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Core statute and a newly consolidated supervisory body are confirmed (T1/T2), but registration/filing mechanics and territorial-scope language remain unconfirmed in available sources.
Sub-modules (5)
Regulator And AuthorityAmber
Supervisory function now sits with the Information Security Committee under MAIDD, established by government decision to regulate and enforce data-protection and information-security law.
Claims (6):
- The Government of Kazakhstan approved the Information Security Committee under the Ministry of Artificial Intelligence and Digital Development (MAIDD) to regulate, implement, and oversee personal data protection and information security, including issuing penalties for violations.
- Ministry of Artificial Intelligence and Digital Development — Unscheduled inspections of businesses for personal-data compliance.
- The Ministry of Artificial Intelligence and Digital Development is the national authorised body for personal-data protection; within the AIFC, the AFSA-appointed Commissioner of Data Protection administers a separate regime under AIFC Data Protection Regulations 2017.
- AFSA Commissioner of Data Protection — AIFC Commissioner of Data Protection is distinct from the national Ministry responsible outside the AIFC
- Ministry of Artificial Intelligence and Digital Development / AFSA Commissioner of Data Protection — in_force
- Information Security Committee (MAIDD) — The Government of Kazakhstan established the Information Security Committee under MAIDD to regulate, implement and oversee personal-data protection and information security, including issuing penalties for violations.
Act And InstrumentsGreen
Primary instrument is Law No. 94-V (2013), amended/operationalised by Law No. 347-VI (2020) which introduced the data protection authority function and consent/legitimate-purpose collection requirements.
Claims (10):
- The Law of the Republic of Kazakhstan of 21 May 2013 No. 94-V On Personal Data and its Protection is the primary omnibus instrument governing personal data processing in Kazakhstan.
- The Law of 25 June 2020 No. 347-VI on Amendments and Regulation of Digital Technologies established a data protection authority function and introduced requirements that personal data be collected and processed with valid consent and legitimate purpose.
- Law No. 326-VIII, signed 24 June 2026, amends Law No. 94-V 'On Personal Data and Their Protection'; most personal-data provisions enter into force 25 August 2026.
- Law No. 326-VIII — Law No. 94-V 'On Personal Data and Its Protection'; signed 24 June 2026, most provisions in force 25 August 2026
- Rules for the Implementation of Personal Data Protection Measures — New version in force 12 July 2026, introducing revised organisational/technical security requirements for restricted-access personal data
- The definition of personal data under Law No. 94-V is amended effective 11 July 2026.
- Law No. 326-VIII (24 June 2026) — Law No. 326-VIII amended Law No. 94-V, with the personal-data-identifier-based redefinition of 'personal data' effective 11 July 2026 and most remaining amendments effective 25 August 2026.
- Law No. 94-V 'On Personal Data and Their Protection' — in_force
- Law No. 326-VIII of 24 June 2026 — Personal-data-protection amendments (Article 1, paragraph 37) entered into force 25 August 2026
- Law No. 94-V 'On Personal Data and its Protection' — Law No. 94-V (21 May 2013) is the primary omnibus instrument governing personal-data processing in Kazakhstan outside the AIFC.
Material ScopeAmber
Material scope is elaborated via subordinate MDAI Rules for the Collection and Processing of Personal Data, covering data-subject rights to information and rectification.
Claims (4):
- The MDAI Rules for the Collection and Processing of Personal Data (approved 23 October 2020) set requirements for collection, use and processing of personal data and set out data-subject rights including the right to be informed of what data is collected and for what purpose, and the right to rectify.
- Law No. 94-V — Definition changed from medium-anchored to 'personal data identifier'-anchored, effective 11 July 2026
- Law No. 94-V — Personal data now means information supplemented by a 'personal data identifier', decoupling the definition from physical medium and biometric-data anchoring.
