1. Overview of the Renewable Energy Sector
1.1 What is the basis of renewable energy policy and regulation in your jurisdiction and is there a statutory definition of ‘renewable energy', ‘clean energy' or equivalent terminology?
The legal framework for renewable energy in Kazakhstan is mainly regulated by the following laws and regulations:
- Law on Support of the Use of Renewable Energy Sources dated 4 July 2009 No. 165-IV (Law on RES).
- Law on Electric Power Industry dated 9 June 2004 No. 588.
The Kazakhstan government adopted the following state programmes that are aimed at the development of renewable energy sources (RES):
- Concept on Transition to Green Economy of the Kazakhstan Republic.
- Strategy for achieving carbon neutrality of the Republic of Kazakhstan until 2060.
- Concept for the Development of the Electric Power Industry of the Republic of Kazakhstan for 2023–2029.
- Kazakhstan's Energy Balance Plan for 2035.
- National Infrastructure Plan of the Republic of Kazakh-stan until 2029.
- Concept of Development of the Fuel and Energy Complex of the Republic of Kazakhstan for 2023–2029.
The Law on RES defines RES as energy sources that are continuously renewable due to naturally occurring processes, including the following types: solar radiation energy; wind energy; hydrodynamic water energy; geothermal energy, heat of the soil, groundwater, rivers, reservoirs; as well as anthropogenic sources of primary energy resources, consumer waste, biomass, biogas and other fuel from consumer waste used for the production of electrical and (or) thermal energy.
1.2 Describe the main participants in the renewable energy sector and the roles which they each perform.
The main participants of the renewable energy sector range from private sector companies operating renewable energy facilities to state authorities, which oversee and support participants. The Ministry of Energy implements state policy to support the use of RES.
The Kazakhstan Electricity Grid Operating Company (KEGOC), the electricity transmission system operator of the unified power system of Kazakhstan, and energy transmitters and energy suppliers are responsible for the transmission and distribution of electricity.
Energy transmitting organisations and energy supplying organisations are responsible for transmission and distribution.
The Kazakhstan Electricity and Power Market Operator (KOREM) acts as an operator of the centralised trading market and an auction organiser.
The Financial Settlement Centre (FSC) carries out centralised purchase and sale of electric energy produced by renewable energy facilities.
Energy producing organisations supply RES and qualified conditional consumers act as consumers of electricity produced by RES.
Other participants include thenon-profit associations Qazaq Green, the Association of Renewable Energy of Kazakhstan and the Association of Regional Environmental Initiatives (ECOJER) that play a significant role in renewable energy promotion. Development banks and financial institutions provide financing and technical assistance for construction and commissioning of renewable energy facilities.
1.3 Describe the government's role in the ownership and development of renewable energy and any policy commitments towards renewable energy, including applicable renewable energy targets.
The Ministry of Energy is the main authorised state authority for renewable energy development in Kazakhstan. It implements state policy, approves technical regulations and national standards, sets targets, moderates every aspect of RES auctions, regulates centralised power purchase and tariffs, and engages in international cooperation.
The Concept on Transition to Green Economy targets 15% from renewable energy in the total electricity production by 2030, and 50% from alternative and renewable sources by 2050.
According to the Strategy on Achieving Carbon Neutrality of the Kazakhstan Republic 2060, it is planned to gradually reduce coal-fired generation with active development of RES in electricity and heat supply, including small-scale installations, smart grids and technologies, as well as decarbonisation of buildings via RES.
Pursuant to the Concept of Development of the Fuel and Energy Complex of the Republic of Kazakhstan for 2023–2029, it is planned to implement RES projects with a total capacity of 4,000 megawatts (MW), including with energy storage systems (ESS) by 2029.
In 2025, the Ministry of Energy announced the auction schedule to select projects for renewable energy facilities construction. The total installed capacity auctioned in 2025 is 1,810 MW, broken down by a type of power plant:
- solar power plants (SPPs) – 90 MW;
- wind power plants (WPPs) – 1,200 MW;
- hydropower plants (HPPs) – 500 MW; and
- biogas power plants (biogas plants) – 20 MW.
In 2025, for the first time, an auction was held for a 1,000 MW wind power plant with an energy storage system in the Northern Zone of Kazakhstan's Unified Power System.
Most of the renewable energy facilities are owned and developed by the private sector with government support. It is done in the form of guaranteed purchase of the entire volume of RES electricity at fixed tariffs or auction prices and distribution to conventional power plants at the renewable energy support tariff.
2. Renewable Energy Market
2.1 Describe the market for renewable energy in your jurisdiction. What are the main types of renewable energy deployed and what are the trends in terms of technology preference and size of facility?
