HR - The American Chamber of Commerce in Kazakhstan

The Human Resources Committee provides a platform for member companies to discuss labor legislation, workforce development, and talent management in Kazakhstan. It brings together HR professionals, legal experts, and business leaders to share best practices, address regulatory challenges, and engage with policymakers on employment-related reforms. The Committee also focuses on fostering inclusive workplaces, advancing leadership development, and supporting a competitive labor market aligned with international standards.

Working Groups/Issues

Issue	Short description	Status
Requirements to publish vacancies at enbek.kz	Employers must publish vacancies for 15 days before applying for work permits, which creates administrative burden due to irrelevant applications and delays in hiring, extending work permit timelines.	Ongoing
High education diploma for work vs. Certificates (CPA, etc.)	Current regulations require formal higher education diplomas for foreign specialists, limiting companies’ ability to hire highly experienced professionals who hold internationally recognized certifications but lack a relevant degree.	Watchlist
Tax deduction of in-kind benefits	There is uncertainty around the tax treatment of non-monetary employee benefits (e.g., medical insurance, psychological support), which are often not deductible and increase employer costs despite their importance for employee welfare.	Not yet started
Calendar days for vacation at the contract	The use of calendar days (instead of business days) for vacation creates confusion and dissatisfaction among employees, especially in international companies, and complicates HR administration.	Not yet started
ICT (intra-corporate transfer)	ICT rules require expatriates to have at least one year of experience with the same legal entity, which does not reflect how multinational companies operate across multiple entities and limits the use of this transfer mechanism.	Watchlist
Labour Code: rotational work cycle (20–21 days)	Proposed changes to reduce rotational shifts from 28–30 days to 20–21 days may significantly disrupt operations in sectors like oil and gas, where longer rotations are standard and operationally critical.	Watchlist
Civil contracts (Договор ГПХ)	Recent legislative changes may lead to civil law (GPH) contracts being reclassified as employment contracts if they exhibit employment characteristics, creating risks of audits, penalties, and the need to transition such workers to formal employment.	On hold
Unified Payroll Payment	Discussion of the practical application of Kazakhstan’s unified payroll payment mechanism, which combines several employee-related taxes and social contributions into a single payment. The issue includes eligibility, calculation, reporting requirements, and the administrative impact on employers.	On hold
Swap program + Secondment	Legal and practical challenges related to temporarily assigning or exchanging employees between affiliated companies or entities. Key issues include employment contract arrangements, payroll and tax treatment, work permits for foreign employees, social contributions, liability, and compliance with Kazakhstan’s labor legislation during the temporary assignment.	Watchlist
Employment orders (“приказы”) requirements	Discussion of whether certain mandatory HR orders and related personnel documents can be simplified, consolidated, or replaced by digital records. The issue focuses on reducing administrative burden while ensuring compliance with Kazakhstan’s labor law and maintaining proper documentation of employment-related decisions.	Not yet started

Frequency of Meetings

Committee Meetings – quarterly
Working Group Meetings – by request

Engagement with the Government

June 29, 2026 – Online seminar on the use of Enbek.kz with JSC “Workforce Development Center”.

How to Join an AmCham Committe

Participation in AmCham committees is open exclusively to AmCham Kazakhstan members.

To join a committee, please sign in to your Member Portal and submit your request directly through the platform. Once submitted, our team will review your request and confirm your participation.