- Law No. 326-VIII (material-scope amendment) — Personal-data definition amended to focus on personal-data identifiers from 11 July 2026, bringing standalone data items into scope when used with an identifier
Territorial ScopeRed
No confirmed statutory language on extraterritorial/non-established-controller application was located in available sources.
Claims (1):
- Kazakhstan data protection framework — Any organisation processing Kazakhstani residents' data, regardless of processing location.
Regulator Registration And FilingRed
A registrar/notification model for data-processing operators has been proposed via draft amendments but had no confirmed enactment timeline as of the last located public consultation record.
Claims (7):
- Draft amendments published for public consultation by MDAI in April 2021 proposed introducing a registrar and notification requirements for data-processing operators, with no confirmed enactment timeline.
- Law No. 94-V (Chapter 3) — New processor-registry requirement effective 25 Aug 2026.
- Law No. 94-V (as amended, Chapter 3) — Requires notification to MAIDD of the start and end of personal-data processing, recorded in a new state register of persons collecting/processing personal data, effective 25 August 2026.
- Central executive body for personal-data protection — Register of entities collecting/processing personal data, effective 25 August 2026
- Kazakhstan personal-data register — A new register of data collectors/processors is being established effective 25 August 2026.
- Law No. 326-VIII introduces a mandatory duty on data owners, operators and third parties to notify the authorised body of commencement and termination of personal-data processing; applies only to 'large' owners/operators (500,000+ unique subjects).
- Law No. 94-V (as amended) — in_force
Key findings (3)
- — source on file
- — source on file
- — source on file
Regulator & Framework
Kazakhstan's national personal-data regime continues to sit under the Ministry of Artificial Intelligence and Digital Development, which acts as the authorised body for personal-data protection, while a separate regime applies within the Astana International Financial Centre, where the AFSA-appointed Commissioner of Data Protection administers the AIFC Data Protection Regulations 2017. This dual-perimeter structure is a standing feature of the Kazakhstani framework and has not changed.
What has changed is the law those national authorities administer. Law No. 326-VIII, adopted 24 June 2026, amends the principal personal-data statute, Law No. 94-V 'On Personal Data and Their Protection'. The redefinition of 'personal data' around a personal-data identifier, rather than around physical medium or biometric linkage, took effect on 11 July 2026, and most of the remaining amendments took effect on 25 August 2026. The amendment wave is now substantially in force rather than pending.
Among the provisions that took effect on 25 August 2026 is a new registration requirement: controllers must notify the Ministry of the start and the end of personal-data processing, with that notification recorded in a newly created state register of persons collecting or processing personal data. This converts what was previously an internal compliance matter into a filing obligation with the national authority, and it applies to both controllers and processors. The AIFC's separate regime under the 2017 Regulations appears unaffected by this national-law amendment wave, preserving the jurisdictional split between the two regimes.
The overall picture is of a national framework that has moved from amendment to implementation over the course of 2026, with the authorised body's practical supervisory toolkit - via the new processing register - now broader than it was before the amendment wave took effect.
Outlook
The amendments are now in force, so the near-term question is one of implementation and enforcement practice under the new Chapter 3 processing-notification mechanism, including how the Ministry operates the new state register in practice. Primary-source confirmation directly from the Ministry or the AIFC has not yet been obtained; reliance at present is on law-firm and press commentary describing the enacted text.
4 earlier distinct update(s)
Regulator & Framework
Kazakhstan's data-protection framework rests on Law No. 94-V 'On Personal Data and Their Protection,' as now amended by Law No. 326-VIII, signed 24 June 2026. Most provisions of the amending law enter into force on 25 August 2026, and the amendment introduces a mandatory duty for data owners, operators and third parties to notify the authorised body of the commencement and termination of personal-data processing. This notification duty is confined to 'large' owners or operators, defined by reference to a subject-count threshold of five hundred thousand or more unique subjects, so smaller controllers fall outside this specific registration-style obligation even as the broader law applies to them in other respects.
