How a Bank Can Launch Halal Products in Central Asia

Demand for Islamic finance in Central Asia is growing faster than the banking sector itself, and the regulatory doors that had been closed for years finally opened in 2026: in Kazakhstan the new banking law has been in force since 19 March, and in Uzbekistan the law on Islamic banking since 29 June. Yet there is no coherent picture of “how a bank actually launches this” grounded in the region’s facts: AI assistants and price articles answer in general terms about the ban on interest rather than what specifically is required of a bank in Kazakhstan and Uzbekistan.

Even more important is what has not yet happened. As of mid-August 2026, not a single bank in either of the two countries has publicly obtained a license or permit for an Islamic window. The laws exist, secondary legislation is coming out, regulators name timelines — yet the field is still empty. This is precisely the window of opportunity worth thinking about in terms of quarters, not years.

This breakdown is a practical route for a bank or an MFO that wants to launch a halal line of business: which path to choose (a window, conversion or a separate bank), what the regulators and the Shari’ah board require, how the tax regime works, which products work in the region and how to assemble all of it technologically. We cite regulatory details with a source and a date; where the rules are new and secondary legislation is still in development, we say so honestly — always verify the current version with the regulator.

Affiliation disclaimer. Finteqstan is a media outlet of the Rocket Firm ecosystem. The ecosystem company Ready Bank is mentioned in this breakdown as an example of an off-the-shelf solution, flagged “(affiliated with the publisher)”. This is not a rating or an ad: a brand here illustrates a step, not a conclusion “buy from them.” The regulatory requirements and the launch logic are the same for any vendor and bank.

Why now

The topic has moved off dead center at the level of the law — and that is the main thing that has changed:

• Kazakhstan. The Law “On Banks and Banking Activity in the Republic of Kazakhstan” No. 258-VIII was signed on 16 January 2026 and came into force on 19 March 2026; it replaced the base law of 1995, which had been amended more than 140 times. A bank with a universal license may now conduct Islamic banking operations without creating a separate legal entity — but on the basis of a separate license to conduct Islamic banking and other operations, with dedicated assets, separate accounting and a Council for the Principles of Islamic Finance (Article 36). Analysts name Islamic windows specifically as the main driver of future growth in retail and SME.
• Uzbekistan. Law No. ZRU-1126 (Uzbek: OʻRQ-1126) — a package of amendments aimed at introducing Islamic banking — was signed on 27 March 2026 and came into force on 29 June 2026. The amendments were made to the Civil and Tax Codes, the laws on the Central Bank and on banks, and to the legislation on microfinance organizations and on deposit guarantees. Before that, Islamic products in the country went around the system — through partnerships with ICD (the Islamic Development Bank group) and through MFOs, which were allowed Islamic products back in 2024.

The scale of demand has also ceased to be a hypothesis, although the figures call for care.

According to the joint report by the EDB, the Islamic Development Bank Institute (IsDBI) and LSEG, “The Future of Islamic Finance in Central Asia” (May 2025), the region’s aggregate Islamic finance assets stood at $699M at the end of 2023 — this is all Islamic finance, not just banking: 18 Islamic banks and 14 non-bank Islamic financial organizations, about 0.01% of the global market. The forecast in the same report: Islamic banking assets of $2.54 billion by 2028 and $6.3 billion by 2033, and separately a sukuk market of $2.05 billion and $5.6 billion respectively.

For a sanity check on scale: Fitch Ratings in May 2026 estimated the aggregate Islamic finance market of Central Asia at more than $600M at the end of 2025 and forecast that the share of Islamic banks in Kyrgyzstan, Kazakhstan and Tajikistan would remain below 1.5% of banking sector assets by the end of 2026. Fitch and the EDB use different methodologies, so you cannot build a trend out of these two figures — but both show one thing: the market is still measured in hundreds of millions, not billions.

