Since June 8, 2026, amendments to Kazakhstan's Labor Code have come into effect, fundamentally changing how businesses are inspected. Labor inspectors will now look beyond the contract's title and examine the actual working conditions. And most importantly — violations will no longer be met with a warning; only fines apply.
Kazakhstan's Ministry of Labor and Social Protection has already clarified how inspections will be conducted and what exactly inspectors will focus on. Here's what you need to know to prepare.
Why the Change
Many companies have long used civil law contracts to save on taxes and social contributions. A person would work like a full-time employee — coming to the office, following a schedule, carrying out instructions — but would officially be listed as a "contractor." As a result, they lost their right to sick leave, vacation pay, and pension savings.
The government is now closing this loophole. If a contract contains even one sign of an employment relationship, it will automatically be deemed an employment contract — regardless of what the parties chose to call it.
How to Tell Employment from Civil Contract
Inspectors will assess the actual relationship, not just the paperwork. Here's what they will look for.
Signs of an Employment Contract (any one is enough):
Work performed in a specific role. The person performs duties tied to a particular profession, specialty, or position.
Personal performance with compliance. The employee works personally, follows a schedule, and adheres to internal company rules.
Regular pay for the process. A fixed salary is paid for the work itself, not for a specific outcome.
When a Civil Contract Is Acceptable:
Payment is for the result. The client pays for a specific volume of completed work or service.
No fixed schedule. The contractor decides when and how to work.
Right to engage others. The contractor may hire subcontractors.
Fixed-term nature. The relationship ends once the result is achieved.
What Fines Are Involved
Allowing a person to work without an employment contract triggers penalties under Article 86 of Kazakhstan's Administrative Code. Warnings are not an option — only fines:
Business Category
First Violation
Repeated Violation
Officials
30 MRP
60 MRP
Small Businesses and NGOs
60 MRP
80 MRP
Medium Businesses
80 MRP
100 MRP
Large Businesses
150 MRP
200 MRP
If the worker is a minor, fines are higher — up to 50–300 MRP depending on the business category.
What Else Will Be Checked
Beyond reclassifying civil contracts, inspectors will review how you enter data into the Unified System for Recording Employment Contracts (USREC). The deadlines are:
for concluding an employment contract — no later than 5 working days;
for amendments and additions — no later than 15 calendar days;
for termination of a contract — no later than 3 working days.
Late submissions trigger fines under Article 98 of the Administrative Code, ranging from 30 to 150 MRP.
How to Prepare Your Business
Review all civil contracts. Make sure they truly reflect civil-law relationships, not disguised employment.
Assess how contractors actually work. If they come to the office, follow a schedule, or use company email — that's a risk.
Reclassify relationships where needed. If a person works like an employee, sign an employment contract.
Set up controls for USREC deadlines. Fines for missing them have not been abolished.
How We Can Help
Acsour experts in Kazakhstan are ready to:
Audit your civil contracts.
Assess the risk of reclassification.
Help bring your HR documentation into compliance with the new requirements.
Support interactions with regulatory authorities.
Help set up timely USREC data submission processes.
Submit a request — our experts will audit your contracts and help you adapt to the new requirements.