Whether the national registry process associated with this notification duty has begun operating, and what form the notification itself takes, has not been verified in the material available. Separately, whether Kazakhstan's distinct AIFC Data Protection Regulations, which apply within the Astana International Financial Centre's own legal perimeter, have been amended in step with these national changes to Law No. 94-V has also not been verified, leaving the relationship between the two regimes an open question going into the law's August commencement date.
Outlook
The commencement of most of Law No. 326-VIII's provisions on 25 August 2026 is the central date to track for this module. Beyond that date, the two unresolved questions are whether the large-controller notification registry is operating in practice and what filing form it requires, and whether the AIFC's parallel data-protection perimeter is being brought into alignment with the national law.
Regulator & Framework
Kazakhstan's foundational data-protection statute, Law No. 94-V, underwent two separate amending interventions that together reshape the framework's core definitions and instrument structure. Law No. 256-VIII amended the statute with effect from 12 July 2026, while Law No. 326-VIII, signed by President Tokayev on 24 June 2026, amended it further with its Article 1, paragraph 37 provisions entering force on 25 August 2026. Taken together, these two laws represent the principal legislative vehicle through which Kazakhstan's data-protection framework was tightened this cycle.
A central element of this amendment wave is the redefinition of the material scope of personal data itself. From 11 July 2026, the personal-data definition was amended to focus on the concept of personal-data identifiers, which has the effect of bringing standalone data items into scope where they are used in conjunction with an identifier, even where those items would not independently qualify as personal data. This identifier-centred approach represents the framework's shift toward assessing personal-data status in context, considering whether a data item can be linked to an identifying element, rather than classifying data items as personal or non-personal in isolation.
Alongside the legislative amendments, Order No. 338/НҚ of 22 June 2026 entirely restated the Rules for the Implementation of Personal Data Protection Measures by Data Controllers and/or Data Processors and Third Parties, with the restated rules in force from 12 July 2026. An entire restatement, rather than a targeted amendment, of implementing rules of this kind typically signals that the regulator intended a comprehensive refresh of operational requirements rather than incremental adjustment, consistent with the broader tightening pattern visible across this cycle's amendment wave.
What remains outstanding from a sourcing perspective is a consolidated primary text from Adilet.zan.kz, Kazakhstan's official legal-text portal, incorporating both the January and June 2026 amendment waves into a single current version of Law No. 94-V. The claims in this brief are sourced from secondary legal commentary describing the effect of the amendments rather than from the consolidated statutory text itself.
Outlook
The framework's near-term trajectory depends substantially on how the identifier-centred personal-data definition is applied in practice, since an identifier-based test can expand or contract the practical scope of personal data considerably depending on implementing guidance or enforcement interpretation. Retrieval of the consolidated Adilet.zan.kz text incorporating both 2026 amendment waves would materially improve confidence in the precise statutory language now in force, an improvement this cycle's secondary-source-dependent record was not able to deliver.
Regulator & Framework
Kazakhstan operates a dual-track data-protection framework. The national regime, outside the Astana International Financial Centre, is administered by a Ministry-level authority, while within the AIFC the AFSA Commissioner of Data Protection administers a distinct regime under AIFC-specific rules. This cycle saw the most significant restructuring of the national statute since its enactment: Law No. 326-VIII, signed 24 June 2026, amended Law No. 94-V 'On Personal Data and Its Protection', with the bulk of provisions entering into force on 25 August 2026. A new, earlier-effective change took hold on 11 July 2026, when the statutory definition of personal data shifted from one anchored to the medium on which data is held to one anchored on a 'personal data identifier'. Alongside the primary statute, a new version of the Rules for the Implementation of Personal Data Protection Measures entered into force on 12 July 2026, introducing revised organisational and technical security requirements for restricted-access personal data. The central executive body responsible for personal-data protection also introduced a new register of entities that collect or process personal data, effective 25 August 2026, creating a registration obligation that did not previously exist in this form.