The share of the Muslim population in the region averages about 85% (per the same EDB report), but the spread across countries is wide: Kazakhstan — 69.3% per the 2021 census, Uzbekistan — 88–97% by various estimates, as no official statistics on religious affiliation are kept there. This is not a niche story, but neither is it “85% of ready customers.”

Where the market actually stands: status as of August 2026

Kazakhstan

• 19 March 2026 — Law No. 258-VIII came into force. Some provisions are deferred: from 1 July 2026 — the regulation of insolvency and compulsory liquidation, from 1 January 2027 — the financial ombudsman and the “Data Showcase,” from 1 May 2027 — the assignment of claims under consumer loans.
• 24 June 2026 — the ARDFM announced that it would reissue the licenses of all banks under the new regime and adopt 82 secondary regulations in three stages (68 already adopted). At the same time a threshold was named: the minimum volume of assets allocated to Islamic operations is no less than 1 billion ₸.
• 27 July 2026 — Otbasy Bank disclosed a two-stage scheme for Islamic mortgages: first current and savings accounts under Shari’ah, then housing financing — after changes to the law on housing construction savings and an expansion of the license. The target launch is October 2026, with products under AAOIFI standards.
• As of 13 August 2026 — there are no public reports of issued licenses for Islamic operations. Banks’ positions (February 2026): Otbasy is the most advanced, BCC is studying it, Halyk is studying it cautiously and awaiting the regulator’s clarifications, and Freedom Bank, Altyn Bank and Eurasian Bank do not consider the area a priority.

Uzbekistan

• 29 June 2026 — Law No. ZRU-1126 came into force.
• July 2026 — the CBU registered changes to eight regulatory documents (liquidity, corporate governance, internal audit, capital adequacy, risk limits, contributions to the Deposit Guarantee Fund).
• 15–16 July 2026 — the Islamic Finance Council under the CBU was established: five members, four specialists in Islamic law from the Fatwa Center of the Muslim Board of Uzbekistan and one technical expert.
• 21 July 2026 — the licensing rules and requirements for members of Shari’ah boards were published; in early August they were registered by the Ministry of Justice. Banks and MFOs can either convert to fully Islamic or open an Islamic window.
• 22 June 2026 — a new version of the law “On the Capital Market” was presented to the President, regulating sukuk for the first time. As of 13 August 2026 — a draft bill, not yet adopted.
• The CBU’s goal is at least one Islamic window in a commercial bank by the end of 2026. No applications or issued licenses have been publicly confirmed.

The AIFC

• 8 April 2026 — the AIFC International Advisory Board on Islamic Finance (IFAB) approved the Shari’ah Governance Rules document. It will come into force only after AFSA’s approval.
• 15 July 2026 — AFSA launched public consultations on the new AIFC Shari’ah Governance Rules and related amendments to the General Rules, Glossary and Islamic Finance Rules. Comments are accepted until 15 September 2026.
• Until the new rules take effect, Chapter 5 of the current Islamic Finance Rules applies.

Fork 1: a window, conversion or a separate bank

The first decision determines both the cost and the timeline of entry. There are not two paths but three — and all three are permitted in both countries.

The key point: windows were legalized only very recently — in Kazakhstan by the law in force since March 2026, in Uzbekistan since June 2026. This is the fastest entry path but also the least battle-tested: the secondary requirements are still forming in places, and there is no application practice at all. The conversion path has already been walked in the region: Zaman Bank in Kazakhstan obtained an Islamic bank license on 17 August 2017 and became the country’s first bank converted from a conventional one; Tavhidbank appeared the same way in Tajikistan.

Regulatory requirements by country

The amounts and rules are as of August 2026; under the new laws the detailed prudential requirements are issued through secondary regulations and must be verified with the regulator.

