General insurers must seek MER advice from "its Approved Actuary"; it is unclear whether insurers not otherwise required to have one must appoint one (PINS and TRR)

PINS Schedule 5, paragraph 10 applies to General Insurance Business. Paragraph 10.2(2) requires an insurer to "seek advice from its Approved Actuary" about its maximum event retention if it issues policies without a maximum amount insured, insures risks in multiple lines of business or has a complex portfolio. Under PINS 2.2.2(2) an Approved Actuary is mandatory for a general insurer only in certain cases, and PINS 9.2 deals with insurers "not required to have an Approved Actuary". The text does not say whether paragraph 10.2(2) itself requires such an insurer to appoint one, or whether it may use the independent actuary described in PINS 9.2.3. TRR Schedule 5, paragraph 10.2(2) is the same.

Proposed correction

Please clarify whether an insurer subject to Schedule 5 paragraph 10.2(2), but outside rule 2.2.2(2), must appoint an Approved Actuary or may use the actuary described in rule 9.2.3 (and the same for TRR).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Insurance and Reinsurance Prudential Rules

Place

PINS Schedule 5 para 10.1

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

2026-10-24

Evidence

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

Paragraphs 10.2 and 10.3 apply to General Insurance Business.

An AIFC-Incorporated Insurer must seek advice from its Approved Actuary about estimating its MER if the AIFC-Incorporated Insurer:

PINS 9.2.2 to 9.2.5 apply to an Insurer that is not required to have an Approved Actuary.

An AIFC-Incorporated Takaful Operator must seek advice from its Approved Actuary about

How to check it without Arxo's tools

1. Open AIFC Insurance and Reinsurance Prudential Rules and find PINS Schedule 5 para 10.1; PINS Schedule 5 para 10.2(2); PINS 9.2.1. Compare the text with the quotation above. A copy is kept in this register: 3f9031ccaf1b4673-aifc-insurance-and-reinsurance-prudential-rules.pdf (SHA-256 3f9031ccaf1b4673811786d2cd011df2d712e9245c96f21c34fbf532bfcbfff7, copy of the official file).
2. Open AIFC Takaful and Retakaful Prudential Rules and find TRR Schedule 5 10.2(2). Compare the text with the quotation above. A copy is kept in this register: f0a0b4a6a254d390-aifc-takaful-and-retakaful-prudential-rules.pdf (SHA-256 f0a0b4a6a254d390fd8452b3b783b3ef05b4fce958ae8bec7843054790e83364, 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) — author of the AIFC Rules

Reported to

Responses

No response recorded.

Documents and reproduction

• AIFC Insurance and Reinsurance Prudential Rules
• AIFC Takaful and Retakaful Prudential Rules

History

1. 2026-10-24Confirmed 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-2026-0135, https://arxo.io/findings/ARXO-2026-0135/ (status as of 2026-10-24). Data: ARXO-2026-0135.json.