Banking as a Service (BaaS) in Kazakhstan: How the Market Works, Who Its Players Are and What the Law Allows

Banking as a Service (BaaS) is a model in which a licensed bank opens up access to its infrastructure to third-party companies via APIs: to payments, card issuance, identification and lending products. Companies embed these services into their own applications under their own brand. The partner needs no banking license, processing or compliance function: the regulatory obligations and settlements remain on the bank’s side, while the company gets ready-made financial “building blocks” for its product.

In Kazakhstan, this model has moved from slide decks into working products. Halyk Bank is developing the Halyk BaaS platform with a catalog of banking APIs, Bank CenterCredit has published its API documentation openly, ForteBank issues cards for third-party brands (Simply, “Yandex Plus Forte”), and dozens of payment organizations handle payment acceptance and payouts. In this guide we break down how BaaS works, what you can and cannot do without a license under Kazakhstan’s laws, compare providers and show real cases, from Simply to re:Kassa. The guide is part of Finteqstan’s series on the fintech market of Kazakhstan.

What BaaS is, in plain terms

Simply put, BaaS is a “bank by subscription.” The bank has a license, processing, compliance and integrations with government systems. The technology company has a product, an audience and scenarios that call for finance: payment, a card, installments, a wallet. BaaS connects the two through APIs: the bank executes the operations and answers to the regulator, while the partner manages the customer experience.

In the classic BaaS scheme there are three roles:

• The provider bank — the holder of the license and the infrastructure. Executes payments, issues cards, performs identification, bears regulatory responsibility.
• The partner (distributor) — a neobank, marketplace, retailer, telecom or MFO. Embeds financial functions into its interface and owns the relationship with the client.
• The client — uses the financial service without leaving the familiar app, and often has no idea which bank is “under the hood.”

The logic of the model is put by Radamir Nasyrov, Head of BaaS Core at Halyk Bank: “The best embedded service is invisible. The client doesn’t know that Halyk is behind the button — they simply get the service in one click. Today a partner doesn’t need its own bank; it needs a reliable bank API.”

How BaaS differs from open banking, embedded finance and white-label

These terms are often conflated, but they describe different things:

The key difference between BaaS and open banking is who opens up access, and why. Open banking in Kazakhstan remains a government initiative: an exchange of data between banks under the National Bank’s standards, with the NPC as operator and the client managing consents. BaaS, by contrast, is the commercial model of a specific bank: it decides for itself which products, on what terms and to which partners it exposes via API. Embedded finance describes the outcome the client sees, while BaaS and open banking are two ways of achieving that outcome.

Why BaaS became possible in Kazakhstan right now

Kazakhstan’s payment market has matured for the “banking as a service” model for three reasons.

The market’s digital maturity. According to the National Bank of Kazakhstan, at the end of 2025 cashless payments accounted for 98.3% by number and 87.2% by volume of retail payments; 8 out of 10 transactions go through internet and mobile banking or QR, with 1.4 times more QR payments made than card payments at POS terminals. A client accustomed to seamless payments in superapps expects the same level in any app, and this creates demand for embedded finance.

Competition among ecosystems. The Kaspi.kz model has shown how profitable the “commerce + payments + lending” combination inside a single app can be (more in Finteqstan’s study "Kazakhstan's Banking Ecosystems"). But only a handful can repeat the path of vertical integration. For other banks, opening their infrastructure to partners becomes a distribution channel beyond their own apps, while for businesses it offers a chance to get their “own Kaspi effect” without a banking license.

The regulatory turn. Since 2023 the National Bank has been steadily building a national digital financial infrastructure: interbank transfers by phone number and a unified QR (working in virtually all banks since 19 July 2026), remote biometric identification, the digital tenge, and the open banking system. The package of banking laws signed on 16 January 2026 enshrined the open banking system at the level of law for the first time: the relevant provisions were introduced into the Law “On Payments and Payment Systems.” The infrastructure barriers to embedded finance are falling every quarter.

The global context confirms the trend: Mordor Intelligence estimates that the global BaaS market will grow from $28.96 billion in 2026 to $65.78 billion by 2031 (CAGR 17.8%), while the embedded finance market, per Grand View Research’s forecast, will reach $588 billion by 2030 at an average annual growth of 32.8%.

BaaS regulation in Kazakhstan: licenses, statuses and restrictions

There is no separate “BaaS law” in Kazakhstan: the model works within the framework of general financial legislation. The key principle is this: licensable operations are always performed by the licensee (a bank or a payment organization), while a partner without a license acts as the interface, an agent or a technology contractor. Below we break down what this framework consists of.

