On 12 June 2026, the President of Kazakhstan signed two laws amending anti-corruption, labour, criminal and administrative legislation: Law No. 311-VIII and Law No. 312-VIII.
One of the key changes is the development of digital mechanisms for identifying conflicts of interest. The Labour Code is being amended to introduce provisions on managing HR processes in state institutions and quasi-public sector entities through the digital HR system “E-qyzmet”. The system must contain information on the employee, the employee’s spouse and close relatives, as well as data on organisations and individual entrepreneurs for which the employee previously worked.
The law also introduces the concept of personal interest and establishes three types of conflict of interest: potential, actual and realised. For each case, a procedure is set for identifying and managing the conflict, including notification, preparation of an opinion and measures such as transfer, changes to powers or dismissal where the conflict cannot be resolved otherwise.
Special attention is paid to the prohibition on the joint employment of connected persons, which now include not only close relatives and spouses, but also in-laws, former spouses, persons maintaining a joint household, dependants and, in some cases, connected legal entities. The restrictions apply not only to direct subordination, but also to work in units overseen or headed by a connected official, to managerial positions in territorial and independent structural units, and to HR, control and audit functions.
For quasi-public sector entities, the amendments clarify anti-corruption compliance requirements. Partnerships, joint-stock companies, the National Welfare Fund and certain state enterprises must designate a structural unit or responsible person to perform compliance functions. This function must be independent of the executive body and accountable to the supervisory board, board of directors or another independent governing body.
The amendments also expand employment restrictions for persons who have previously committed corruption offences. The prohibition on holding certain positions will apply, in particular, to positions in the National Bank, financial market regulatory bodies, civil aviation organisations, state organisations and quasi-public sector entities, as well as to positions related to procurement, budget-funded projects and access to personal data.
Criminal legislation clarifies the elements of corruption offences related to bribery: liability will now arise not only for receiving a bribe, but also for demanding, offering or promising one. At the same time, the offence of receiving illegal remuneration by employees of organisations is specified, and liability is introduced for providing such remuneration to employees who are not persons authorised to perform state functions or persons treated as equivalent to them.
Administrative legislation has also been amended. The limitation period for bringing individuals to administrative liability for corruption offences is increased from 1 year to 3 years. Fines are introduced for providing and receiving illegal material remuneration, gifts, benefits or services, and the liability of legal entities for providing illegal remuneration is clarified.
In addition, administrative liability is provided for failure to take, or late taking of, measures to manage a conflict of interest, failure to report corruption crimes being prepared, committed or already committed, and failure to respond to a report of a corruption violation.
