Capital of Digital Asset Service Providers: DAA Table 2 and PRU (INV) Table 3.3 both apply to the same activities with different amounts

DAA 3.2(1)(b) and Table 2 set the capital of a Digital Asset Service Provider at USD 250,000 for Providing Custody, USD 100,000 for Managing Investments and USD 250,000 for Dealing in Investments as Principal (other than matched principal). PRU (INV) 1.3 applies to any firm authorised to conduct these activities; Investments include Digital Assets (Glossary), and PRU (INV) 1.3(6) does not exclude Digital Asset Business. PRU (INV) Table 3.3 sets USD 500,000 for Providing Custody Services and for Dealing in Investments as Principal and USD 150,000 for Managing Investments, with the liquid assets requirement in PRU (INV) 4. DAA 3.2(1)(a) keeps the general authorisation requirements of other applicable rules, and for stablecoin issuers DAA 4.2(b) states that "the highest amount applies" where another activity requires more capital, so the DAA amounts may be meant as a floor next to PRU (INV). The Rules do not say so for Table 2. Example: a firm licensed only to provide custody of Digital Assets with capital resources of USD 300,000 meets Table 2, but is USD 200,000 below PRU (INV) Table 3.3 for the same activity.

Proposed correction

Please state whether the DAA Table 2 amounts are meant to replace or to supplement PRU (INV) for Digital Asset Service Providers. If they replace it, PRU (INV) 1.3 could exclude Digital Asset Business; if PRU (INV) applies, Table 2 could say that the higher amount applies.

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Rules on Digital Asset Activities (DAA), V5

Place

DAA 3.2(1)(b), p.44

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

2026-10-25

Evidence

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

the applicant must ensure that it maintains at all times capital resources no lower than the capital requirement specified in Table 2 by reference to the activity that the Digital Asset Service Provider is authorised to conduct

250,000 Providing Custody

These PRU(INV) Rules apply to PRU Investment Firms.

A "PRU Intermediary Investment Firm" is an entity that has an Authorisation to conduct any of the following Regulated Activities

(c) Providing Custody Services;

Providing Custody Services 500,000

These PRU(INV) Rules do not apply to entities that have an Authorisation to conduct any of the following activities unless they are PRU Investment Firms

A Security, Unit, Derivative, Digital Asset or Environmental Instrument

safeguarding and administering Digital Assets belonging to another Person

general authorisation requirements applicable to the applicant under the Framework Regulations and other applicable rules

Regulated Activity for which the capital requirement is higher than USD 200,000, the highest amount applies

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 3.2(1)(b), p.44; DAA Table 2, p.44 (row Providing Custody); DAA 3.2(1)(a), p.44; DAA 4.2(b), p.77 (the same drafter's rule for stablecoin issuers). 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 Prudential Rules for Investment Firms (PRU INV), V7 and find PRU (INV) 1.3(1); PRU (INV) 1.3(4); PRU (INV) 1.3(4)(c); PRU (INV) Table 3.3; PRU (INV) 1.3(6). Compare the text with the quotation above. A copy is kept in this register: 1d2d8c432b940719-pru-v7.pdf (SHA-256 1d2d8c432b94071987e1f351c1dd44b443f39d75aa8fc552c31d1c7051812e89, copy of the official file).
3. Open AIFC Glossary (GLO), V23 and find Glossary, «Investment». 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).
4. Open AIFC General Rules (GEN), V20 and find GEN Schedule 1 para 5(c). 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. 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 Prudential Rules for Investment Firms (PRU INV), V7
• AIFC Glossary (GLO), V23
• AIFC General Rules (GEN), V20

History

1. 2026-10-25Confirmed 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-2026-0173, https://arxo.io/findings/ARXO-2026-0173/ (status as of 2026-10-25). Data: ARXO-2026-0173.json.