Who regulates what

Supervision of the financial market in Kazakhstan is split between two regulators:

• The ARDFM (the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market, operating since 2020) — licenses banks and supervises banks, MFOs, insurers and securities-market participants. It is the ARDFM that issues the banking license (Art. 19 of the Law “On Banks and Banking Activities” No. 258-VIII).
• The National Bank of Kazakhstan (NBK) — regulates the payment market: maintains the registration and register of payment organizations, sets the rules for electronic money, and develops the national digital financial infrastructure (open banking, interbank mobile payments, the digital tenge) through its subsidiary, the National Payment Corporation (NPC).
• A separate circuit is the AIFC in Astana, with its own regulator, AFSA, and a legal system based on the principles of English law (more on it below).

What licenses and statuses exist

The banking license. The new Law “On Banks and Banking Activities” No. 258-VIII was signed on 16 January 2026 and has been in force since March 2026: under Art. 135 it takes effect 60 days after the first official publication, and Aequitas lawyers cite the date of 19 March 2026 (some provisions take effect through 2027). It replaced the 1995 law and introduced proportional licensing: a universal and a basic banking license. Universal banks are also allowed “Islamic windows” — that is, Islamic operations without setting up a separate Islamic bank, subject to organizational separation and separate accounting. The minimum own capital is 20 billion tenge for a universal license and 10 billion for a basic one, and 4 billion for the housing construction savings bank (the ARDFM resolution on prudential standards, 2026). The basic license is designed as an easier entry for new players: it allows a limited list of operations. The first universal license under the new law was obtained by Freedom Bank (7 July 2026); a year earlier the MFO KMF converted into KMF Bank.

The payment organization (PO). Regulated by the Law “On Payments and Payment Systems” of 26.07.2016 No. 11-VI. This is not a license but a registration with the National Bank (Art. 16): an LLP submits a package of documents, including internal AML/CFT control rules, and enters the NBK’s public register; the review period is 15 business days. The minimum charter capital is 150 million tenge for one type of service plus 50 million for each additional one (Resolution of the NBK Board No. 129). Of the nine types of payment services listed in Art. 12 of the law, four are available to payment organizations (subparagraphs 3, 7, 8, 9 of paragraph 1): accepting cash for payments without opening an account, distributing electronic money and cards, processing payments in electronic money, and processing payments initiated by the client in electronic form. At the end of 2025, the NBK register lists 135 payment organizations; their turnover grew from 1.5 trillion tenge in 2018 to around 10 trillion in 2025.

Electronic money. In Kazakhstan, only the National Bank, banks and Kazpost are entitled to issue e-money (Art. 42 of Law No. 11-VI). A company with payment-organization status may be an operator of an electronic-money system under a contract with the issuer, or a distribution agent; wallet services use this arrangement.

What’s next: “first-category payment organizations.” In the summer of 2026, parliament approved a package of amendments “on improving and digitalizing the financial market,” creating a new class of players: first-category payment organizations with a National Bank license. They are to be allowed to open current accounts for legal entities, issue electronic money and connect directly to the NBK’s payment systems; deposits and lending will remain prohibited. According to media reports, the law was signed in the summer of 2026; the exact details and the dates on which the provisions take effect should be verified as of the publication date. For the market, this is a step toward an analog of European EMI licenses: some BaaS scenarios will become available without a partner bank.

What you can do without a license — and what you can’t

The practical question for any BaaS product: where is the line drawn. From Law No. 11-VI and banking legislation, it comes out as follows.

Allowed without a license or registration:

• embedding a partner bank’s financial services via API: the licensable operation is performed by the bank, and the client contract is concluded with the bank (the BaaS model proper);
• acting as a payment agent or subagent of a bank or a payment organization under an agency contract (Art. 13–14 of Law No. 11-VI), with disclosure of the fee and joint liability of the service provider;
• providing technical support for payment services: processing, gateways and IT contracting for a bank or a PO are explicitly excluded from the concept of a payment service (Art. 12, paragraph 2);
• issuing closed-loop instruments: gift cards and points accepted only by the issuer itself are not considered a payment service (Art. 12, paragraph 2).

