Important. This article is a practical overview, not a legal opinion. Labour legislation changes, so before making HR decisions check against the current version of the Labour Code at adilet.zan.kz or consult a specialist.
Digitalisation of HR processes
A separate chapter has been added to the Code on conducting HR processes within a digital personnel system. At this stage the requirement is addressed to state institutions and quasi-public sector entities: the procedure for conducting such processes and the rules of access to the system have been defined.
For private business this creates no direct obligation to move to a digital system. But the direction is clearly set, and the practical conclusion for commercial companies is this: HR record keeping is gradually shifting to electronic format, and companies whose documents exist only in paper folders will find themselves at a disadvantage during inspections and when interacting with government services.
What to do: if you work with the public sector or quasi-public companies, clarify the requirements for digital HR document flow. Everyone else should put their records in order and ensure HR documents exist in a structured electronic form.
The concept of an "employer act" has been broadened
This change looks technical but in practice it is the most significant. Previously employer acts covered internal documents directly regulating employment relations — orders, internal labour regulations, policies. Now they also include other acts connected with employment relations.
What this changes in the real life of a company:
- More internal documents fall under requirements for drafting, approval and familiarising employees
- Documents previously considered "informal" — procedures, instructions, bonus policies — acquire legal weight
- Accordingly the risk grows: if an employee has not signed to confirm they have read a document, relying on that document in a dispute becomes difficult
Check in your own company
- Whether all internal documents affecting employees' work have been properly approved
- Whether there are signed acknowledgement sheets for each such document
- Whether internal procedures contradict employment contracts or the Labour Code
- Whether there are "grey" rules applied in practice but written down nowhere — these must either be formalised or stopped
Leave for screening examinations
An obligation has been introduced for employers to grant employees leave to undergo screening examinations. Failure to grant such leave entails liability under the legislation of Kazakhstan.
In practice this means a corresponding clause should appear in the internal labour regulations and in the leave procedure, and department heads should know that such leave cannot be refused.
What changed in calculations from 2026
One change directly affecting HR and accounting teams deserves separate mention: from 1 January 2026 the mechanism of offsetting social tax against social contributions ceased to apply. This changes how the burden on the payroll fund is calculated.
Basic deductions from employee income remain unchanged:
| Payment | Rate | Paid by |
|---|---|---|
| Mandatory pension contributions | 10% | employee |
| Individual income tax | 10% after deductions | employee |
| Compulsory health insurance contributions | 2% | employee |
| Employer contributions and taxes | depend on the tax regime | employer |
If you have no dedicated HR administrator or accountant tracking such changes, the risk of errors in calculations and reporting increases substantially.
What to check in employment contracts
An employment contract template is a document created once and then copied for years. That is precisely why outdated wording is most often found in it.
Mandatory template review
- All required terms are present and stated specifically, not by reference to "in accordance with legislation"
- The probation condition is stated explicitly if you apply one
- Place of work and the regime of working and rest time are specified
- Pay arrangements are described so the employee understands what makes up their income
- There are no terms worsening the employee's position compared with the Labour Code — such terms are void
- The contract is signed by both parties and a copy has been given to the employee
Who is at greatest risk
From experience working with Kazakhstan companies, HR compliance failures concentrate in fairly predictable places:
| Type of company | Typical problem |
|---|---|
| Small business without an HR administrator | HR functions split between the accountant and the manager, records kept on a residual basis |
| Fast-growing companies | Headcount has grown while HR processes remain as they were with five employees |
| Companies with branches | Different practices operate in different units, with no unified employer acts |
| Organisations with high turnover | Large volumes of hiring and dismissal, documents drawn up retrospectively |
A retail company grew from 8 to 45 employees in eighteen months. Throughout that period the accountant maintained HR documents in spare moments: contracts were signed but many late, and leave orders were issued selectively.
The problem surfaced in a labour dispute with a dismissed employee: the company could document neither familiarisation with internal regulations nor the grounds for the disciplinary measures it relied on.
Restoring the HR records took a month and a half and required an external specialist — substantially more expensive than outsourced HR administration would have cost over that entire period.
An action plan for the coming month
- Take stock of internal documents. Compile a list of all acts affecting employment relations and check how they were approved
- Acknowledgement sheets. Make sure each document has employee signatures. This is the first thing examined in a dispute
- Update internal labour regulations to reflect the new provisions, including screening leave
- Review employment contracts for compliance with the current version of the Code — especially templates used for years
- Reconcile payroll calculations taking the 2026 changes into account
In brief
The main 2026 changes: a chapter on digital HR processes for state institutions and the quasi-public sector, a broadened concept of employer acts, and a new obligation to grant leave for screening examinations. For business the main practical conclusion is to put internal documents and acknowledgement sheets in order, since a wider range of acts now falls under the requirements.