KAZAKHSTAN Trends and Developments Contributed by: Timur Odilov, Mikhail Abdulov, Olzhas Abubakirov and Alnur Dauylbay, Haller Lomax LLP
rates for solid minerals extracted from technogenic mineral formations. Coal Regulation There are ongoing efforts suggesting a shift of regula - tory authority over the coal sector from the Ministry of Industry and Construction of RoK to the Ministry of Energy of RoK. At the same time, the coal lobby is reportedly becoming more active, advocating for increased production and higher emission limits, In connection with the adoption of the Uranium Amendments, concerns and pressure are increasing regarding the potential rise of resource nationalism in Kazakhstan which, in foreign investors’ view, could extend beyond the uranium sector to other mineral industries. among other measures. Resource Nationalism This context, combined with global shifts in trade and politics, has accelerated the rise of economic nation - alism across the wider economy. This trend is further reinforced by a newer generation of parliamentar - ians and government officials with strong nationalist views, advocating for tighter regulatory restrictions for both traditional and new market participants, as well as an expanded role for the state in directing eco - nomic development through state-owned enterprises (national companies) and other government-backed institutions. Conversely, another group of market-oriented policy - makers continues to oppose the growing regulatory pressure and the increasing barriers faced by new investors. Tau-Ken Samruk Driven by the strategic importance of rare earth met - als, a significant policy proposal concerning licensing access is currently under consideration. The govern - ment and Tau-Ken Samruk are seeking to reinstate Tau-Ken Samruk’s priority right for obtaining both exploration and mining licences for critical minerals. We expect this priority right to be restored in 2026. Such restoration would signify a focused effort to increase the state’s presence in the sector and secure
control over the early stages of the supply chain for materials vital to modern technology and energy tran - sition, effectively reversing previous legislative efforts aimed at liberalising subsoil access. Digitalisation in the Subsoil Use Sector Kazakhstan is experiencing accelerated digitalisation in the subsoil use sector. The e-minerals.e-qazyna.kz portal was launched to digitalise the process of issu - ing exploration licences and providing other govern - ment services related to subsoil use. Also, there is a noticeable increase in the adoption of AI in industry. According to the Ministry of Artifi - cial Intelligence and Digital Development of RoK, the Astana Hub ecosystem is seeing rapid growth of start-ups focused on geology and subsoil use. These companies are implementing digital solutions aimed at improving the efficiency, transparency and safety of production operations. Notable Kazakhstani pro - jects include Hard Code, AppStream ERP and Manul Technologies. The Ministry further reports that in 2024, a total of 6,500 government services in the field of subsoil use were provided, of which more than 5,000 (82%) were delivered electronically. National Geological Service In 2021, President Tokayev instructed the creation of the National Geological Service (NGS). The NGS aims to digitise and centralise geological data, mak - ing archived records accessible to investors. By December of 2025, 83% of archives, ranging from Soviet-era surveys to contemporary data, had been digitised, with further efforts ongoing. By 2026, NGS plans to digitise all geological data. This initiative rep - resents a commitment to utilising modern technology to unlock historical and recent geological insights, potentially driving new exploration ventures and aid - ing in resource estimation. Modernisation of exploration techniques Technological advancements are transforming Kazakhstan’s mining sector. The adoption of geospa - tial data, remote sensing technologies and AI-driven analytics has enhanced resource estimation and exploration efficiency. These tools enable operators
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