Mining 2026

KAZAKHSTAN Trends and Developments Contributed by: Timur Odilov, Mikhail Abdulov, Olzhas Abubakirov and Alnur Dauylbay, Haller Lomax LLP

Under the SSU Amendments, a special new chap - ter has also been introduced establishing an auction procedure for subsoil plots intended for exploration or mining of solid minerals. This mechanism applies to subsoil plots containing recorded reserves and resources included free from ongoing subsoil use operations, areas with identified exploration pros - pects, and territories of expired, invalidated or termi - nated subsoil use contracts. In addition, as mentioned in the corresponding arti - cle on Mining Law and Practice in Kazakhstan in this Global Practice Guide, the Uranium Amendments adopting more stringent uranium regulation have been adopted. Among the adopted Uranium Amendments is a pro - vision making the extension of uranium mining con - tracts conditional on: • KAP holding a direct or indirect interest of not less than 90%; or • transfer by a foreign participant (shareholder) of a joint venture for uranium mining to a KAP or to a legal entity created jointly with it of the technology for the conversion and enrichment of uranium to the form of uranium hexafluoride. This ensures a high level of state control over contract renewals. Investment Attractiveness and the Role of the AIFC Foreign investment trends Kazakhstan’s mining sector continues to attract inter - national investors, driven by the country’s abundant mineral resources and reform introduced under SSU Code. Key investors primarily originate from China, Russia, Canada and Australia, reflecting the global appeal of Kazakhstan’s resource potential. Conse - quently, joint ventures and strategic partnerships are becoming increasingly common, facilitating knowl - edge transfer and the introduction of industry best practices. Notably, there is significant interest from EU coun - tries and the USA regarding the exploration of criti - cal minerals in Kazakhstan. For example, in Q4 2025,

the National Mining Company Tau-Ken Samruk JSC (“Tau-Ken Samruk”) signed an agreement with USA investment firm Cove Capital for the joint development of the Northern Katpar and Upper Kairakty tungsten deposits. The project involves an expected invest - ment of approximately USD1.1 billion. Additionally, the market is witnessing a rising number of “junior” private mining companies entering Kazakh - stan, many of which are foreign investors. While the sector remains active, it is not immune to global economic shifts. Due to a general worldwide slowdown in M&A, a similar deceleration is being observed in the local mining sector. However, signifi - cant deals are still occurring, most notably, the recent acquisition of the Raygorodok Gold Mine by China’s Zijin Mining from RG Gold, the Kazakhstan-based gold mining firm. AIFC There is a marked preference among foreign inves - tors for the AIFC platform over the general jurisdiction when establishing a presence in the country. This is largely because the AIFC operates on common law, a legal framework that is familiar and trusted by inter - national investors. Currently, approximately 300 mining-related compa - nies from 23 different countries are registered within the AIFC. • 35% of these are Asian companies, predominantly from China. • There is also a notable presence of companies from the UK, Turkey, Cyprus and Russia. According to AIFC data, registered mining companies have contributed a total of KZT20.5 billion (approxi - mately USD38.6 million) in taxes. Furthermore, the AIFC is actively working to position itself as a central

hub for the industry. Exploration funding

Historically, exploration funding in Kazakhstan has pri - marily been sourced either directly by subsoil users or through joint ventures formed with senior partners. However, the landscape is beginning to shift, show -

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