Not allowed without the corresponding license or registration:

• opening and maintaining clients’ bank accounts, taking deposits, lending: these are banking operations requiring an ARDFM license;
• issuing payment cards in your own name: card issuance is reserved for banks, and partner cards are legally issued by the bank (subparagraph 6 of paragraph 1 of Art. 12 of Law No. 11-VI is unavailable to payment organizations);
• issuing electronic money (only the NBK, banks, Kazpost);
• providing payment services under subparagraphs 3, 7–9 without PO registration with the National Bank; it is even prohibited to call oneself a “payment organization” without registration (Art. 15).

There are no special provisions on BaaS and embedded finance in Kazakhstan law; general institutions apply: agency arrangements, outsourcing, the exceptions of Art. 12. That is why the allocation of responsibility between the bank and the partner is determined by contract, and the quality of that contract is among the project’s main risks.

Open banking: the plan and the reality

The National Bank published the Concept for the Development of Open API and Open Banking for 2023–2025 in February 2023. From 1 November 2023, a pilot ran with five banks (Bank RBK, Altyn Bank, Home Credit Bank, Bank CenterCredit, Otbasy Bank) on exchanging account data with the client’s consent. The NPC was appointed operator of the system: the rules, a model contract and technical specifications have been published, APIs for account, balance and transaction data are available, and for 2026 APIs of open data on banks’ products, ATMs and branches are planned. Legal codification has also taken place: the accompanying Law No. 259-VIII of 16 January 2026 introduced the concept of an “open banking system” and a chapter on the national digital financial infrastructure — of which this system is named a component — into the Law “On Payments and Payment Systems.”

From here the questions begin. The Concept allotted a deadline of the end of 2025 for all the initiatives. The calendar has run out, yet mandatory deadlines for banks to connect never appeared (as of August 2026 they are not in open sources); the pilot ran on a focus group of a hundred clients and got no high-profile continuation. There are grounds to doubt that the voluntary stage will grow into a working system at all: for large banks that have spent years building closed ecosystems, sharing client data with competitors is not advantageous, and without the largest participants open banking does not reach critical mass. This is an editorial assessment, but there is indirect confirmation for it: results appear quickly where the National Bank does not wait for volunteers but builds the infrastructure itself.

A recent example is exactly this kind: the Interbank Mobile Payments System (IMPS). Since 19 July 2026, transfers by phone number and payment via a unified QR have been available to clients of virtually all banks; the P2P transfer limit is 1 million tenge per transaction. This matters for BaaS scenarios: the unified QR and phone transfers become the “default” infrastructure on top of which partners build customer journeys.

Sandboxes and the AIFC: where to test the model

• The National Bank’s sandbox (the “special regulatory regime,” Resolution No. 178 of 11.11.2019) is open to banks, payment organizations and other residents; since July 2025 it has run a separate track for digital assets: tenge stablecoins, asset tokenization, crypto exchanges (22 projects as of early 2026).
• The ARDFM’s special regulatory regime — a similar instrument for activities licensed by the ARDFM.
• AFSA’s FinTech Lab (AIFC) — the sandbox of the AIFC jurisdiction: testing with real clients while gradually meeting the full requirements; at the end of 2025 it held 24 companies.

The AIFC is a separate regulatory circuit for fintech. Since October 2025 the Providing Money Services framework has applied there, covering currency exchange, maintaining payment accounts, acquiring, payment initiation and account-data services; by early 2026, 10 money-services providers had been authorized. An important limitation: AIFC participants provide financial services to residents in tenge only through accounts at Kazakhstan’s second-tier banks, and AIFC banks cannot hold clients’ tenge accounts. That is why, for mass retail products in tenge, the AIFC circuit is usually combined with a partner bank “on the ground.”

KYC and remote identification

Remote onboarding in Kazakhstan relies on government infrastructure: the Identification Data Exchange Centre (IDEC), whose operator is the NPC. Banks, payment and microfinance organizations, AIFC participants and participants in the open banking ecosystem connect to the IDEC. Since April 2026, when opening an account remotely, banks are required to perform biometric authentication of the client through the IDEC (the ARDFM’s Biometric Authentication Rules of 3 April 2026), and since 12 July 2026 the joint rules of the ARDFM and the NBK on the National Biometric Authentication System have been in force. The scale of the infrastructure is telling: over 2025, more than 50 million requests passed through the NBK’s biometric services. For BaaS partners this means that “passport-grade” KYC can be assembled from ready-made blocks: government infrastructure, a provider bank’s services such as Halyk ID, or commercial vendors (Verigram, Biometric.Vision).

