Important. This list is practical and covers the most frequent findings. The exact set of required documents depends on headcount, activity and company specifics. Current requirements are in the applicable version of the Labour Code at adilet.zan.kz.
Why this matters more than it seems
Missing HR documents create three distinct risks. The first is administrative liability during an inspection. The second, and more expensive, is a lost labour dispute: if an employer cannot document its position, the court decides in favour of the employee. The third is the inability to hold an employee accountable for breaching rules they never signed to acknowledge.
The checklist: 12 items
| No. | Document | What to check |
|---|---|---|
| 1 | Employment contracts with all employees | One for every employee, all required terms, signatures of both parties, a copy given to the employee |
| 2 | Internal labour regulations | Approved, current, employees have signed to acknowledge them |
| 3 | Staffing schedule | Approved, matching actual headcount and the job titles in contracts |
| 4 | Personnel orders | Hiring, transfer, leave, dismissal — for every HR action, citing the relevant provisions |
| 5 | Personal files and record cards | Maintained, containing current data, personal data protected |
| 6 | Leave schedule | Approved, employees informed, actual leave documented by order |
| 7 | Working time records | Kept regularly and consistent with payroll calculations |
| 8 | Job descriptions | One for every role, employees have signed to acknowledge them |
| 9 | Pay and bonus documentation | Policy approved, bonus criteria clear and applied consistently |
| 10 | Occupational safety documents and briefings | Briefings delivered, logs completed, signatures present |
| 11 | Consents to personal data processing | Obtained from all employees, data storage properly organised |
| 12 | Acknowledgement sheets for employer acts | For each internal document — signatures of all employees with dates |
Item 12 is the most underrated. Since 2026 the concept of an employer act has been broadened: more internal documents now fall under it. A document without an acknowledgement sheet effectively does not work — you cannot rely on it in a dispute or when imposing a penalty.
How to run a self-check in two hours
- Take the list of employees and check there is an employment contract for each. Separately check part-timers, temporary staff and anyone working "by arrangement"
- Compare job titles in contracts against the staffing schedule. Discrepancies are a frequent inspection finding
- Check orders for the past year: every HR action should have a document
- Find the acknowledgement sheets for internal regulations and job descriptions
- Check how current your templates are: if the employment contract has not been updated for several years, it almost certainly contains outdated wording
- Look separately at leavers from the past year: were the grounds correctly documented and settlements made
Typical findings in small and medium business
What turns up most often
- An employee has been working for months and the employment contract is still unsigned
- Contracts exist but were signed in a single copy and never given to employees
- Job titles in contracts do not match the staffing schedule
- Internal labour regulations exist but nobody has been asked to acknowledge them
- Leave is granted in practice but never documented by order
- Bonuses are paid at the manager's discretion with no approved criteria
- Job descriptions were downloaded from the internet and do not reflect actual duties
- Consents to personal data processing are absent entirely
How to organise storage
Having a document and being able to find it quickly are different things. In an inspection or in court, a document that "exists somewhere" but cannot be located within a reasonable time works exactly like a missing one.
Basic rules
- A separate folder for each employee: contract, orders, applications, acknowledgement sheets
- A single register of orders with continuous numbering and no gaps
- Electronic copies of all key documents with backup storage
- Access control: personal data should not be open to the whole company
- Documents of leavers kept for the prescribed periods rather than destroyed immediately
- One person responsible for the HR archive — with diffused responsibility documents get lost
On personal data. HR documents contain personal data, and their processing is governed by the law of Kazakhstan on personal data and its protection. Employee consent is required, along with organisational protection measures: restricted access and secure storage. Free access to personal files for all employees is a breach.
What to do in house and what to outsource
Proper HR record keeping requires time and knowledge of current requirements. A realistic approach for a smaller company looks like this:
| Headcount | Sensible approach |
|---|---|
| Up to 10 people | Outsourced HR records — an in-house administrator is uneconomic, and doing it yourself is risky |
| 10–50 people | Outsourcing, or combining the function with accounting provided that person understands labour law |
| 50–150 people | An in-house HR administrator, with an external audit once a year if needed |
| Over 150 | An HR department with divided functions |
The most vulnerable position is in companies where HR record keeping hangs on the accountant or office manager as an additional duty. Formally the function is covered; in practice neither time nor expertise remains for it.
Where to start if there are many gaps
Do not try to close everything at once. The priority is:
- Employment contracts — without them the risk is greatest
- Personnel orders for the current year
- Internal regulations and acknowledgement sheets
- Staffing schedule and aligning contracts with it
- The remaining documents in order of importance for your activity
In brief
The minimum set of HR documents includes employment contracts, internal labour regulations, a staffing schedule, personnel orders, a leave schedule, working time records, job descriptions, pay and safety documentation, consents to personal data processing and acknowledgement sheets. The most common and most expensive failing is missing acknowledgement signatures: without them a document does not protect the employer.