Two points that are often missed:

• Kazakhstan is two different jurisdictions. The national regime (the ARDFM) and the AIFC perimeter (AFSA) are different sets of requirements, capital and Shari’ah governance rules. The AIFC, moreover, does not operate “under English law,” as is often written, but under its own acts, which may be built on the principles, legislation and precedents of the law of England and Wales; Kazakhstan’s criminal and tax law continues to apply within the AIFC. The Centre has its own court, separate from and independent of Kazakhstan’s judicial system. The choice of regime is a strategic decision, and the market calls the coexistence of two regimes in one market regulatory arbitrage.
• Deposit insurance. Under Kazakhstan’s national regime, Islamic banks do not participate in the deposit guarantee system — and the new law did not change this, although it did in fact extend guarantees to banks with a basic license. In Uzbekistan, mudarabah investment deposits are likewise excluded from state guarantees. This must be built into product communication with the client from day one.

Taxes: where it is settled and where it is not

Murabaha is structured as a sale and purchase: the bank buys an asset and resells it to the client. From the standpoint of the tax code these are two transactions instead of one — and if the legislator did not account for this, the tax can arise twice. The tax regime for such operations in Kazakhstan and Uzbekistan for 2026 is arranged differently, and this directly affects which product to launch first.

Uzbekistan: the tax regime is tuned for Islamic operations. Law No. ZRU-1126 introduced into the Tax Code a special regime for the Islamic financial operations of banks and MFOs, in force since 29 June 2026:

• VAT — the positive difference between the sum of payments and the redemption price under Islamic leasing (ijara) is exempt; the markup under murabaha is exempt from VAT; operations with Islamic securities are equated to operations with conventional securities and exempt; trust management services are exempt.
• Profit tax — remuneration under Islamic operations is recognized as income; fines and penalties collected within Islamic operations and directed to charity are recognized as a deductible expense (a rule that does not exist for conventional lending).
• Personal income tax — individuals’ income under Islamic financing contracts with banks and MFOs is exempt; income from sukuk is equated to dividends.
• Property tax and land tax under ijara are paid by the bank or MFO as the lessor — unlike in conventional leasing.
• Intermediate transfers of ownership are exempt from state duty and notary fees.
• The condition for applying the benefits is separate accounting of income from Islamic operations, fixed in the accounting policy. That is, the tax benefit is technically tied to the same ring-fencing that the regulator requires.

Kazakhstan: there are still no special provisions for Islamic operations. The mechanics: the bank buys an apartment and pays VAT, and when ownership is re-registered to the client the VAT arises again, since the buyer is not a VAT payer. No special provisions on murabaha and ijara appeared in the new Tax Code (No. 214-VIII of 18.07.2025, in force since 1 January 2026), while the VAT rate was raised from 12% to 16%, and the developers’ VAT benefit on the sale of apartments was abolished. As of August 2026, double VAT is named the main constraining factor for Islamic mortgages in Kazakhstan — both Zaman Bank and market participants say so publicly.

What this means in practice. Until the tax question on mortgages is settled, there is less friction at launch for products where double VAT does not arise or is immaterial in amount — commodity and trade finance for SMEs, auto finance, ijara with a correct structure; the flagship Islamic mortgage is logically planned as a second step. This applies to the Kazakh tax perimeter; in Uzbekistan the special regime removes these costs.

What Shari’ah compliance requires

Regardless of the path, a bank will have to build a perimeter that does not exist in conventional banking:

