Data control and data accuracy in the Unified State Register of Employers of Kazakhstan: changes in legislation and tools for employers

Effective January 1, 2026, the Republic of Kazakhstan has tightened controls on the use of civil law contracts in cases where an employment relationship effectively exists between the parties.

Entering into civil law contracts is not prohibited in and of itself; however, their use is permitted only in the absence of any indication of employment. If the work is performed in a specific position or profession, the employee is subject to internal work regulations and is compensated for the work process rather than for a specific result, such a relationship must be formalized through an employment contract.

Effective March 12, 2026, administrative liability will be imposed for violations related to the operation of the Unified System for the Registration of Employment Contracts (ESUTD). In accordance with Article 98 of the Code of the Republic of Kazakhstan on Administrative Offenses (CoAO RK), administrative liability is established for violations of the procedure and deadlines for submitting information on the conclusion and termination of employment contracts, as well as on amendments and additions thereto, committed in the form of:

• failure to enter information into the ESUTD within the established deadlines, or entering it late;
• failure to enter all required information into the ESUTD;
• entering inaccurate and/or incorrect information into the ESUTD.

The amount of the fine depends on the business category and increases progressively for repeat violations (1 MCI in 2026 — 4,325 tenge) in accordance with the Code of the Republic of Kazakhstan on Administrative Offenses:

1) Initial violation:

• government officials — 30 MCI (129,750 tenge);
• small businesses and NGOs — 60 MCI (259,500 tenge);
• medium-sized businesses — 80 MCI (346,000 tenge);
• large businesses — 150 MCI (648,750 tenge).

2) A repeat violation within a year:

• government officials — 60 MCI (259,500 tenge);
• small businesses and NGOs — 80 MCI (346,000 tenge);
• medium-sized businesses — 100 MCI (432,500 tenge);
• large businesses — 200 MCI (865,000 tenge).

In this regard, the Ministry of Labor and Social Protection of the Population of the Republic of Kazakhstan reminds employers of the need to strictly comply with the rules for entering data into the ESUTD.

The following information must be entered into the ESUTD: the employee’s IIN, the employer’s IIN/BIN, position and job function, place of work, term of the employment contract, start date, as well as the date and number of the employment contract.

Failure to enter even one of the specified details is considered incomplete provision of information.

In such cases, the employer may: 1) correct any inaccuracies (errors); 2) delete the information if the employee’s and/or employer’s details were entered incorrectly, within 30 business days from the date the initial information was entered. Failure to correct the error in a timely manner entails administrative liability in accordance with Article 98 of the Code of Administrative Offenses of the Republic of Kazakhstan.

To facilitate the transition of businesses to the new requirements, the agency recommends using the proactive tools available on the HR Enbek Labor Resources Portal. The platform is designed to prevent violations: the system automatically identifies inaccuracies and sends notifications to the employer’s personal account regarding discrepancies found for specific employees. This mechanism allows for timely verification of data accuracy and ensures that personnel records comply with current legislation.

In addition, an interactive monitoring dashboard titled “Discrepancies Regarding Employees” has been implemented in the “Employees” section of the Portal. Its database is updated monthly and allows employers to monitor, in real time, the accuracy of information regarding employment contracts and the completeness of mandatory pension contribution payments.

Employers are advised to conduct an audit of existing civil law contracts, assess whether there are signs of an employment relationship, and, if necessary, convert such relationships into employment contracts, including the option of formalizing remote work. It is also important to designate a person responsible for maintaining the Unified State Register of Employment Contracts and ensure compliance with data submission deadlines.

The tightening of regulations is aimed at eliminating the practice of substituting employment relationships with civil law relationships and strengthening guarantees for the protection of workers’ labor rights.