91829586cbde62fec9a8d37e946d417252e7d, copy of the official file). - Open AIFC Glossary (GLO), V23 and find Glossary V23, 'Takeover Rules'. Compare the text with the quotation above. A copy is kept in this register: 041617346ad87a9f-glo-v23.pdf (SHA-256
041617346ad87a9ff3634eff95b3b92f65ee5f4965298a2c1137b8b9a8374b45, copy of the official file). - Open AIFC Financial Services Framework Regulations, V12 and find FSFR V12 s.88(1), page 43. Compare the text with the quotation above. A copy is kept in this register: 9c995b9be0e4359d-fsfr-v12.pdf (SHA-256
9c995b9be0e4359d9a595afe7d0a9d5d9f3a4597c3ee3255db2b2e1df520b5c3, copy of the official file). - Open ComReg_V8, with amendments as of 17 October 2024, commence on 1 January 2025 and find AIFC Companies Regulations V8, Part 7, Chapter 11 heading (Regulations, not AFSA Rules). Compare the text with the quotation above. A copy is kept in this register: a77bf2c39b86d220-comreg_v8_01.01.25.pdf (SHA-256
a77bf2c39b86d2202b1f8e6654fc1884cfd9e1c9648fbdd97894a4ff22939e03, copy of the official file). - 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
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-27 | Astana Financial Services Authority (AFSA) |
Responses
No response recorded.
Documents and reproduction
- Market Rules V13., (with amendments as of 7 December 2025, which commence on 1 January 2026)
- AIFC Glossary (GLO), V23
- AIFC Financial Services Framework Regulations, V12
- ComReg_V8, with amendments as of 17 October 2024, commence on 1 January 2025
History
- 2026-10-24Confirmed by Arxo
- 2026-10-27Entered in the register
- 2026-10-27Reported to Astana Financial Services Authority (AFSA) (e-mail)
Cite this record
Arxo Law, Arxo Findings Register, ARXO-2026-0098, https://arxo.io/findings/ARXO-2026-0098/ (status as of 2026-10-24). Data: ARXO-2026-0098.json.