• The Shari’ah board. Mandatory in all three regimes, but named and structured differently:
  • Kazakhstan, national regime — the “Council for the Principles of Islamic Finance” (Article 36 of Law No. 258-VIII). In legal texts and in correspondence with the ARDFM, use precisely this name rather than the calque “Shari’ah board.” The requirements for council members are set by a separate ARDFM act — the draft underwent public discussion until 11 February 2026 and calls for confirmed knowledge of Islamic law and finance, a ban on personal benefit in approved transactions, and requirements for experience and residency.
  • The AIFC — a Shari’ah Supervisory Board, at least 3 members (IFR 5.1(2)(a)); members must be competent given their qualifications and experience; appointments and dismissals are approved by the governing body; an SSB member cannot be a director or controller of the same institution. Separately required are an appointment and fitness assessment policy, conflict-of-interest management and record-keeping of qualifications.
  • Uzbekistan — an Islamic finance council in every institution: at least 3 members; the chair and deputy hold an academic degree in Islamic sciences, 5+ years of experience in Shari’ah law and command of Arabic at the level of working with primary sources; technical members hold relevant higher education and 7+ years of experience; at least one member with a valid AAOIFI certificate, and from 1 July 2027 certification is mandatory for all members; at least two thirds of the Shari’ah specialists are citizens of Uzbekistan; a mandatory interview at the Central Bank; council members bear responsibility alongside the management board and the supervisory board. The head of an Islamic window in a conventional bank must have 7+ years of banking experience and a mandatory AAOIFI certificate.
• Standards. Two organizations that are constantly confused:
  • AAOIFI (Bahrain, 1991) — a non-profit organization that develops standards for Islamic financial institutions themselves across five areas: Shari’ah, accounting (FAS), auditing, governance (GSIFI) and ethics. Despite the name, its Shari’ah standards are the most influential. It runs professional qualifications (CSAA, CIPA and others) — the very certificates that Uzbekistan requires of council members.
  • IFSB (Kuala Lumpur, 2002–2003) — an international standards body whose members are regulators and central banks. It issues prudential and supervisory standards — capital adequacy, risk management, corporate governance, disclosure — for banking, capital markets and takaful. The Central Bank of Uzbekistan has been an IFSB member since December 2024.
• Separate accounting (ring-fencing in industry terminology). Islamic funds cannot be mixed with interest-bearing ones: segregated accounts and funding, a separate asset pool, separate reporting, separate Shari’ah control. For a window this requirement is a hard condition of the license in both countries, and in Uzbekistan also a condition for the tax benefits.
• Income purification. Income earned in a way that is incorrect from a Shari’ah standpoint does not stay in the bank’s profit — it is directed to charity. In Uzbekistan this is expressly fixed: the institution must have such a policy, and the corresponding fines and penalties are recognized as a deductible expense. For IT this is a separate process: identification, segregation, reporting.

The practical takeaway: a halal line of business is not “renaming a loan” but a separate operational, accounting and staffing perimeter on top of the bank. That is precisely why technology here matters no less than the legal documents.

The menu of halal products

What actually works in the region and what the new laws recognize:

• Murabaha — a sale with a markup: the bank buys an asset and resells it to the client in installments at a fixed price, without interest. The most widely used product in the region: it accounts for about 63% of the portfolio of Uzbekistan’s Islamic MFOs, and 69% in Q1 2026. Recognized by Uzbek law.
• Ijara — Islamic leasing with subsequent buyout. Widely used in Kazakhstan, recognized by Uzbek law.
• Diminishing musharakah — the base structure for housing finance: the bank and the client own the home jointly, and the client’s share is gradually bought out.
• Musharakah — a partnership with profit and loss sharing by stake. Recognized by Uzbek law (about 14% of the Islamic MFO portfolio).
• Mudarabah — a trust partnership (capital from one party, management from another); the basis for Islamic deposits. Recognized by Uzbek law (about 17% of the MFO portfolio).
• Wakalah — an agency contract: managing funds for a fee. Recognized by Uzbek law.
• Salam — prepayment for a future delivery (agricultural and trade finance). Recognized by Uzbek law.
• Istisna — financing the manufacture or construction of an asset. It is not on the list of operations in the Uzbek law, but it was precisely through istisna that the Islamic Development Bank financed infrastructure projects in the region for decades — a workable structure for project finance.
• Sukuk — Islamic securities (shares in assets instead of interest). In Kazakhstan, issues take place on the AIFC exchange (AIX): the first Kazakh corporate sukuk was Gamma-T SPC, an ijara sukuk, December 2024; the first retail sukuk was Asia Mineral Resource SPC, $10M, a minimum denomination of $10, 2025; the Tayyab Finance Sukuk program for 20 billion ₸ is registered there as well. In Uzbekistan, sukuk is regulated not by the law on Islamic banking but by the new version of the law “On the Capital Market” — it was presented in June 2026 and, as of August 2026, has not been adopted, although the tax benefits for sukuk have already been added to the Tax Code.
• Takaful — Islamic mutual insurance. Within the AIFC perimeter it is a separate licensed activity (Takaful Business); retakaful does not require a separate license and is regulated by the same rules. Takaful is not regulated by Uzbek law.