Who provides BaaS in Kazakhstan: a map of the players

In Kazakhstan, full-fledged BaaS with card issuance, onboarding and lending products under the partner’s brand is publicly offered by only one bank so far: Halyk. Around it operate several banks with open APIs of varying depth, white-label partnerships under individual contracts, and a layer of non-bank payment infrastructure. The reverse is also important: the country’s largest fintech ecosystem, Kaspi.kz, does not provide classic BaaS — it is a closed, vertically integrated model.

A comparison table of providers

A few clarifications on the table. The first concerns the term “developer portal” in the BCC row. This is an open section of the bank’s website with technical API documentation, where any company can — without negotiations or an NDA — study which services the bank exposes to partners and how the integration is structured. Developers use the portal, but it is addressed first and foremost to the business choosing a provider: open documentation saves weeks of correspondence and lets you assess a project’s feasibility before signing papers. Second: open APIs for a bank’s own corporate clients (host-to-host for 1C and ERP systems) exist at other banks too, for example at Alatau City Bank (ex-Jusan) and Bereke Bank. This is a useful integration, but not BaaS: the bank serves its own client rather than exposing products under a third-party brand. Third: Freedom Bank has no public BaaS offering; the group is developing embedded finance inside its own ecosystem (Aviata, Freedom Travel) and offers external companies the Freedom Pay payment service. And fourth: the market is complemented by KYC vendors (Verigram, Biometric.Vision, Aitu Passport) and the government identification infrastructure IDEC; both banks and payment organizations connect to them.

Halyk BaaS: how the largest bank’s platform works

Halyk Bank (group assets of 20.9 trillion tenge at the end of 2025, 11.5 million active retail and more than 500,000 business clients) has approached BaaS systematically: not separate integrations on request, but a platform with an API catalog, package tariffs and a dedicated team (the platform’s card is in our catalog: Halyk BaaS). The strategy was articulated in 2024 by Andrey Zavarzin, deputy chairman of the board for IT and innovation: “We are wrapping all our current services in APIs and rolling them out as BaaS — or rather, even EaaS, Ecosystem as a Service.” The platform was publicly presented in November 2024 at the Rocket Conf conference (the SDK solution’s original name was NeoTab), although as a layer of the IT architecture BaaS had appeared in the bank’s investor materials as early as late 2023.

The service catalog

On the official landing page baas.halykbank.kz, the bank positions the platform as “banking and non-banking services for your products”: “connect payments, KYC, card issuance and other services from Halyk Bank into your product in days, not months.” The API catalog includes:

• Halyk ID / Business ID — authorization of individuals and businesses through the Halyk ecosystem, without passwords or manual data entry (technologically, this is OAuth 2.0);
• client registration and authorization — onboarding “without forms, passwords or SMS”: the data is pulled from the Halyk profile;
• card issuance — physical and virtual Halyk cards under the partner’s brand, including co-brand, with instant activation;
• card management — blocking, limits, PIN, statements, card details via API;
• QR payments — payment via QR on Halyk’s POS infrastructure;
• transfer operations — transfers by card and phone number, P2P, mass payouts;
• disbursement and repayment of microloan funds — the cycle of issuing and repaying a loan within the partner’s interface (for MFOs there is a separate Halyk Widget SDK);
• government services — identity verification and data from government databases (PSC, eGov).

The services are bundled into three packages: “Basic” (authorization + QR payment), “MFO” (cards + loan disbursement and repayment) and “NeoBank,” the maximum configuration with co-brand card issuance, card details, statements, limits and transfers. According to the company, the platform brings together 8+ services, 50+ partners and 5 million active users with an SLA of 99.9% and API latency under 50 ms; integration takes “from 14 days.” There is no independent verification of these figures: Halyk does not disclose separate reporting for BaaS.

How to connect and what’s under the hood

Connection happens in three steps: an application and signing an NDA, then access to the technical documentation in GitLab, then integration with support from the BaaS team. Unlike BCC, the platform has no public documentation: it opens up after an NDA. The technology stack, which the bank’s engineers disclosed at the Halyk Tech Sprints meetups: authorization on OAuth 2.0, exchange with partners via RSA keys, a mobile SDK (integrated through Swift Package Manager), some screens on WebView so that the bank can update the flows without releases on the partner’s side, and its own design system for quickly adapting interfaces.

