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Entrepreneurs in Kazakhstan have started receiving mass notifications from tax authorities due to discrepancies between the number of registered cash registers and officially employed staff. Tax officials are demanding explanations about who actually operates these cash registers. In the business community, this has been called a new tool for uncovering unregistered workers and under-the-table salaries.
The mismatch between the number of registers and employees does not by itself prove any violation. Businesses may have objective reasons: some registers may not be in use, others may be seasonal or backup, and sole proprietors may operate without employees. However, for tax authorities, this discrepancy has become a trigger for inspection.
The new Tax Code, effective from January 1, 2026, enables automatic cross-referencing of reports with cash register data, electronic invoices, and employee records. If the system detects regular transactions through cash registers but few or no employees in the reports, questions arise.
The new Tax Code, effective from January 1, 2026, enables automatic cross-referencing of reports with cash register data, electronic invoices, and employee records. If the system detects regular transactions through cash registers but few or no employees in the reports, questions arise.
What Tax Authorities Can Uncover
By matching data, inspectors can identify:
- unregistered workers
- underreported payroll
- unpaid taxes and social contributions
- formal employment of workers under other entities
- substitution of employment contracts with service agreements
- signs of business fragmentation
If the audit confirms violations, entrepreneurs may face additional assessments of income tax, pension contributions, social payments, and penalties.
What to Do If You Receive a Notice
The notification cannot be ignored — failure to respond may result in restrictions on bank account transactions or limitations on issuing electronic invoices. First, determine the type of document: whether it is an informational warning or a formal notice. Deadlines and response procedures depend on this.
Next, review each register: verify its registration, location, transaction history, and the person operating it. If a register is unused, explain this in your response and deregister it. If the sole proprietor operates the register themselves, note this clearly — the proprietor is not considered an employee.
If an internal review reveals actual violations, avoid a formal reply. Instead, assess any outstanding liabilities, formalize employment relationships, and pay additional taxes and penalties accordingly.
For those who haven't yet received a notice, it is wise to conduct an internal check proactively: verify which registers are linked to your business, deregister unused ones, reconcile the number of operating outlets with employee records, and review service contracts — if a person works on a schedule and follows internal rules, the relationship may be deemed employment regardless of the contract's title.
Next, review each register: verify its registration, location, transaction history, and the person operating it. If a register is unused, explain this in your response and deregister it. If the sole proprietor operates the register themselves, note this clearly — the proprietor is not considered an employee.
If an internal review reveals actual violations, avoid a formal reply. Instead, assess any outstanding liabilities, formalize employment relationships, and pay additional taxes and penalties accordingly.
For those who haven't yet received a notice, it is wise to conduct an internal check proactively: verify which registers are linked to your business, deregister unused ones, reconcile the number of operating outlets with employee records, and review service contracts — if a person works on a schedule and follows internal rules, the relationship may be deemed employment regardless of the contract's title.
How We Can Help
Acsour experts in Kazakhstan are ready to assist you in navigating these new tax controls:
- Audit your HR and tax records.
- Provide full HR administration with guaranteed accuracy.
- Support your company during tax inspections.
Submit a request — our experts will audit your HR and tax records, verify the alignment with cash register data and employee numbers, and help you avoid penalties.