Solar and wind energy are the most widely deployed sources of renewable energy in Kazakhstan. Based on wind atlas of Kazakhstan developed in 2009, the potential of wind is estimated at approximately 900,000 GWh of electricity per year. According to the solar atlas of Kazakhstan, the southern part of the country has a huge potential for development of solar energy, with the potential estimated at 2.5 billion kWh per year. Based on estimates by experts, Kazakhstan has a substantial hydropower potential – 170 billion kWh, with 30 billion economically viable.
As of the end of June 2025, 156 RES facilities are in operation, with a total installed capacity of 3122.12 MW:
- 63 WPPs – 1,570.05 MW;
- 48 SPPs – 1,262.61 MW;
- 42 HPPs – 287.685 MW; and
- three biogas plants – 1.77 MW.
In 2025, it is envisaged to implement nine RES projects with the total installed capacity of 455.5 MW (five WPPs – 387.5 MW, two HPPs – 28 MW, and two SPPs – 40 MW).
In 2024, the concept of a small-scale renewable energy facility (up to 200 kW) was introduced into the Law on RES, allowing owners to use energy for their own needs and sell the excess. Individuals or legal entities that own such facilities and are connected to grids with a separate metering system are recognised as net consumers. Energy transmission organisations are obliged to ensure their unimpeded connection to the electric grid, subject to the requirements for the installation of metering devices.
Kazakhstan's experience with waste-to-energy (WtE) projects is still emerging, but several promising projects and plans are underway.
2.2 What role does the energy transition have in the level of commitment to, and investment in, renewables? What are the main drivers for change?
Kazakhstan ratified the Paris Agreement in 2016 and submitted its National Determined Contributions, aimed at reducing greenhouse gas emissions by 15% by 2030 from the 1990 levels.
The Concept on Transition to Green Economy of the Kazakhstan Republic and the Strategy on Achieving Carbon Neutrality of the Kazakhstan Republic 2060 highlight the importance of RES in transition to green economy and carbon neutrality.
Main drivers for the change are energy transition targets set in state policies driven by decarbonisation and the climate change agenda.
2.3 What role, if any, has civil society played in the promotion of renewable energy?
Civil society is generally supportive of renewable energy development, except some industrial groups that use conventional energy such as coal, petroleum, and gas.
Some industrial groups are shifting towards developing RES facilities in order to support the green economy agenda promoted by the government. Under the Law on RES, qualified conditional consumers include conditional customers that are energy producing organisations using coal, gas, sulphur-containing raw materials, oil products and nuclear fuel that operate RES facilities. Qualified conditional consumers are obliged to conclude annual contracts with the FSC for the purchase of electricity produced by energy producing organisations using RES, energy waste disposal and flood electricity.
2.4 What is the legal and regulatory framework for the generation, transmission and distribution of renewable energy?
The Law on RES, the Law on Electric Power Industry dated 9 June 2004 No. 588 and by-laws provide a legal and regulatory framework for the generation, transmission, and distribution of renewable energy.
2.5 What are the main challenges that limit investment in, and development of, renewable energy projects?
Kazakhstan's Model Power Purchase Agreement (PPA) for renewable energy projects presents several bankability challenges that may deter investors and lenders. One of the key issues is the absence of a change of law clause, leaving developers without protection or reimbursement if legal or regulatory changes negatively impact project economics. Additionally, the force majeure provisions are vague, creating uncertainty in unforeseen circumstances. While the law mandates the single buyer to purchase electricity from RES producers, transmission companies are not obligated to accept or deliver the full output, undermining the take-or-pay principle. Moreover, the PPA lacks clear risk allocation for curtailment and grid downtime, exposing developers to revenue losses without compensation.
The Model PPA provides limited protection for investors, as it is not subject to negotiation or revision to reflect investor-specific risks. Notably, it lacks provisions addressing early termination due to the offtaker's default and does not ensure payment of termination compensation, leaving investors exposed to significant risk.
There are also challenges regarding the return on investment in energy storage projects. The auction framework presumes that project developers will recoup their investments through the applicable renewable energy tariffs, with the ceiling rates currently set at 34.61 tenge/kWh for SPPs and 22.68 tenge/kWh for WPPs. These tariffs do not include the costs of installing ESS, which makes such projects economically unviable for investors.
2.6 How are large utility-scale renewable power projects typically tendered?
Kazakhstan implements various types of renewable energy projects through mechanisms such as auctions, direct agreements, corporate PPAs among group companies, and Intergovernmental Agreements (IGAs). Most projects are auction-based and generally moderate in scale, typically ranging from 20 MW to 50 MW, occasionally reaching up to 100 MW. Notably, the only recent large-scale project, a 1 gigawatt (GW) wind power plant with ESS, is currently being implemented, with the winner having been selected through the auction framework.
