The Kazakhstan Head of State has signed an amendment to the Tax Code that will substantially expand the country’s electronic invoicing requirements. This legislation makes e-invoicing mandatory for all registered VAT payers and extends requirements to include a comprehensive range of who are not payers of VAT (hereinafter referred to as non-VAT payers) and specialized business categories. Kazakhstan utilizes a CTC clearance model in which taxpayers must obtain a pre-validation from the government platform prior to issuing electronic invoices to customers. The changes take effect 1 January 2026.
Key Changes
The Tax Code amendment introduces mandatory e-invoicing requirements for all registered VAT payers and significantly expands coverage to include specific categories of non-VAT payers. This comprehensive expansion affects multiple business sectors and specialized activities previously outside the electronic invoicing scope.
Newly covered non-VAT payers include:
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Commission agents and forwarding agents;
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State material reserve offices when releasing goods;
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International goods carriage service providers;
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Accredited conformity assessment legal persons under technical regulation legislation;
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Customs-related entities: representatives, carriers, warehouse owners, authorized economic operators;
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Simplified tax regime taxpayers with simplified returns;
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Taxpayers under international treaties as specified by regulatory acts;
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Sellers of imported goods;
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Taxpayers selling goods tracked through “Virtual Warehouse” module (goods list to be published by authorized body);
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Medical service providers and sellers of medicines, medical products, and technical auxiliary means;
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Law offices providing legal assistance through lawyer-established practices;
The requirements will not apply to individuals selling personal property, including individual entrepreneurs or persons in private practice.
What’s Next?
Businesses should should assess their current invoicing systems against the newly covered taxpayer categories and potentially prepare for the 1 January 2026 implementation date.
For future updates on Kazakhstan and similar developments in other countries, follow our Regulatory Analysis page.
