ARXO-2026-0186 · Reported
Foundations Regulations s.36: since Amendments No. 1 (2019) "the Foundation's return date" is not defined; since Amendments No. 3 (2023) s.36(4)-(5) still refer to "Schedule 3 (Fines and Fees)" and to fees "prescribed in Regulations"
Amendments No. 1 to the Foundations Regulations (2019) deleted the definition of the return date ("each anniversary of the date it received its Commercial Licence") from section 36(3) but kept the words "made up to the Foundation's return date"; the term is not defined elsewhere. The filing deadline, "within 6 months of the end of each financial year", does not depend on that date, and the Registrar may set another date. Amendments No. 3 (2023) moved fees to the Fees Rules (section 61) and removed fees from Schedule 3, but section 36(4) still refers to "Schedule 3 (Fines and Fees)" and section 36(5) still requires "application for registration fees ... as prescribed in Regulations".
Proposed correction
Please specify the date to which an annual return under section 36 must be made up, and update the fee references in section 36(4) and (5) to match the current fee provisions.
- Jurisdiction
- Kazakhstan — AIFC
- Act
- AIFC Foundations Regulations, V5
- Place
- Foundations Regulations V5, s.36(3)
- 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.
The annual return must be made up to the Foundation’s return date, or such other date the Registrar considers appropriateliable to a fine, as set out in Schedule 3 (Fines and Fees).A Foundation must pay the prescribed application for registration fees to the Registrar as prescribed in Regulations.Fees Rules contain a list of fees payable to the Registrar in connection with these Regulations.which shall be each anniversary of the date it received its Commercial LicenceA Foundation must pay the prescribed Commercial Licence fees to the Registrar as prescribed in Regulations.The annual return must be made up to the Foundation’s return date, which shall be each anniversary of the date it received its Commercial Licencewithin 6 months of the end of each financial year, or other date the Registrar considers appropriateto these Regulations contains a list of maximum fines
How to check it without Arxo's tools
- Open AIFC Foundations Regulations V5 with amendments as of 17 October, commence on 1 January 2025 and find Foundations Regulations V5, s.36(3); Foundations Regulations V5, s.36(4); Foundations Regulations V5, s.36(5); Foundations Regulations V5, s.61. Compare the text with the quotation above. A copy is kept in this register: 1101421f81f4073f-fr_v5_may_2024_ba.pdf (SHA-256
1101421f81f4073f8d6409fa9a7f4d564402f8b5fe55d94fe1600ee6922797d2, copy of the official file). - Open AIFC Foundations Regulations (initial release) 26.03.2019 and find Foundations Regulations V1 (26.03.2019), s.36(3) and (5); Foundations Regulations V1, s.36(5). Compare the text with the quotation above. A copy is kept in this register: da033f8908e2bd78-fr_v1_24_26.03.2019.pdf (SHA-256
da033f8908e2bd7808492eda984b77e4e3f29c3f4fa8d10ee7bc962c62f67090, copy of the official file). - Open AIFC Foundations Regulations A1 with amendments as of 5 July 2019, commence on 5 July 2019 and find Foundations Regulations Amendments No. 1 (2019), p.3, s.36(3): the words after "return date" are struck through (deleted); same, p.3, s.36(3): inserted words (underlined). Compare the text with the quotation above. A copy is kept in this register: 107e6ab6f0532285-fr_a1_02.07.2019.pdf (SHA-256
107e6ab6f0532285a08d6db1307b8f27f562fe9ae585d1e7e9ed5d8c604f9c39, copy of the official file). - Open AIFC Foundations Regulations A3 with amendments as of 28 December 2022, commence on 1 January 2023 and find Foundations Regulations Amendments No. 3 (2023), p.4, s.60(3): unstruck words only; "Part 1 (Fines) of" and "and Fees" are struck through. Compare the text with the quotation above. A copy is kept in this register: 654d3a2cce121db0-fr_a3_01.01.2023.pdf (SHA-256
654d3a2cce121db0e336fde304ac7b45b573bcc6002330e23a00e2f52910ba38, copy of the official file). - 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
- AIFC Authority — body that prepares AIFC acts and publishes them on the AIFC website
Reported to
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-27 | AIFC Authority |
Responses
No response recorded.
Documents and reproduction
- AIFC Foundations Regulations V5 with amendments as of 17 October, commence on 1 January 2025
- AIFC Foundations Regulations (initial release) 26.03.2019
- AIFC Foundations Regulations A1 with amendments as of 5 July 2019, commence on 5 July 2019
- AIFC Foundations Regulations A3 with amendments as of 28 December 2022, commence on 1 January 2023
History
- 2026-10-24Confirmed by Arxo
- 2026-10-27Entered in the register
- 2026-10-27Reported to AIFC Authority (e-mail)
Cite this record
Arxo Law, Arxo Findings Register, ARXO-2026-0186, https://arxo.io/findings/ARXO-2026-0186/ (status as of 2026-10-24). Data: ARXO-2026-0186.json.