DAA 2.8.2(1)(c): stablecoin admission criteria "in (4) or (5)": (5) is a notice after admission, and the reserve test in (4)(c) covers only Fiat stablecoins

DAA 2.8.2(1)(c) makes admission of a Fiat or Commodity stablecoin to trading depend on "all of the requirements in (4) or (5) as applicable". Paragraph (4) lists reserve criteria, but its test of reserve adequacy in (4)(c) speaks only of "reserves in respect of Fiat stablecoins". Paragraph (5) is not a criterion: it requires the operator to notify the AFSA within 3 business days after admission (in earlier versions, 10 days before admission). So for a Commodity stablecoin the operator has no stated test that the reserves cover the stablecoins in circulation. Issuers licensed in the AIFC must still meet the reserve rules in DAA 4.7.1, which cover Commodity stablecoins, and the AFSA approves stablecoins other than those issued by licensed Digital Asset Service Providers (2.8.1(3)(b)); the gap concerns the operator's admission test, mainly for stablecoins issued outside the AIFC. PMS 2.4.2(1)(c) has the same wording (AIFC2-PMS-02).

Proposed correction

Please state the reserve test that applies when a Commodity stablecoin is admitted to trading, and in 2.8.2(1)(c) refer only to the paragraphs that contain admission criteria.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Digital Asset Activities (DAA), V5

Place

DAA V5, 2.8.2(1)(c)

Record

Discrepancy

Class

Text of the act

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.

for a Fiat or Commodity stablecoin, all of the requirements in (4) or (5) as applicable

Digital Asset Trading Facility Operator is required to notify the AFSA within 3 business days after the admission of the Digital Asset to trading.

the published information referred to in (4)(a) demonstrates that the reserves in respect of Fiat stablecoins:

(1) For the purposes of 2.8.1(3)(b), a Digital Asset can be admitted to trading on the Operator’s facility

Digital Asset Trading Facility Operator is required to notify the AFSA 10 days prior to the date of the admission of the Digital Asset to trading.

obtain approval of the AFSA in respect of Fiat and Commodity stablecoins, except for stablecoins issued by the Digital Asset Service Providers holding the relevant Licence.

Issuer of a Commodity stablecoin must issue stablecoins whose reserve assets consist of referenced Commodities only.

notify the AFSA 10 days prior to the date of the admission

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, 2.8.2(1)(c); DAA V5, 2.8.2(5); DAA V5, 2.8.2(4)(c); DAA V5, 2.8.2(1) lead-in; DAA V5, 2.8.1(3)(b), p.24; DAA V5, 4.7.1(3-1). 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 Initial Version and find DAA initial version, 2.8.2(5) (pre-V5 wording). Compare the text with the quotation above. A copy is kept in this register: b2e861a30dc0572c-aifc-rules-on-digital-asset-activities-daa_stablecoins.pdf (SHA-256 b2e861a30dc0572cad84b883e338a785dd3bc1239d668642df59d25fa86e7c0c, copy of the official file).
3. Open AIFC Rules on Digital Asset Activities A3., with amendments as of 13 April 2025, which commence on 13 October 2025 and find DAA V4 (in force 13.10.2025), 2.8.2(5) - prior notice before Amendments No. 4. Compare the text with the quotation above. A copy is kept in this register: 25e9223f15295f6e-aifc-rules-on-digital-asset-activities-daa_v4_13.10.2025_ma-1-1.pdf (SHA-256 25e9223f15295f6eb3e01993c141d64c3d6bbb6931ecc42040f1a2b3ac84240b, 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 Initial Version
• AIFC Rules on Digital Asset Activities A3., with amendments as of 13 April 2025, which commence on 13 October 2025

Related records

• ARXO-2026-0161 — PMS 2.4.2(1)(c): stablecoin criteria "in subrules (4) or (5)": (5) is a prior notice, and the reserve test in (4)(c) covers only Fiat stablecoins

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-2026-0152, https://arxo.io/findings/ARXO-2026-0152/ (status as of 2026-10-24). Data: ARXO-2026-0152.json.