Recent practice indicates that GW-scale renewable energy projects in Kazakhstan are primarily implemented through IGAs. These agreements, signed on a case-by-case basis with the government, serve as an alternative mechanism for developing large utility-scale projects. IGAs can take precedence over certain national legal provisions and offer investors customised legal, regulatory, and fiscal conditions. These may include exemptions from standard requirements, stabilisation clauses, customs and tax incentives, guaranteed tariffs, and assured access to land and infrastructure. To date, Kazakhstan has signed and ratified IGAs for GW-scale renewable projects equipped with ESS with France and the UAE. Meanwhile, IGAs with China and the Kingdom of Saudi Arabia remain at various stages of negotiation and legislative approval and have not been yet ratified.
2.7 To what extent is your jurisdiction's energy demand met through domestic renewable power generation?
As set out in the Concept for the Development of the Electric Power Industry of the Republic of Kazakhstan for 2023–2029, Kazakhstan aims to increase the share of electricity generated from RES to 12.5% of total electricity production by 2029. The annual targets are as follows:
- 2023 – 5%.
- 2024 – 5.5%.
- 2025 – 6%.
- 2026 – 7%.
- 2027 – 8%.
- 2028 – 10%.
These figures reflect the government's strategic commitment to gradually expanding domestic renewable energy generation to meet the growing energy demand.
According to the Ministry of Energy, by the end of June 2025, electricity generated from RES facilities accounted for 6.81% of the total energy production of Kazakhstan.
3. Sale of Renewable Energy and Financial Incentives
3.1 What is the legal and regulatory framework for the sale of utility-scale renewable power?
Electricity generated from RES can be sold through several mechanisms. Most commonly, RES producers enter into long-term PPAs with the FSC under fixed tariffs or auction-based tariffs. Alternatively, corporate PPAs are possible for direct sales to large consumers at negotiated prices, outside of regulated tariffs but within the one group of companies as specified by the Law on RES, meaning it is not universally available to every company. RES producers may also participate in the wholesale and balancing electricity markets, provided they meet grid access and forecasting requirements.
3.2 Are there financial or regulatory incentives available to promote investment in/sale of utility-scale renewable power?
RES legislative framework, inter alia, provides for the following support measures:
- guaranteed purchase of all electricity produced and supplied to the grid;
- PPA is concluded at auction prices for 20 years;
- creation of a reserve fund at the FSC;
- one-time indexation during construction and annual indexation of tariffs;
- exemption from payment for the transmission of electric energy; and
- reservation of the land plots and grid connection points for conducting auctions.
Investment preferences are provided depending on the type of investment projects. Renewable energy facilities fall under the category of investment and priority investment projects implementation. Investment preferences include tax preferences, state in-kind grants and exemption from custom duties.
3.3 What are the main sources of financing for the development of utility-scale renewable power projects?
In Kazakhstan, renewable energy projects are commonly structured using project finance models that combine both debt and equity funding. This allows investors to spread their risk and provides them with a stake in the project's success.
The country has also expressed a commitment to leveraging green bonds as a financing tool for renewable initiatives.
3.4 What is the legal and regulatory framework applicable to distributed/C&I renewable energy?
Distributed and commercial and industrial (C&I) renewable energy projects are governed by the Law on RES, the Law on Electric Power Industry dated 9 June 2004 No. 588, and several by-laws such as rules for connecting to electrical networks and operating small-scale facilities, and rules for the purchase and sale of electrical energy from net consumers.
3.5 Are there financial or regulatory incentives available to promote investment in distributed/C&I renewable energy facilities?
Net consumers of electric energy can use electricity and/or heat generated by RES for self-consumption and sell surplus electricity to energy supply organisations. The surplus is purchased at a capped price set by the Committee for the Regulation of Natural Monopolies. Energy supply companies are obliged to buy this surplus and transmission companies must ensure grid access.
Small hydropower plants of up to 10 MW are allowed to sell excess electricity directly to non-regulated energy supply organisations, creating new revenue streams and improving project bankability.
The government introduced budget lending programmes to strengthen regional grid companies, which indirectly support the integration of small-scale renewable energy facilities. By improving grid reliability and reducing connection risks, these measures enhance the bankability of distributed and C&I renewable projects and make them more attractive to potential investors.
Moreover, under the Draft Law on Alternative Energy Sources, distributed generation is defined as a power plant with a capacity of 35 MW or less, operating either autonomously or in parallel with the centralised power supply system. Introduction of the distributed generation term is necessary for regulating small-scale generation facilities that can operate autonomously. This will contribute to the decentralisation of the power system and reduces losses during electricity transmission.
3.6 What are the main sources of financing for the development of distributed/C&I renewable energy facilities?
Although financing for distributed and C&I renewable energy projects in Kazakhstan remains limited and commercial banks are still cautious toward such projects, the situation is gradually improving.
