DAA 4.11.3: is the base of the 2% ongoing capital the outstanding stablecoins or the reserve assets?

DAA 4.11.3(1) sets ongoing capital at 2% "of the average outstanding Fiat stablecoins or Commodity stablecoins". For an issuer with several categories, 4.11.3(3) says this amount "should be the sum of the average amounts of the reserve assets backing each category", and the Guidance describes it as the average amount of reserve assets at the end of each day over the preceding 6 months. Reserve assets must be at least equal to the outstanding stablecoins (4.7.1(2)) and may be larger. For an issuer with one category, the binding text does not say which base applies or over what period the average is taken.

Proposed correction

Please state in the rule whether the base is outstanding stablecoins or reserve assets, and move the averaging period into the rule.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Digital Asset Activities (DAA), V5

Place

DAA V5, 4.11.3(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.

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

the amount of the average outstanding Fiat stablecoins or Commodity stablecoins should be the sum of the average amounts of the reserve assets backing each category.

refers to the average amount of reserve assets at the end of each calendar day, calculated over the preceding 6 (six) months.

the value of the reserve assets must at all times be at least equal to the nominal value of all outstanding units

the amount of the average outstanding Fiat stablecoins or Commodity stablecoins should be the sum of the average amounts of the reserve assets backing each category.

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, 4.11.3(1); DAA V5, 4.11.3(3); DAA V5, Guidance to 4.11.3; DAA V5, 4.7.1(2). 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. 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)

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-2026-0154, https://arxo.io/findings/ARXO-2026-0154/ (status as of 2026-10-24). Data: ARXO-2026-0154.json.