- within Finance and Banking, Tax and Technology topic(s)
On 18 December 2025, the Senate of the Republic of Kazakhstan approved amendments to the Code "On Subsoil and Subsoil Use" aimed at digitalisation of the sector, increasing transparency in the granting of subsoil use rights, and strengthening procurement requirements.
The amendments establish the Unified Subsoil Use Platform 1 (hereinafter, the "USP") as the core digital infrastructure of the industry, featuring an open database of geological information. The platform covers key business processes and public services in the field of exploration and extraction of solid minerals and widely occurring mineral resources.
The platform is to be integrated with the Unified State System for Management of the Fuel and Energy Complex (EnergyTech) 2, which ensures the collection, storage, and analysis of subsoil data in the hydrocarbons sector.
The status of the operator responsible for managing geological information is assigned to the National Geological Service. The organisation remains in state ownership and is not subject to privatisation, which is intended to ensure the preservation of strategically important geological information and eliminate data duplication.
The law introduces a mechanism for conducting electronic auctions for the granting of subsoil use rights. Auctions will apply both to vacant subsoil plots and to plots for which subsoil use rights have been terminated.
At the same time, a priority right for the exploration and extraction of solid minerals is established for strategic investors implementing large industrial and innovation projects with a value exceeding 14.5 million Monthly Calculation Indices (MCI) 3 (approximately KZT 62,712,500,000). In such cases, subsoil use rights may be granted outside the auction procedure, subject to compliance with the established requirements.
The amendments increase the minimum share of in-country value in works and services procured for exploration and extraction operations, including uranium, from 50% to 70% of the total annual volume.
A separate set of changes concerns subsoil use at sites hosting technogenic mineral formations located within the boundaries of populated areas. One of the conditions for obtaining a license is the mandatory removal of such formations outside populated areas and their subsequent processing.
For solid mineral processing projects, investment incentives are provided, including exemptions from corporate income tax and land tax for 10 years, from property tax for 8 years, and from VAT on the import of equipment for 5 years. The minimum investment threshold for concluding a processing agreement is increased from 7 million to 70 million MCI.
At the same time, a draft order of the Ministry of Energy of the Republic of Kazakhstan has been prepared to amend the Rules for the procurement of goods, works, and services by subsoil users and their contractors in the exploration and production of hydrocarbons.
The draft provides for the rejection of tender bids with a procurement value exceeding 20,000 MCI in the absence of the supplier's tax reporting for the past three years or in the absence of cash flow reflected in the tax reports.
The purpose of these changes is to exclude shell companies, sham entrepreneurs, and persons evading tax payments from participation in procurement procedures.
Footnotes
1. Unified Subsoil Use Platform (see: https://minerals.e-qazyna.kz/ru/start)
2. See: https://www.gov.kz/memleket/entities/energo/press/news/details/1093923?lang=ru
3. MCI (Monthly Calculation Index) is a coefficient established annually by the Law "On the Republican Budget" and used to calculate taxes, fines, social benefits, and other payments; for 2026, the MCI is set at KZT 4,325 pursuant to Law No. 239-VIII "On the Republican Budget for 2026–2028" dated 8 December 2025.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
