Your Kazakhstani customer or buyer is asking for ESG information. Here is what the regulatory environment requires — and what they need from you.
Kazakhstan is Central Asia's largest economy and a significant exporter of oil, gas, metals, and agricultural commodities to EU and global markets. Kazakhstani companies face ESG requirements from two directions: from international buyers and investors subject to CSRD, CSDDD, and EU taxonomy requirements, and from Kazakhstan's own developing ESG regulatory framework. The Kazakhstan Stock Exchange (KASE) has introduced ESG disclosure requirements for listed companies, and Kazakhstan's participation in the Paris Agreement and its 2060 net-zero commitment are driving domestic sustainability regulation.
Key regulations in Kazakhstan — ESG Supplier Guide
KASE ESG Disclosure Requirements
The Kazakhstan Stock Exchange requires listed companies to publish annual sustainability reports aligned with GRI Standards or TCFD recommendations. The requirement covers environmental performance, social responsibility, and corporate governance. From 2024, the scope has expanded and reporting requirements have been strengthened, with the Astana International Financial Centre (AIFC) applying equivalent standards to companies listed on AIX.
EU CSDDD — Corporate Sustainability Due Diligence Directive
EU companies importing from Kazakhstan — particularly in oil and gas, metals, and agricultural commodities — will be required under CSDDD to conduct human rights and environmental due diligence across their supply chains. Kazakhstani suppliers will receive questionnaires covering environmental management, labour rights, community impact, and anti-corruption practices.
Kazakhstan Environmental Code 2021
Kazakhstan's Environmental Code 2021 introduced a comprehensive environmental regulatory framework including mandatory environmental impact assessments, best available technology requirements for industrial facilities, and a national emissions trading scheme. The Code aligns Kazakhstan's environmental standards more closely with EU norms and provides the domestic compliance framework that international buyers assess when conducting supply chain due diligence.
Kazakhstan National ETS — Emissions Trading Scheme
Kazakhstan operates a national emissions trading scheme covering major industrial emitters in energy, metals, and chemicals. Companies subject to the ETS must monitor and report verified emissions data. This provides a credible emissions reporting framework that international buyers and investors can reference when assessing Kazakhstani suppliers' climate performance.
Kazakhstan PDPL & KZ-CERT Cyber Obligations
Kazakhstan's Law on Personal Data and Its Protection (2013, amended 2023) requires data controllers to notify the Authorized Body for Personal Data Protection within 24 hours of a personal data breach. Kazakhstan's KZ-CERT (Computer Emergency Response Team) coordinates national cyber incident response under the Ministry of Digital Development. The Law on Information Security (2023) mandates cybersecurity incident reporting for critical information infrastructure operators. Kazakhstan's digital transformation programme is accelerating cybersecurity regulatory development. Suppliers processing Kazakhstani customer data must align incident response to the 24-hour notification window — one of Central Asia's tightest breach notification deadlines.
What this means for you as a supplier
Kazakhstani companies supplying EU buyers or listed on KASE/AIX face ESG reporting obligations from both domestic and international sources. EU buyers in oil and gas, metals, and agriculture will require supply chain due diligence evidence under CSDDD. KASE-listed companies already have mandatory ESG reporting obligations. The Environmental Code 2021 and national ETS provide a domestic compliance framework that can be used as evidence in international buyer assessments. Anti-corruption compliance — Kazakhstan scores 39/100 on the Transparency International CPI — is a specific area of focus for EU and US buyers.
Key dates
2022 (ongoing)
KASE mandatory ESG reporting — listed companies must publish annual sustainability reports
July 2021 (ongoing)
Environmental Code 2021 in force — stricter environmental standards for industrial companies
July 2029
CSDDD Phase 1 — largest EU companies must conduct supply chain due diligence including Kazakhstani suppliers
2060
Kazakhstan net-zero target — long-term decarbonisation trajectory relevant to energy sector suppliers
AIFC: Kazakhstan's international financial hub
The Astana International Financial Centre operates under English common law and applies international financial and ESG standards equivalent to those of major Western exchanges. Companies listed on the AIX exchange or seeking international investment through AIFC are subject to ESG disclosure requirements aligned with TCFD and GRI. The AIFC provides a bridge between Kazakhstan's domestic regulatory framework and international investor expectations, and is increasingly used by Kazakhstani companies seeking EU and UK institutional investment.
Critical minerals: growing EU supply chain scrutiny
Kazakhstan is a significant producer of uranium, chromium, manganese, and rare earth elements — all classified as critical raw materials under the EU Critical Raw Materials Act. EU companies sourcing these materials from Kazakhstan face specific due diligence obligations under the EUCRMA and CSDDD. Kazakhstani mining and processing companies should be prepared to provide detailed environmental impact, community consultation, and responsible sourcing evidence to EU buyers in the energy, automotive, and electronics sectors.
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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