ARXO-2026-0112 · Reported
Reports on Single Family Office and Corporate Treasury Centre Funds: the draft extends CIS 10.4 and 10.5 to every Domestic Fund, but 10.5(b) and the Guidance to 2.4.17 do not match
Under the current CIS, reports on Single Family Office and Corporate Treasury Centre Funds (10.5-1(j), 10.5-1.1) have no deadline, frequency or recipient: both Funds must be Exempt Funds, and 10.5, which sets the timing and recipients of Fund reports, applies to Non-Exempt Funds only (10.1(ii)). CIS also does not require these Funds to be audited (10.4 and 10.1(i)). The draft in Consultation Paper AFSA-PSRD-CSP-2026-0001 extends the audit rule in 10.4 and the periodic reports in 10.5(a) to each Domestic Fund, which answers most of this point. Two questions remain on the draft. First, 10.5(b) still sets the four-month deadline for the annual report "for the Non-Exempt Fund", while 10.5(c) no longer says "Non-Exempt", so the deadline for the annual report of other Domestic Funds is unclear. Second, the Guidance to the new 2.4.17 says that for a Corporate Treasury Centre Fund "the standard Fund Manager reporting requirements under CIS 10.5 also do not apply", while the draft 10.5(a) covers each Domestic Fund and states no exception.
Proposed correction
When finalising the draft, please make 10.5(b) cover every Fund to which 10.5(a) applies (for example "for the Fund", as in 10.5(c)), and either state in the rules that 10.5 does not apply to Corporate Treasury Centre Funds, with the reporting that replaces it, or align the Guidance to 2.4.17 with 10.5(a).
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC Collective Investment Scheme Rules (CIS), V8
- Place
- CIS V8 10.1(ii)
- Record
- Discrepancy
- Class
- Amendments
- Where it arose
- The amending 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.
Rule 10.5 applies to Non-Exempt Funds only.Rule 10.4 applies to Non-Exempt Funds and Real Estate Investment Trusts only;for a report on a Single Family Office Fund, statements:be an Exempt Fund; andparticularly for the purposes of their annual and interim reports, which are required to be prepared under applicable the AIFC CIS Rules.The matters set out in (a) to (l) must be included in any Fund Manager’s report, except for the Corporate Treasury Centre Fund Manager’s report:For a report on a Corporate Treasury Centre Fund, the Fund Manager must report on the progress of the fund’s treasury activities and include in the report:copies of the fund’s audited financial statements; andthe Fund Manager must report on the progress of the fund’s treasury activitiesexamined and reported upon by an Auditor; andUnless otherwise provided in its Articles of Association, a Private Company and its Directors are not required to comply with subsections (4)(b) and (5) if the Company has
How to check it without Arxo's tools
- Open Collective Investment Scheme Rules V8., with amendments as of 15 December 2024, commence on 1 January 2025 and find CIS V8 10.1(ii); CIS V8 10.1(i); CIS V8 10.5-1(j); CIS V8 7.2-1.2(a)(i) / 7.2-1.3(a)(i); CIS V8 10.5-1 chapeau; CIS V8 10.5-1.1; CIS V8 10.5-1.1(ii); CIS V8 10.5-1.1 — 'must report'. Compare the text with the quotation above. A copy is kept in this register: 733512c03c358cc3-cis_v8_fr0009-01.01.2025.pdf (SHA-256
733512c03c358cc361a31decd44731fd64d90dcb747829a11e3d1382e4669fb7, copy of the official file). - Open ISLAMIC FINANCE RULES and find IFR 7.6 Guidance — assumes CIS requires annual and interim reports of Exempt Funds. Compare the text with the quotation above. A copy is kept in this register: f5bf530f9d9d46ed-islamic-finance-rules-1.pdf (SHA-256
f5bf530f9d9d46edbfb3740d5937f3ca2ec853c0a15174b64d7e9d548a7baaed, 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 s.131(4)(b); AIFC Companies Regulations V8 s.131(6). 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
- Collective Investment Scheme Rules V8., with amendments as of 15 December 2024, commence on 1 January 2025
- ISLAMIC FINANCE RULES
- 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-2026-0112, https://arxo.io/findings/ARXO-2026-0112/ (status as of 2026-10-25). Data: ARXO-2026-0112.json.