Green bonds have emerged as a financing tool to support small-scale renewable energy projects, particularly for SMEs, through placements on the Astana International Exchange.
3.7 What is the legal and regulatory framework applicable to the development of green hydrogen projects?
Kazakhstan's Hydrogen Energy Development Concept, until 2030, serves as the key legal framework for developing hydrogen energy. The Concept envisions ambitious targets: at least 25,000 tonnes of hydrogen production by 2030 (with green hydrogen representing 50%).
In the absence of a dedicated hydrogen law, green hydrogen projects are regulated indirectly via existing regulations related to energy, industry and the environment, including the Law on RES, Environmental Code, as well as standards applying to flammable materials.
A Draft Law on Alternative Energy Sources is currently being developed to specifically regulate hydrogen by introducing definitions such as “hydrogen energy” in the Law on RES, referring to a range of technologies, processes, and infrastructure associated with generating electricity using hydrogen.
3.8 Are there financial or regulatory incentives available to promote investment in green hydrogen projects?
There are currently no dedicated financial or regulatory incentives specifically tailored for green hydrogen projects in Kazakhstan. However, the following frameworks provide partial or potential support.
Under taxonomy of green projects approved by government decree, installations for production of hydrogen with renewable energy are classified as green projects to be financed by green bonds and green loans.
Kazakhstan's Hydrogen Energy Development Concept until 2030 outlines plans to establish national standards for hydrogen technologies, particularly in the area of safety, and to introduce subsidies and support measures aimed at fostering the growth of the hydrogen industry.
3.9 What are the main sources of financing for the development of green hydrogen projects in your jurisdiction?
Green hydrogen projects are at a preliminary development stage. Generally, the main sources of financing for large-scale infrastructure projects in the renewable energy field are project finance, debt financing and equity. The same sources are likely to be employed for green hydrogen projects. Green loans and green bonds are emerging as key financing tools for green hydrogen projects.
3.10 What is the legal and regulatory framework that applies for clean energy certificates/environmental attributes from renewable energy projects?
The International REC Standard Foundation has approved Kazakhstan for I-REC for Electricity issuance. The ECOJER is the issuer of I-REC. I-REC certificates in Kazakhstan can be sold either through direct bilateral agreements with buyers or via intermediaries such as traders or brokers. These certificates verify that a specific quantity of electricity was generated from renewable sources.
In early 2025, the Astana International Exchange received accreditation from the I-TRACK Foundation as an official platform operator for I-RECs. This milestone marked a key step in the rapid development of Kazakhstan's I-REC market, with the first transaction taking place in February 2025 between a domestic renewable energy generator and a global trading firm.
3.11 Are there financial or regulatory incentives or mechanisms in place to promote the purchase of renewable energy by the private sector?
The single buyer (FSC) purchases all electricity generated from RES and sells it as part of the overall electricity mix to end consumers. As a result, end consumers effectively pay for all electricity, including that produced from RES. Currently, there are no specific support mechanisms or incentives provided directly to end consumers for consuming renewable electricity.
3.12 Is there a mandatory (or a developed voluntary) carbon emissions trading market in your jurisdiction?
Kazakhstan already operates a mandatory cap-and-trade carbon emissions trading system (KazETS) established under the Environmental Code. It applies to installations emitting over 20,000 tonnes of CO2 annually, predominantly in energy, mining, metallurgy, oil and gas, and manufacturing sectors. KazETS consists of primary and secondary carbon markets. In the primary market, the carbon trading system operator sells carbon quota units from the relevant reserve category of the National Quota Plan at auction. In the secondary carbon market, entities buy and sell carbon units among themselves through direct transactions or through a commodity exchange.
Additionally, a voluntary carbon market exists. In 2023, the Kazakhstan Voluntary Carbon Certificate Programme was introduced by Qazaq Green, creating a domestic standard for carbon offsets designed to meet ESG needs of private companies outside a mandatory market.
3.13 What is the legal and regulatory framework applicable to the development of carbon capture and storage projects?
Kazakhstan does not have a standalone and specific legal and regulatory framework related to carbon capture and storage.
The Environmental Code obliges enterprises to use the best available techniques. Carbon capture and storage is referred to as promising technologies under the government decree on the approval of the reference book on the best available techniques.
The Subsoil Use Code governs the use of underground resources and could theoretically apply to underground CO2 storage. However, CO2 geological storage is not explicitly defined or regulated as subsoil use activities.
Based on the Strategy for achieving carbon neutrality of the Republic of Kazakhstan until 2060, it is planned to develop a vision for the decommissioning of coal-fired power plants with a current operating life of more than 30 years and the introduction of carbon capture and storage technology for those units that will continue to operate after 2035.
3.14 Are there financial or regulatory incentives available to promote investment in carbon capture and storage projects?