Outlook
The consolidated text of Law No. 94-V incorporating the January, June and August 2026 amendment waves has not yet been independently retrieved to a primary Adilet.zan.kz source this cycle, and the precise territorial scope of the national regime, as distinct from the AIFC regime, has not been independently pinpointed. Resolution of either gap would sharpen the picture of which entities fall under which of Kazakhstan's two parallel data-protection frameworks.
Regulator & Framework
Kazakhstan's personal-data protection regime outside the Astana International Financial Centre continues to be anchored by Law No. 94-V, 'On Personal Data and its Protection', dated 21 May 2013, the primary omnibus instrument governing personal-data processing. Supervisory authority rests with the Information Security Committee, established under the Ministry of Digital Development, Innovation and Aerospace Industry (MAIDD), which regulates, implements and oversees personal-data protection and information security, including issuing penalties for violations.
This cycle brought the most substantial amendment to that framework in some time. Law No. 326-VIII, signed 24 June 2026, restated the statutory definition of personal data with effect from 11 July 2026, narrowing its focus onto specific identifiers: full name, Individual Identification Number (IIN), facial image, and facial biometric vector and its derivatives. This is a materially tighter and more technically specific definition than a general-purpose omnibus definition would typically provide, and it signals a regulatory focus on biometric and identity-linked data specifically.
The same amendment wave established two new state registers, both effective 25 August 2026: a register of persons and entities engaged in the collection and/or processing of personal data, and a separate register of personal-data security breaches. These registers create new registration and filing obligations for data controllers and processors that did not previously exist under the 2013 framework, and they represent a shift toward a more transparent, centrally-tracked population of data handlers.
Outlook
The primary consolidated text of Law No. 326-VIII on Adilet.zan.kz has not been independently retrieved this cycle; all findings here rest on secondary legal-advisory summaries from multiple firms. Confirmation against the primary statutory text would sharpen confidence in the precise scope of the new registers and the definitional changes. Watch for MAIDD's implementing procedures, expected to operationalise the registers now that their August 2026 effective date has passed.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and claims (28)
- Probable DataGuidance — The Government of Kazakhstan approved the Information Security Committee under the Ministry of Artificial Intelligence and Digital Development (MAIDD) to regulate, implement, and oversee personal data protection and information security, including issuing penalties for violations. observed
- Probable DataGuidance (mirroring official text) — The Law of the Republic of Kazakhstan of 21 May 2013 No. 94-V On Personal Data and its Protection is the primary omnibus instrument governing personal data processing in Kazakhstan. observed
- Probable DataGuidance — The Law of 25 June 2020 No. 347-VI on Amendments and Regulation of Digital Technologies established a data protection authority function and introduced requirements that personal data be collected and processed with valid consent and legitimate purpose. observed
- Probable DataGuidance — The MDAI Rules for the Collection and Processing of Personal Data (approved 23 October 2020) set requirements for collection, use and processing of personal data and set out data-subject rights including the right to be informed of what data is collected and for what purpose, and the right to rectify. observed
- Probable DataGuidance — Draft amendments published for public consultation by MDAI in April 2021 proposed introducing a registrar and notification requirements for data-processing operators, with no confirmed enactment timeline. observed
- Probable Uppersetup — Law No. 94-V (Chapter 3) — New processor-registry requirement effective 25 Aug 2026. observed
- Probable Wikipedia — Law No. 326-VIII, signed 24 June 2026, amends Law No. 94-V 'On Personal Data and Their Protection'; most personal-data provisions enter into force 25 August 2026. observed
- Probable Uppersetup — Law No. 94-V (as amended, Chapter 3) — Requires notification to MAIDD of the start and end of personal-data processing, recorded in a new state register of persons collecting/processing personal data, effective 25 August 2026. observed
