AUD 9.2.1 table: the rows for Non-Exempt Funds and Reporting Entities refer to CIR 11.4(a) and MAR 3.2.2, which do not require an audit

The table in AUD 9.2.1 links each auditor's report to the rule that requires it. Two rows do not lead there: "Financial Statements - Non-Exempt Fund" refers to "CIR 11.4(a)", a rulebook name the Glossary no longer has (the fund auditor rule is CIS 10.4), and "Financial Statements - Reporting Entity" refers to MAR 3.2.2, which is "Signing of the annual report" (the audit duty is MAR 3.1.2). The rows for the client asset reports refer to COB 8.2.19, 8.3.14 and 11.8.15, which no longer require an auditor's report; the draft in Consultation Paper AFSA-PSRD-CSP-2026-0005 replaces these references with a new GEN 6.3.9, and we support that change, but it leaves the two rows above as they are. In the draft GEN 6.3.9, item (a)(iv) requires an "Insurance Intermediary Auditor's Report" "if the Authorised Firm is permitted to control or hold Client Money". This is the same condition as for the Client Money Auditor's Report in (a)(ii) and is not limited to insurance intermediaries; the Glossary and the AUD table call this report "Insurance Intermediary Audit Report".

Proposed correction

Please update the two rows to the provisions that require the audit (for example CIS 10.4 and MAR 3.1.2). When finalising the draft GEN 6.3.9, please limit item (a)(iv) to insurance intermediaries that hold or control Client Money and use one name for the report.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Auditor Rules

Place

AUD 9.2.1 table, row 'Client Money Auditor's Report' (rendered page checked)

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

2026-10-25

Evidence

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

COB 8.2.19

COB 8.3.14

COB 11.8.15

CIR 11.4(a)

MAR 3.2.2

The report specified in COB 8.2.19.

provide at least once a year an audited statement of the Client Money unless such a statement has been provided in a periodic statement in accordance with COB 9.

Intermediary must provide at least once a year an audited statement of the Client Money.

such other reports as the AFSA may require; and

The AFSA may at any time require auditors of certain companies to prepare such additional audit reports as it believes necessary

produce, if the Authorised Firm is permitted to control or hold Client Money, an Insurance Intermediary Auditor’s Report in accordance with the Rules in AUD Annex C

How to check it without Arxo's tools

1. Open AIFC Auditor Rules and find AUD 9.2.1 table, row 'Client Money Auditor's Report' (rendered page checked); AUD 9.2.1 table, row 'Client Investments Auditor's Report'; AUD 9.2.1 table, row 'Insurance Intermediary Audit Report'; AUD 9.2.1 table, row 'Financial Statements - Non-Exempt Fund'; AUD 9.2.1 table, row 'Financial Statements - Reporting Entity'; AUD 9.2.3, p.17. Compare the text with the quotation above. A copy is kept in this register: b7eb7eed75dfea7f-aifc-auditor-rules.pdf (SHA-256 b7eb7eed75dfea7f0aefc2937b881836c3b1a7ba4f59701ec90fcfec5af4fae3, copy of the official file).
2. Open AIFC Glossary (GLO), V23 and find Glossary V23, 'Client Money Auditor's Report'. Compare the text with the quotation above. A copy is kept in this register: 041617346ad87a9f-glo-v23.pdf (SHA-256 041617346ad87a9ff3634eff95b3b92f65ee5f4965298a2c1137b8b9a8374b45, copy of the official file).
3. Open Conduct Of Business Rules Initial version and find COB V1 (10.12.2017), 8.2.19; COB V1 (10.12.2017), 11.8.15. Compare the text with the quotation above. A copy is kept in this register: f0613d3937d23587-cob_v1_fr0005_10.12.2017.pdf (SHA-256 f0613d3937d235871f74a92c9ccc430cfab72b4aba2873560ebdd390b6106e7f, copy of the official file).
4. Open AIFC General Rules (GEN), V20 and find GEN V20 6.3.9(a)(ii). 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).
5. Open AFSA Consultation Paper AFSA-PSRD-CSP-2026-0005: Targeted Amendments to the AIFC Rules (15.07.2026) and find Consultation Paper AFSA-PSRD-CSP-2026-0005 (15.07.2026, closed, not adopted as of 25.10.2026), Annex, new GEN 6.3.9(a)(iv). Compare the text with the quotation above. A copy is kept in this register: 05a2ed115abcc1ab-AFSA-PSRD-CSP-2026-0005.pdf (SHA-256 05a2ed115abcc1ab90a39c74ced2414b5a157d49522442ec652e29947cb34872, copy of the official file).
6. 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 Auditor Rules
• AIFC Glossary (GLO), V23
• Conduct Of Business Rules Initial version
• AIFC General Rules (GEN), V20
• AFSA Consultation Paper AFSA-PSRD-CSP-2026-0005: Targeted Amendments to the AIFC Rules (15.07.2026)

Related records

• ARXO-2026-0167 — AUD Annex C (Insurance Intermediary Auditor's Report) measures client money 'in accordance with COB 11', which has no client-money 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-2026-0166, https://arxo.io/findings/ARXO-2026-0166/ (status as of 2026-10-25). Data: ARXO-2026-0166.json.