As of now, there are no financial or regulatory incentives specifically for carbon capture storage projects. However, Taxonomy of Green Projects (approved by Government Decree) defines carbon capture and storage technologies as green projects, making them eligible for financing via green bonds issuance and green loans.
3.15 What are the main sources of financing for the development of carbon capture and storage projects in your jurisdiction?
As of now, there are no carbon and capture storage apart from pilot projects to be implemented by industrial companies. As with other large-scale infrastructure initiatives, particularly in the low-carbon and renewable energy sectors, project finance, debt financing and equity investment remain the primary sources of funding for carbon capture and storage projects. Similarly, green loans and green bonds are emerging as important financing instruments for such projects, especially where they align with Kazakhstan's green taxonomy and decarbonisation goals.
4. Consents and Permits
4.1 What are the primary consents and permits required to construct, commission and operate utility-scale renewable energy facilities? Does the consenting and permitting regime differ for specific types of renewable energy facilities, such as nuclear, offshore wind, battery storage, or others?
The primary permit to launch a project is to obtain land use rights. It includes: permission to use land plot for engineering survey activities; inclusion in the renewable energy facilities siting plan as part of auction; and in-kind grant for temporary gratuitous use of land.
When developing a HPP, the developer must obtain the right for water use as well. A permit for special water use is issued by the regional branches of the authorised body, Catchment Authorities of the Ministry of Agriculture of the Republic of Kazakhstan.
The construction and operation of renewable energy facilities requires several stages of project procedures and design. Request for the provision of source materials is submitted to local state authorities. Source materials include architectural planning specifications, technical specifications for connection to the sources of engineering and utility provision, cross profiles of roads and streets, vertical design elevations, extracts of the detailed design plan and layout scheme of external utility networks. After receiving source materials, the schematic design is developed, which must be approved by local executive authorities.
Design documentation is developed by individuals and legal entities that are licensed for the relevant types of survey and design activities in architecture, urban planning and construction under Law on Permissions and Notifications. Design documentation is considered complete after approval by local executive authorities.
Furthermore, depending on the specifics of the renewable energy facility, the feasibility study and design documentation may be subject to additional approval by the Ministry of Agriculture for land management, the authorised body for the study of mineral resources, the Ministry of Emergency Situations in the field of civil protection and in the field of industrial safety, the Ministry of Transport of the Republic of Kazakhstan for water transport issues, as well as the local executive authorities in which territory the construction of the renewable energy facility is planned.
For the implementation of construction and installation works, the investor must conclude an agreement with a specialised organisation that has a state licence on construction and installation works, stipulated in the Law on Permissions and Notifications, for implementing these works.
Finally, the investor should obtain an entitlement document with a note on the introduction to the information system of the legal cadaster of a newly created immovable property and renewable energy facility.
4.2 What are the primary consents and permits required to construct, commission and operate distributed/C&I renewable energy facilities?
In general, the permitting and consent requirements applicable to utility-scale renewable energy projects, as outlined in question 4.1, also apply to distributed and C&I renewable energy facilities in Kazakhstan.
At the same time, recent regulatory developments have introduced a more tailored approach for small-scale renewable energy facilities regarding connection to the electrical grid and its operation.
Technical conditions for connecting a small-scale renewable energy facility to the electrical grid are issued to the net consumer on the basis of a notification. The validity period of the technical conditions is one year. No fee is charged for the issuance or re-issuance of the technical conditions.
The transmission organisation, upon receiving a notification from the net consumer, issues the technical conditions within the following timeframes:
- for facilities with a capacity of up to 100 kW – within three business days from the date of receipt of the notification; and
- for facilities with a capacity from 100 to 200 kW – within five business days from the date of receipt of the notification.
Commissioning of RES small-scale renewable energy facilities is carried out by the transmission organisation by verifying that the works performed comply with the technical conditions, within three business days from the date of receipt of a notification in free form from the net consumer about the completion of works.
4.3 What are the requirements for renewable energy facilities to be connected to and access the transmission network(s)?
A request to identify the closest connection point should be submitted to an energy transmission organisation. In addition, an investor contacts a specialised project organisation, which will develop the power generation scheme. KEGOC, an electricity transmission system operator, agrees on the “power generation scheme” with the organisation, to whose grid connection is planned to be done.
An energy producing organisation, planning the creation (expansion and reconstruction) of new or existing renewable energy facilities, and an energy transmission organisation, to whose electrical grids the facilities are directly connected, sign a standard agreement on the facilities connection under the control of authorised bodies in the RES and electric power industry sectors.
Renewable energy facilities are exempted from payment for the transmission of electricity in case of electricity sale to the FSC.