For launch, banks usually take murabaha and ijara — they cover the bulk of retail and SME demand and map most easily onto the existing lending perimeter. In the housing segment the base structure is considered to be diminishing musharakah, and in the corporate segment, trade finance.

The deposit side: what a conventional bank does not have

An Islamic bank does not pay interest on a deposit — it shares profit. In practice this means two things.

First: the deposit becomes an investment product. The classic structure is mudarabah: the client provides capital, the bank manages it, profit is shared in a pre-agreed proportion, and a loss, absent fault of the bank, falls on the client. The second structure is wakalah: the bank manages the funds as an agent for a fixed fee. Current accounts are usually built on qard (an interest-free loan) — no income accrues on them at all.

Second: the state guarantee does not extend to such deposits. In Kazakhstan, deposits of Islamic banks are not part of the KDIF guarantee system — and the new law did not change this. In Uzbekistan, mudarabah investment deposits were excluded from state guarantees by the amendments of Law No. ZRU-1126. For a bank this means that communication with the client must be set up before launch, not after the first support inquiry: a client used to an insured deposit will perceive this as a downgrade unless the logic is explained.

A separate practical point: Otbasy Bank in Kazakhstan is taking precisely this path — in the first stage it launches current and savings accounts under Shari’ah and only in the second moves to financing. For a bank with a large liability base this is a sensible sequence: liabilities are simpler, cheaper and do not run into the tax question.

How it is implemented technologically

The legal framework is half the job. The other half is assembling the product in IT so that it is Shari’ah-compliant and passes audit:

• Product logic without interest. Murabaha and ijara are calculated not as an interest schedule but as a sale and purchase or a lease with a markup — this is a separate product configuration in the lending pipeline and digital banking. Separately, support is needed for the bank’s ownership of the asset in the interval between purchase and transfer to the client: in murabaha the bank actually becomes the owner, and this must be reflected in the accounting.
• A separate ledger and accounting. That same separate accounting from the regulator’s requirements must be implemented in the system: segregated accounts, a separate pool of assets and funding, separate reporting, tagging of Islamic operations. In Uzbekistan the right to tax benefits depends on this as well.
• Profit distribution across liabilities. Mudarabah deposits need a mechanism for calculating and distributing profit across the pool — this is not “accruing interest with a different formula” but a separate subsystem with its own reporting to the client.
• Income purification. Identifying improperly earned income, segregating it and directing it to charity — a process that must be in the system, not in an accountant’s Excel.
• Reporting and Shari’ah audit. The annual report of the Shari’ah board, internal Shari’ah audit, Shari’ah reviews — within the AIFC perimeter these are directly tied to AAOIFI standards (GSIFI No. 1, 2 and 3). The system must deliver data in the breakdowns that these reviews require.
• Integration into channels. Halal products must live in the same mobile app and CRM as the rest, but with correct Shari’ah logic and, if desired, Islamic services for the client.

This perimeter can be assembled in two ways — like any banking product: through custom development or an off-the-shelf (boxed) solution. The choice logic is the same as we discussed in the guides on the cost of launching a neobank and the lending pipeline: off-the-shelf is faster and cheaper at the start with a standard product set, custom development wins with deep customization. Regulatory capital for an Islamic bank, as for a conventional one, is capital on the balance sheet rather than a launch expense; a window lets you do without it but does not cancel the requirements for dedicated assets.