Public case studies

• Vlife (a loyalty superapp with a network of gas-station partners) — the platform’s first major partner in 2025: onboarding, Halyk ID, payment for services and card issuance.
• TAS Group (lending secured by cars) — the integration was announced in September 2025: authorization via Halyk ID, instant crediting of microloans to cards, issuance of a digital card to clients without a Halyk card.
• re:Kassa (online cash registers for SMBs) — according to the company’s CPO, Pavel Flerov, integrating the cash register into the bank’s infrastructure took two months and “brings thousands of connections and billions in turnover” (per the company). A telling sequel: in June 2026 Halyk closed a deal to buy 100% of re:Kassa (ARDFM permit No. 60 of 09.04.2026), and the BaaS partner became part of the group.

The “Our partners” block on the landing page itself shows a broader circle: TasCredit, the Onay transport card, Birinshi Lombard, Findom.kz, the Gold Apple (Zolotoye Yabloko) chain, as well as Halyk group services (Halyk Life, Halyk Finance, Halyk Market, Kino.kz).

The bank frames its positioning directly: “We do not compete with fintech companies and microfinance organizations. Instead, we are their technology partner, sharing in the growth and expanding our own presence in the market,” says Sultan Isaev, director of the digital-channel sales development department at Halyk Bank.

Use cases: who needs BaaS and why

Telecom: Simply on ForteBank’s infrastructure

The most mature Kazakh case of embedded finance is Simply, a fintech service of Beeline Kazakhstan launched in June 2021. Its legal structure is telling: the operator of the wallet and the app is a subsidiary payment organization, the LLP KazEuroMobile (in the NBK register since 2018), while the issuer of the payment cards, since November 2024, is ForteBank. The scheme is still in effect: on Simply’s terms page, the payment-card issuance agreement leads to Forte’s tariffs (verified in August 2026). At the end of 2024, Simply had 3.2 million monthly active users: the telecom monetizes its subscriber base with financial products without holding a banking license. The trend continues in Kyrgyzstan, where a group linked to the operator “O!” bought Halyk’s local subsidiary in 2024 and is building O!Bank on its basis.

Neobanks and fintech startups

For a startup, the choice is between its own license and the partner model. Your own license has become more accessible: a basic banking license requires from 10 billion tenge of capital, and the conversion of an MFO into a bank has been tested by KMF. But this path remains expensive and long, and the ARDFM does not approve everyone: in 2024, Solva was refused a conversion into a bank. BaaS shortens time to market: according to Halyk representatives at the platform’s presentation, an integration that used to take around half a year now fits into a few weeks. Halyk BaaS’s “NeoBank” package includes onboarding, co-brand cards, statements and transfers — effectively a construction kit for a retail financial app. What costs what in both scenarios, we calculated in detail in the guide "How Much It Costs to Launch a Neobank in 2026".

MFOs: the lending cycle inside the app

The clearest demand for BaaS in Kazakhstan comes from the microfinance segment: MFOs need loan crediting to a card, repayment and identification, but building card infrastructure themselves makes no economic sense. For this, Halyk built a separate SDK (Halyk Widget), and the TAS Group case shows the mechanics: the client authorizes via Halyk ID, instantly receives the loan on a card, and, if they have no card, is immediately issued a digital one produced in the same flow. How the lending process is structured end to end, from application to disbursement, we break down in the guide "Loan Origination in Central Asia".

Marketplaces and e-commerce: installments as infrastructure

The Kaspi model, where installments live inside its own bank (around 40% of the ecosystem’s financial-product volume in the first half of 2025), competitors reproduce through partnerships. Since 2023, Ozon in Kazakhstan has shown offers from four lenders at once at checkout (Halyk Bank, Home Credit Bank, Eurasian Bank, the MFO “Freedom Finance Credit”); Wildberries launched installments in February 2026 (the partner banks are not publicly named). A separate “installments as a service” niche has also emerged: Kazakhstan’s Airba Pay combines online acquiring and partner banks’ credit offers into a single API for retailers (Intertop, Tele2, iSpace, etc.). Context on the installments market is gathered in the BNPL in Central Asia hub.

Retail and offline services

Classic POS lending in retail chains (Technodom, Sulpak) has long operated through partner banks: Halyk, ForteBank, Home Credit. BaaS moves this mechanic from the “credit expert in the store” into an API: QR payment with bonuses in a single scan, embedded installments at the checkout, loyalty programs with a partner’s card (the Vlife case). For service platforms, payment acceptance and mass payouts to contractors are added; this part is covered both by banking APIs and by payment organizations: OneVision, Freedom Pay and Kassa24 offer payouts to cards via API.