4.4 What are the requirements for renewable energy facilities to be connected to and access the distribution network(s)?
Requirements for energy transmission for renewable energy facilities to be connected to and access the distribution network are the same as for the connection to transmission network (see question 4.3).
4.5 Are microgrids able to operate? If so, what is the legislative basis and are there any financial or regulatory incentives available to promote investment in microgrids?
There is no legal definition of microgrids under the Law on RES. Nevertheless, microgrids are able to operate with electricity consumed from a renewable energy facility operating in an off-grid mode in non-electrified settlements and/or settlements, where centralised electricity supply is not economically feasible.
4.6 Are there health, safety and environment laws/regulations which should be considered in relation to specific types of renewable energy or which may limit the deployment of specific types of renewable energy?
The Environmental Code requires enterprises to conduct an Environmental Impact Assessment (EIA), depending on hazard class. The investor and project developer should take into account the results of the EIA and ensure the least damage is done to the environment and health. The EIA procedure results in the preparation of an environmental management plan, and the results are then submitted for the state environmental expert review. Environmental permits for emissions are issued by authorised environmental protection bodies, depending on hazard class.
Project developers, including renewable energy, should comply with fire, industrial, and health and safety regulations and instructions under the Kazakhstan legislation. Non-compliance may lead to administrative or criminal liability in case of severe damage to health and safety.
5. Storage
5.1 What is the legal and regulatory framework which applies to energy storage and specifically the storage of renewable energy?
The Law on RES defines ESS as a technical device with an automated control system designed for accumulation, storage and output of electric energy, and interconnected facilities and infrastructure technologically necessary for its operation. The Law on RES also allows ESS to be part of renewable energy projects, including within auction mechanisms, but it does not mandate their inclusion.
The operation of ESS is regulated by the Electric Grid Rules and Rules of Technical Operation of Electric Power Plants and Grids, which establish requirements for the management, testing, technical condition and participation of ESS in frequency regulation and power flows.
5.2 Are there any financial or regulatory incentives available to promote the storage of renewable energy?
There are currently no dedicated financial support schemes specifically for energy storage in Kazakhstan.
Separate incentives may be considered in IGAs on the development of large-scale renewable energy projects.
5.3 What are the main sources of financing for the development of energy storage projects in your jurisdiction?
Energy storage projects in Kazakhstan are currently at a nascent development stage and tend to be financed alongside with projects on construction of the wind and SPPs. Project finance, debt financing and equity investment remain the primary sources of funding.
6. Foreign Investment and International Obligations
6.1 Are there any special requirements or limitations on foreign investors investing in renewable energy projects?
There are no special limitations on foreign investors investing in renewable energy projects. The government encourages and welcomes foreign investment and constantly improves the legal framework in order to increase the investment attractiveness of Kazakhstan, including the renewable energy sector.
Renewable energy projects are included in the priority investment project category. The priority investment project is a project for the creation of new production facilities, providing for investment by a legal entity in the construction of new production facilities in an amount no less than approximately US$15 million; for the expansion and/or renovation of existing production facilities, providing for an investment by a legal entity in the amount no less than approximately US$37 million.
6.2 Are there any currency exchange restrictions or restrictions on the transfer of funds derived from investment in renewable energy projects?
Currency transaction is subject to registration with the National Bank in the following cases: the receipt of property (money) in Kazakhstan and/or occurrence of obligations of a resident to return property (money) to a non-resident in the amount exceeding US$500,000; and the transfer of property (money transfer) from Kazakhstan and/or occurrence of the resident's requirements to return the property (money) by non-resident in the amount exceeding US$500,000.
The repatriation of national and/or foreign currency is ensured within the time frame stipulated by the currency export or import contract. Repatriation of national and/or foreign currency on export or import consists of crediting to bank accounts in authorised banks: proceeds in national and/or foreign currency from exports; and national and/or foreign currency, transferred by a resident in favour of a non-resident to make settlements on import, in cases of non-fulfilment or incomplete fulfilment of obligations by a non-resident.
6.3 Are there any employment limitations or requirements which may impact on foreign investment in renewable energy projects?
There are no specific employment limitations or requirements that may impact foreign investments. Nevertheless, investors should obtain permission to attract foreign employees, the quantity of which is regulated by the relevant quota.
Generally, all work on occupational health and safety should be aimed at creating a system of organisational measures and technical means, designed to prevent exposure of workers to dangerous production factors.
6.4 Are there any limitations or requirements related to equipment and materials which may impact on foreign investment in renewable energy projects?
RES auction winners are required to only use new equipment for construction of RES facilities.
In 2023, KazStandard, with the support of the ECOJER Association, developed 11 new national standards aimed at harmonising the deployment of renewable energy technologies in Kazakhstan. These standards cover a wide range of areas, including technical specifications, safety requirements, and performance criteria for renewable energy equipment, such as solar panels, wind turbines, and related infrastructure. Although currently non-binding, these standards serve as an important guidance framework for developers, suppliers, and investors.
