DP Rules r.4.2.3(a): first notification due 'no later than 14 days start of the operations' - before or after the start is not said

Rule 4.2.3(a) requires the notification of Personal Data Processing operations 'no later than 14 days start of the operations' - a word ('after' or 'before') is missing, so the deadline can be read as 14 days before the operations start or 14 days after. The neighbouring r.4.3 uses the full form 'no later than 14 days after the day the particulars change'. Text unchanged since the 2018 Rules; the notification attracts the item 3 fee (USD 1,000/500/200).

Proposed correction

Please state whether the first notification is due 14 days before or 14 days after the start of the operations (rule 4.3 uses "after the day").

Jurisdiction

Kazakhstan — AIFC

Act

AIFC Data Protection Rules

Place

r.4.2.3(a)

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.

no later than 14 days start of the operations; and

about changed particulars of Personal Data Processing operations as soon as possible after the particulars change, but no later than 14 days after the day the particulars change.

no later than 14 days start of the operations; and

How to check it without Arxo's tools

1. Open AIFC DATA PROTECTION RULES (with ammendments as of 1 April, 2025) and find r.4.2.3(a); r.4.3. Compare the text with the quotation above. A copy is kept in this register: d585ad603a068eef-aifc-data-protection-rules.pdf (SHA-256 d585ad603a068eefe225665e2d0b41d0e5cfa6f6f7e554dfb53d2e673d5a8614, copy of the official file).
2. Open AIFC DATA PROTECTION RULES 2018 and find 2018 Rules r.4.2.3(a) - same text. Compare the text with the quotation above. A copy is kept in this register: 8664e957109b527d-aifc-data-protection-rules-no.1-of-2018-1-1.pdf (SHA-256 8664e957109b527d9f7e9826d52dc1d5506e65f3282baf255e27a89d5663e969, copy of the official file).
3. 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

Responses

No response recorded.

Documents and reproduction

• AIFC DATA PROTECTION RULES (with ammendments as of 1 April, 2025)
• AIFC DATA PROTECTION RULES 2018

History

1. 2026-10-24Confirmed by Arxo
2. 2026-10-27Entered in the register
3. 2026-10-27Reported to AIFC Authority (e-mail)

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0204, https://arxo.io/findings/ARXO-2026-0204/ (status as of 2026-10-24). Data: ARXO-2026-0204.json.