How to choose a BaaS provider: a checklist

Seven questions worth asking before signing a contract:

1. Product perimeter. Is everything your scenario needs available: onboarding/KYC, cards (virtual? physical? co-brand?), transfers, payouts, lending products, QR?
2. Legal structure. Who concludes the contract with the end client, how is responsibility allocated, what happens to the clients if the partnership is terminated?
3. API depth and documentation. Is the developer portal public (as at BCC), or is the documentation provided after an NDA (as at Halyk BaaS)? Is there a sandbox?
4. Timeline and integration model. An SDK or a pure REST API, how long the pilot takes (the timelines stated on the market: from 14 days to 12 weeks), who does the integration.
5. SLA and reliability. Availability guarantees, API latency, 24/7 support, the incident procedure.
6. Economics. Package tariffs, transaction fees, minimum volumes, the cost of issuing and servicing cards.
7. Strategic risks. Whether the provider competes with your product in your own niche, and whether, conversely, it is willing to invest in a partner (Halyk’s purchase of re:Kassa shows both sides of this coin).

Trends: where BaaS is heading in Kazakhstan and Central Asia

The regulatory vector is widening the circle of players. “First-category payment organizations” with an NBK license (legal-entity accounts, e-money issuance, direct access to payment systems) will create an intermediate class between POs and banks, a Kazakh analog of European EMIs. In parallel, Law No. 258-VIII lowered the barrier to entry into banking with the basic license. Competition for distributor partners will intensify.

Open banking: a fork in the road. The legal framework and the operator are in place, but the voluntary stage is stalling: the Concept’s deadlines have passed, there is no mandatory connection, and for banks with strong ecosystems data sharing is disadvantageous. Either the National Bank will repeat the IMPS scenario and make connection mandatory, or open banking will remain niche and the market will keep growing through bilateral BaaS partnerships. For now, in our view, the second option is more likely.

Infrastructure is becoming commoditized. The unified QR and transfers by phone number (IMPS, in virtually all banks since July 2026), mandatory biometrics through the IDEC, and the digital tenge — which became legal tender on 18 July 2026 (issuance exceeded 330 billion tenge at the end of 2025, and since August 2026 it is mandatory for part of public procurement) — make basic payment functions available to everyone. They cease to be a competitive advantage; value shifts toward product scenarios and data.

Ecosystems versus “invisible banks.” Kaspi has proven the strength of the closed model; Halyk’s bet is the opposite: to become the infrastructure for other companies’ products. Between these poles the other banks will choose: BCC already has open APIs, Forte has white-label issuance, and Freedom has a universal license and an appetite for an ecosystem.

Central Asia as the next market. Kazakhstan’s payment companies are already expanding to neighbors: OneVision operates in Uzbekistan, Azerbaijan, Kyrgyzstan and Tajikistan, and Airba Pay and Freedom Pay in Uzbekistan. Regional cases confirm the demand for embedded finance: Uzbekistan’s Uzum raised more than $130 million in March 2026 at a valuation of $2.3 billion, while TBC Bank Uzbekistan grew its ecosystem to 23 million users. The experience honed on Kazakhstan’s BaaS scales to a region with a population of more than 80 million people.

Launching a financial product? Halyk BaaS, the platform of Kazakhstan’s largest bank, gives you onboarding and Halyk ID, card issuance under your brand, QR payments, transfers and microloan services via API. Submit a request at baas.halykbank.kz: the platform team gets in touch within 1–2 business days.

Sources

Key primary sources worth checking directly.

Halyk BaaS:

• Halyk BaaS landing page — baas.halykbank.kz
• "Under the hood of Halyk BaaS" — Digital Business KZ
• Halyk expands its BaaS infrastructure (the TAS Group case) — Kapital.kz

Regulation:

• Law of the Republic of Kazakhstan "On Banks and Banking Activities" No. 258-VIII of 16.01.2026 — adilet.zan.kz
• Law of the Republic of Kazakhstan "On Payments and Payment Systems" No. 11-VI — adilet.zan.kz
• The NBK — digital financial infrastructure and open banking
• The NPC — the open banking system
• AFSA (AIFC) — the Providing Money Services framework
• Aequitas — an overview of Kazakhstan's fintech regulation (Chambers)

Market players:

• Bank CenterCredit — Open API (developer.bcc.kz)
• ForteBank — acquiring documentation
• Kaspi.kz — partner guide

Market and trends:

• Mordor Intelligence — the global BaaS market
• Grand View Research — embedded finance

Check current requirements and figures with the regulators — the ARDFM and the National Bank of Kazakhstan: some of the regulatory dates and standards, as of the publication date, are based on business media and legal reviews and are being verified as official acts are issued.