7. Competition and Antitrust
7.1 Which governmental authority or regulator is responsible for the regulation of competition and antitrust in the renewable energy sector?
The Agency on the Protection and Development of Competition (Antimonopoly Agency) is the national governmental authority responsible for managing the protection of competition and limitation of monopolistic activities, control, and regulation of activities classified as state monopoly, as well as state control and the licensing of activities in the field of commodity exchange, including the renewable energy sector.
7.2 What power or authority does the relevant governmental authority or regulator have to prohibit or take action in relation to anti-competitive practices?
The Antimonopoly Agency can initiate an investigation upon the receipt of a complaint or at its own initiative. It can also request the information necessary for conducting the investigation from any entity operating on the market or from State bodies. Upon completion of proceedings, the Antimonopoly Agency may impose fines or remedial measures and terminate contracts that violate the competition legislation.
7.3 What are the key criteria applied by the relevant governmental authority or regulator to determine whether a practice is anti-competitive?
Horizontal agreements are prohibited if such agreements may result in or lead to: the establishment or maintenance of prices (tariffs), discounts, extra charges (extra payments) and/or markups; the increase, decrease or maintenance of prices at the auctions, distortion of the results of trades, auctions and contests, including by dividing by lots; the division of the commodity market on a territorial basis, the volume of sale or purchase of goods, the range of goods sold or the composition of sellers or customers (clients); the reduction or termination of the goods production; or the refusal to conclude contracts with certain sellers or customers (clients).
Vertical agreements between market entities are prohibited if such agreements result in or lead to the establishment of the resale price of the goods, unless the seller establishes for the customer (client) the maximum resale price of the good. Such an agreement provides for the obligation of the customer (client) not to sell the goods of a market entity that is a competitor of the seller. This prohibition does not apply to agreements on the organisation by the customer of the sale of goods under a trademark or other means of individualisation of the customer or producer; such an agreement provides for the seller's obligation not to sell goods to a market entity that is a competitor of the customer (client).
The concerted actions of market entities engaged in the production and sale of goods aimed at restricting competition are prohibited, including those concerning: economically, technologically, and otherwise unjustified setting of different prices (tariffs) for the same product by market participants; the conclusion of contracts on the condition that the counterparties assume additional obligations that, in terms of their content or in accordance with business practice, do not relate to the subject matter of these contracts (unjustified demands for the transfer of financial resources and other property, property rights or non-property rights); restricting access to the commodity market or removing other market participants from it as sellers (suppliers) of certain goods or their buyers; the unreasonable restrictions on the production or sale of goods; the unreasonable refusal to conclude contracts with certain sellers (suppliers) or customers; and the application of discriminatory conditions to equivalent contracts with other entities.
The prohibitions set out above on anti-competitive agreements do not apply to agreements between market participants belonging to the same group of persons if one of such market participants exercises control over another market participant, or if such market participants are controlled by the same person.
8. Dispute Resolution
8.1 Provide a short summary of the dispute resolution framework (statutory or contractual) that typically applies in the renewable energy sector, including procedures applying in the context of disputes between any applicable government authority/regulator and the private sector.
There is no specific dispute resolution framework applicable to renewable energy. Mainly, disputes are resolved through litigation or arbitration.
The parties to the agreement may specify in the contract the arbitration clause, except in cases where the dispute can be resolved only in the state courts of the Republic of Kazakhstan. Currently, the Astana International Financial Centre (AIFC) courts and the AIFC arbitration are gaining popularity among parties when stipulating dispute resolutions in agreements. The AIFC is a financial hub attracting, implementing, and protecting local and foreign investments based on the common law.
8.2 Are alternative dispute resolution or tiered dispute resolution clauses common in the renewable energy sector?
The Kazakhstan court system consists of three layers: the court of the first instance; the Appellate Court; and the Supreme Court. Mainly, disputes in the RES sector are resolved by litigation or arbitration. Under Model PPA with the FSC, disputes may be resolved by the International Arbitration Centre of the AIFC. Before concluding the Arbitration Agreement, the FSC shall make a request to the Ministry of Energy for consent to conclude such agreement.
8.3 What interim or emergency relief can the courts grant?
Under the Kazakhstan legislation, claimants may apply to the court for an injunction in order to secure their claim at any stage of litigation proceedings. Injunctions include, but are not limited to: the imposition of arrest on property owned by the defendant and held by him/her or other citizens; the prohibition to the defendant to perform certain actions; the prohibition to other persons to transfer property to the defendant or perform other obligations in relation to him/her, as provided by the law or contract; the suspension of the sale of property in the event of a claim for the release of property from seizure; the suspension of the contested legal act of a state body or local government body; the suspension of recovery upon an enforcement document contested by a debtor in the court proceedings; the suspension of bidding for out-of-court sale of the item under the loan; and the suspension of the disputed acts and actions of the judicial executor connected with the address of collecting on the property made in the enforcement proceeding.