What to ask a banking software vendor. Five questions that quickly separate real support for Islamic products from marketing:

1. How is separate accounting implemented — is it a separate ledger or tagging of operations within a common one?
2. Is there support for intermediate ownership of the asset in murabaha, and how is it reflected in the accounting?
3. How is profit calculated and distributed across the mudarabah pool?
4. What reports does the system produce for the Shari’ah audit and the board’s annual report?
5. Which jurisdiction’s regulation is the solution adapted to — Kazakhstan’s national regime, the AIFC or Uzbekistan? These are three different sets of requirements.

An example of an off-the-shelf solution is the murabaha product of the Ready Bank (affiliated with the publisher) platform: according to the company, this is an implementation-ready solution that connects to the bank’s CRM; the company states adaptation to the Uzbek law on Islamic banking (the CBU’s secondary regulations continue to come out in 2026, so the currency of compliance is worth checking with the vendor). Other banking software vendors in the region are in the market map.

Timelines and team

Licensing timelines — what regulators have published:

• Uzbekistan: a CBU decision on an application within up to 2 months, with notification of the applicant within 3 business days. A 3-year business plan is required, with market analysis, a funding strategy and risk management. The state duty is 0.1% of the minimum charter capital.
• The AIFC: confirmation of receipt of an application within 2 business days; an Initial Review Letter within up to 4 weeks; up to 2 months for the applicant to address comments; subsequent rounds of 2 weeks each. The average processing time for a materially complete application is 2–3 months, followed by an in-principle letter, company registration and the contribution of capital.
• Kazakhstan, national regime: there is no public regulation yet on the timelines specifically for the Islamic license — in June 2026 the ARDFM announced the reissuance of licenses for all banks and 82 secondary regulations in three stages. It is worth going by the general timeline for reviewing banking licenses and building in a buffer.

These are the regulator’s timelines, not the project’s. Everything else is added on top: assembling the Shari’ah board (in Uzbekistan — with AAOIFI certificates and two thirds citizens of the country), writing product methodologies and obtaining the board’s opinions on them, rebuilding accounting, reworking IT, training the front line. A realistic horizon for a window is not “a quarter” but a little over a year from the decision to the first transaction if the IT perimeter is taken off-the-shelf, and longer with custom development.

Who you will have to hire or find on the market:

Market participants name the shortage of Shari’ah specialists and auditors as one of the main constraining factors in Kazakhstan. In Uzbekistan the Central Bank is addressing this systematically: a memorandum with Malaysia’s INCEIF on staff training has been signed, and in 2025 a project office for Islamic finance was created.

What most often blocks a launch

1. Taxes (Kazakhstan). Double VAT on murabaha has not been removed, and the rate rose to 16% from 2026. It is this, not regulation, that holds back Islamic mortgages.
2. Liquidity. There is no Shari’ah interbank market or liquidity management instruments — an Islamic window has nowhere to place a surplus and nowhere to borrow short-term.
3. Staff. Shari’ah advisers and auditors are in short supply across the region; in Uzbekistan formal requirements on citizenship and certification are added to this.
4. Deposit guarantees. The absence of a state guarantee is not a legal formality but a matter of retail client trust.
5. Positioning. By market participants’ estimates, about 90% of the borrowers of Kazakhstan’s Islamic banks are non-practicing Muslims or non-Muslims who come for the terms rather than for religious reasons. A product designed only around religious motivation misses most of its own audience.
6. Two regimes in one market. The market calls the coexistence of the national regime and the AIFC regulatory arbitrage: products that are essentially identical live under different rules, and this complicates both competition and the choice of jurisdiction.

