Part 4 covers issuers of Commodity stablecoins, but authorisation (4.1) and capital (4.2) name only Fiat stablecoins

Amendments No. 3 (approved 13 April 2025, in force 13 October 2025) extended the Part 4 application statement to "issuing Fiat stablecoins and Commodity stablecoins", but in the same instrument added only "or issuing Fiat stablecoins" to 4.1(1), the lead-in of 4.2 and 4.2(b). The current version keeps this. Rule 4.11.3(1) says "In addition to DAA 4.2(b), an issuer of a Fiat stablecoin or Commodity stablecoin" must hold ongoing capital of 2%, so it assumes that 4.2(b) applies to both. GEN Schedule 1, paragraph 21, Guidance (5) also mentions only Fiat stablecoins. A Commodity-stablecoin issuer might be covered as "Providing Money Services in relation to Digital Assets" (buying and selling of a Digital Asset), but 4.1(2) treats issuing as a separate activity. The rules therefore do not say clearly which licence a Commodity-stablecoin issuer needs or whether the USD 200,000 floor in 4.2(b) applies to it.

Proposed correction

Please clarify how rules 4.1 and 4.2 apply to issuers of Commodity stablecoins, including the licence category and the minimum capital, for example by adding "or Commodity stablecoins" after "issuing Fiat stablecoins" in 4.1(1), the lead-in of 4.2 and 4.2(b).

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Digital Asset Activities (DAA), V5

Place

DAA V5, Part 4 application statement

Record

Discrepancy

Class

Amendments

Where it arose

The amending 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.

issuing Fiat stablecoins and Commodity stablecoins

A Person wishing to carry on Providing Money Services in relation to Digital Assets or issuing Fiat stablecoins in or from the AIFC must be an Authorised Firm licensed by the AFSA for providing a Regulated Activity of Providing Money Services.

The AFSA may not grant authorisation or variation of a Licence to carry on the activities of Providing Money Services in relation to Digital Assets or issuing Fiat stablecoins if:

In addition to DAA 4.2(b), an issuer of a Fiat stablecoin or Commodity stablecoin must ensure that it maintains at all times ongoing capital resources in the amount of 2% of the average outstanding Fiat stablecoins or Commodity stablecoins

Assets., issuing Fiat stablecoins and Commodity stablecoins.

Digital Assets or issuing Fiat stablecoins in or from the AIFC must be an Authorised Firm licensed

An Authorised Firm Providing Money Services in relation to Digital Assets, issuing Fiat stablecoins must comply with DAA Chapter 4

A Person authorised to issue Fiat stablecoins may provide Money Services in relation to Digital Assets and Money Services under paragraph 21 Schedule 1 GEN.

How to check it without Arxo's tools

1. Open AIFC Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026) and find DAA V5, Part 4 application statement; DAA V5, 4.1(1); DAA V5, 4.2 lead-in; DAA V5, 4.11.3(1); DAA V5, 4.1(2), p.76. Compare the text with the quotation above. A copy is kept in this register: 4a5174f747a66c22-daa_v5_01.01.2026.pdf (SHA-256 4a5174f747a66c222093a9cbd075c58816f1761b7a3b2807f86f9b98ccf28557, copy of the official file).
2. Open AIFC Rules on Digital Asset Activities (with amendments as of 13 April 2025, which commence on 13 October 2025) and find Amendments No. 3 (13.04.2025), Part 4 application statement - underlined insertion (rendered page checked); Amendments No. 3, 4.1(1) - underlined insertion covers Fiat only (rendered page checked). Compare the text with the quotation above. A copy is kept in this register: 65f769cc1ef6b168-daa_a3_19.05.2025-1.pdf (SHA-256 65f769cc1ef6b168b00e94cdbedbcff984140bcec05015e059bf048f2d94c0d4, copy of the official file).
3. Open AIFC General Rules (GEN), V20 and find GEN V20, Schedule 1 para 21, Guidance (5). Compare the text with the quotation above. A copy is kept in this register: e863a30c73072b03-gen-v20.pdf (SHA-256 e863a30c73072b0323a4d064ab0e3f7e103428a7992f91360ed19a173a68e681, copy of the official file).
4. 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 Rules on Digital Asset Activities_V5 (with amendments as of 7 December 2025, which commence on 1 January 2026)
• AIFC Rules on Digital Asset Activities (with amendments as of 13 April 2025, which commence on 13 October 2025)
• AIFC General Rules (GEN), V20

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-2026-0149, https://arxo.io/findings/ARXO-2026-0149/ (status as of 2026-10-24). Data: ARXO-2026-0149.json.