8.4 Is your jurisdiction a party to and has it ratified the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards and/or the Convention on the Settlement of Investment Disputes between States and Nationals of Other States and/or any significant regional treaty for the recognition and enforcement of judgments and/or arbitral awards?
Kazakhstan has been a party to the New York Convention on the Recognition and Enforcement of Arbitral Awards since 1995. Although Kazakhstan has not formally ratified the Convention, it is considered binding with regard to enforcement of foreign arbitral awards.
8.5 Are there any specific difficulties (whether as a matter of law or practice) in litigating, or seeking to enforce judgments or awards, against government authorities or the state?
Under the Kazakhstan legislation, a party may protect its interests by all available legal means, starting from filing a lawsuit in court and ending with indispensable measures of decision executions. Generally, there are no difficulties litigating against government authorities.
8.6 Are there examples where foreign investors in the renewable energy sector have successfully obtained domestic judgments or arbitral awards seated in your jurisdiction against government authorities or the state?
To date, we are not aware of the cases where foreign investors in the renewable energy sector have successfully secured domestic court judgments or arbitral awards against government authorities or the state in Kazakhstan.
9. Updates and Recent Developments
9.1 Please provide a summary of any recent cases, new legislation, regulations, and policy announcements in renewables in your jurisdiction.
In 2024, Kazakhstan's legislation on renewable energy, electric power industry, and the balancing market was amended to include projects with ESS. As of 2025, the legal framework for such projects is still under development.
Under the Draft Law on Alternative Energy Sources, it is planned to introduce a definition of alternative energy, which refers to a sector of power generation that encompasses technologies and methods for producing, converting, storing, and distributing energy from both renewable and non-renewable sources. Non-renewable sources in this context exclude traditional fossil fuels (oil, gas and coal) and include hydrogen energy, nuclear power, syngas, industrial and metallurgical gases, and waste heat used for electricity and/or heat production.
The Draft Law on Alternative Energy Sources also aims to enhance the legal framework for ESS in Kazakhstan by fully integrating them into the Kazakhstan's unified power system. It envisions the introduction of a structured revenue model for storage, including participation in the wholesale electricity market and balancing services, with mechanisms such as arbitrage pricing and introduction of a separate auction mechanism for ESS. The Draft Law also proposes a classification of ESS, including:
- residential ESS;
- battery energy storage systems (BESS) – based on rechargeable battery technologies; and
- behind-the-meter storage systems – designed to serve individual consumers or facilities, operating independently from grid-level controls.
In 2024, the Law on Thermal Power Engineering was enacted, supporting the development of sustainable and efficient thermal energy infrastructure, including integration with renewable sources where feasible. It provides a support measure in the form of deploying public-private partnership mechanisms for the implementation of energy saving measures and the introduction of RES into heat supply projects, taking into account economic and technical feasibility.
In 2024, Kazakhstan's legal framework introduced the concept of a hybrid group – a cluster of entities within the wholesale electricity market operating in the same energy hub, collectively generating at least 25% of their electricity from RES. This innovative structure enables the integration of renewable energy projects with complementary sources, such as natural gas, enhancing flexibility and reliability.
In 2025, amendments were introduced to the auction qualification requirements for renewable energy projects, dividing them into two categories: (1) projects with an installed capacity up to 499 MW; and (2) projects over 499 MW. Moreover, winners of auctions for projects over 499 MW are required to construct and commission an energy storage system simultaneously with the renewable energy facility, with a capacity of at least 30% of the installed capacity of the renewable energy facility and sufficient capacity to deliver power for two hours while maintaining the term of the PPA.
9.2 How do you envisage the renewable energy landscape in your jurisdiction evolving over the next five years?
Over the next five years, Kazakhstan's renewable energy landscape is expected to experience steady and strategic growth, driven by several key factors. Firstly, the government's commitment to its green economy transition, Paris Agreement goals, and carbon neutrality by 2060 will continue to support the expansion of renewable energy, particularly through auctions and IGAs. We anticipate an increase in both domestic and international investment, especially in utility-scale solar and wind projects, renewable waste to energy projects, hybrid projects, as well as emerging areas such as green hydrogen and ESS.
Regulatory and legislative improvements are necessary to facilitate this growth. These include developments of specific legal and regulatory frameworks for green or low-carbon hydrogen with carbon capture and storage technologies and standalone ESS. Without such legal reforms, integration of advanced technologies may face practical and financial hurdles.
Originally published by ICLG.
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.