The rest of Central Asia: a brief overview

Kyrgyzstan is the region’s most mature market and the only one with a long history. A memorandum between the republic, the Islamic Development Bank and EcoBank was signed in May 2006, the pilot project was officially launched in July 2007, and the first Islamic deposit products date from May 2008. In June 2025 the NBKR issued EcoIslamicBank a new-format license for Islamic banking operations. The Islamic financing portfolio stood at 18.1 billion soms for the 11 months of 2025 versus 9.0 billion a year earlier, more than doubling; in 2023 Islamic financing accounted for about 2.2% of loans issued by banks.

Tajikistan is second in seniority. Tavhidbank appeared in 2019 as a result of the conversion of Sohibkorbank with ICD support. As of January 2025 the assets of the Islamic segment are around $36M, that is 0.9% of the banking system’s assets, with an average annual growth since 2020 of 29.3%. The infrastructure: one Islamic bank, two microcredit companies with Islamic windows, an Islamic leasing company, and 33 centers for Shari’ah banking services.

What follows from this for Kazakhstan and Uzbekistan. No market in the region has, in twenty years, gone beyond single-digit percentages of banking assets. For comparison: it took Malaysia about forty years to reach 43% of bank loans, Turkey about the same to reach 9.2% of assets; in the UAE the share holds steadily at around 18%. The EDB’s forecast for Central Asia — $6.3 billion by 2033 — is a move into single-digit percentages, not the Malaysian model. The business case for an Islamic window is more honestly counted as capturing a specific segment rather than a market share.

What to do next: a checklist

1. Choose the path — a window, conversion or a separate bank. For testing demand, a window is almost always more sensible.
2. Choose the jurisdiction (for Kazakhstan) — the national regime or the AIFC: they have different requirements, capital, Shari’ah governance rules and tax regime.
3. Calculate taxes before the product, not after. In Kazakhstan, check whether the chosen product runs into double VAT; in Uzbekistan, fix separate accounting of income in the accounting policy, otherwise the benefits do not apply.
4. Assemble Shari’ah governance — the board and product approval procedures. Start before everything else: in Uzbekistan the requirements for the composition are strict, and from 1 July 2027 AAOIFI certification is mandatory for all board members.
5. Determine the starting product — as a rule, murabaha and/or ijara; for housing, diminishing musharakah; for liabilities, mudarabah and wakalah.
6. Think through the communication about deposit guarantees before launch, not after the first client question.
7. Build separate accounting into the IT perimeter from the very start — adding it later is expensive. From the outset, also build in profit distribution across the pool, income purification and reporting for the Shari’ah audit.
8. Verify the current rules with the regulator (the ARDFM / AFSA / the CBU) — under the new laws secondary regulations continue to come out: in Kazakhstan 68 of 82 acts have been adopted, in the AIFC consultations on the new Shari’ah governance rules run until 15 September 2026, and in Uzbekistan national standards based on AAOIFI are being adopted.

Related materials: the hubs Islamic banking in Kazakhstan and in Uzbekistan, the banking software market map, how much it costs to launch a neobank.

Sources

Key primary sources worth checking directly:

• Kazakhstan's Law "On Banks and Banking Activity" No. 258-VIII of 16.01.2026 — adilet.zan.kz
• Uzbekistan's Law on Islamic Banking OʻRQ-1126 of 27.03.2026 — lex.uz
• AIFC Islamic Finance Rules (PDF)
• AIFC Islamic Banking Business Prudential Rules (PDF)
• EDB — IsDBI — LSEG. "The Future of Islamic Finance in Central Asia," 2025 (PDF)
• Kazakhstan's Tax Code No. 214-VIII

Verify current requirements with the regulators — the ARDFM and AFSA (the AIFC) in Kazakhstan, the Central Bank of Uzbekistan, the KDIF for deposit guarantees. Individual facts (the status of secondary regulations, cases, market figures) also rely on business media publications and analyses by law firms (Kursiv, Spot.uz, Gazeta.uz, KPMG, Baker McKenzie, Aequitas, Unicase, Forbes.kz) — with dates given in place in the text.