- Probable https://www.ey.com/en_kz/technical/tax-alerts/2026/09/kazakhstan-personal-data-law-amendments-deletion-anonymisation-data-breach-register — Law No. 326-VIII — Law No. 94-V 'On Personal Data and Its Protection'; signed 24 June 2026, most provisions in force 25 August 2026
- Probable https://www.bakermckenzie.com/en/insight/publications/2026/07/kazakhstan-new-amendments-to-personal-data-legislation — Rules for the Implementation of Personal Data Protection Measures — New version in force 12 July 2026, introducing revised organisational/technical security requirements for restricted-access personal data
- Probable https://www.ey.com/en_kz/technical/tax-alerts/2026/07/personal-data-protection-rules-updated-kazakhstan-2026 — Law No. 94-V — Definition changed from medium-anchored to 'personal data identifier'-anchored, effective 11 July 2026
- Probable https://www.morganlewis.com/pubs/2026/07/republic-of-kazakhstan-data-protection-law-amendments-in-2026 — Central executive body for personal-data protection — Register of entities collecting/processing personal data, effective 25 August 2026
- High Morgan Lewis — The definition of personal data under Law No. 94-V is amended effective 11 July 2026. observed
- High GRATA International — Ministry of Artificial Intelligence and Digital Development — Unscheduled inspections of businesses for personal-data compliance. observed
- High EY Kazakhstan — Law No. 94-V — Personal data now means information supplemented by a 'personal data identifier', decoupling the definition from physical medium and biometric-data anchoring. observed
- High VLO Law Firms — Kazakhstan data protection framework — Any organisation processing Kazakhstani residents' data, regardless of processing location. observed
- High Morgan Lewis — Kazakhstan personal-data register — A new register of data collectors/processors is being established effective 25 August 2026. observed
- Probable Wikipedia — The Ministry of Artificial Intelligence and Digital Development is the national authorised body for personal-data protection; within the AIFC, the AFSA-appointed Commissioner of Data Protection administers a separate regime under AIFC Data Protection Regulations 2017. observed
- Probable Morgan Lewis — Law No. 326-VIII (24 June 2026) — Law No. 326-VIII amended Law No. 94-V, with the personal-data-identifier-based redefinition of 'personal data' effective 11 July 2026 and most remaining amendments effective 25 August 2026. observed
- Probable https://www.bakermckenzie.com/en/insight/publications/2026/07/kazakhstan-new-amendments-to-personal-data-legislation — AFSA Commissioner of Data Protection — AIFC Commissioner of Data Protection is distinct from the national Ministry responsible outside the AIFC
- Probable Uppersetup — Law No. 326-VIII introduces a mandatory duty on data owners, operators and third parties to notify the authorised body of commencement and termination of personal-data processing; applies only to 'large' owners/operators (500,000+ unique subjects). observed
- Probable Wikipedia — Ministry of Artificial Intelligence and Digital Development / AFSA Commissioner of Data Protection — in_force observed
- Probable Morgan Lewis — Law No. 94-V 'On Personal Data and Their Protection' — in_force observed
- Probable Uppersetup — Law No. 94-V (as amended) — in_force observed
- Probable https://www.ey.com/en_kz/technical/tax-alerts/2026/09/kazakhstan-personal-data-law-amendments-deletion-anonymisation-data-breach-register — Law No. 326-VIII of 24 June 2026 — Personal-data-protection amendments (Article 1, paragraph 37) entered into force 25 August 2026
- Probable Wikipedia — Information Security Committee (MAIDD) — The Government of Kazakhstan established the Information Security Committee under MAIDD to regulate, implement and oversee personal-data protection and information security, including issuing penalties for violations. observed
- Probable Morgan Lewis — Law No. 94-V 'On Personal Data and its Protection' — Law No. 94-V (21 May 2013) is the primary omnibus instrument governing personal-data processing in Kazakhstan outside the AIFC. observed
- Probable https://www.morganlewis.com/pubs/2026/07/republic-of-kazakhstan-data-protection-law-amendments-in-2026 — Law No. 326-VIII (material-scope amendment) — Personal-data definition amended to focus on personal-data identifiers from 11 July 2026, bringing standalone data items into scope when used with an identifier