On January 16, 2026, East 8 Time, Kazakhstan's President Tokayev signed a new version of the "Law on Banks and Banking Activities," officially incorporating digital financial assets into the country's banking regulatory framework. This amendment, which is based on traditional banking law, categorizes digital financial assets into three major categories and, for the first time at the national level, provides a clear legal status for unsecured digital assets, including Bitcoin. This move is seen by the local legal community as a key turning point in the country's cryptocurrency regulatory history. With the enactment of this bill, Central Asia is ushering in a systemic experiment: on one end is a highly regulated banking supervision system, and on the other is a highly volatile and innovative cryptocurrency market. Kazakhstan has chosen to operate at the intersection of the two, seeking a replicable middle ground between regulation and openness.

From Mining Paradise to Regulatory Testing Ground

If we rewind a few years, Kazakhstan's role in the global cryptocurrency narrative was more of a "mining paradise." During the global restructuring of computing power, this energy-rich country attracted a large number of mining companies due to cheap electricity and relatively lenient policies, allowing it to rank among the top in global computing power share. However, with the accumulation of electricity shortages, pressure from energy subsidies, and regulatory concerns, authorities began to adopt a more cautious attitude towards the mining industry, implementing electricity price hikes, tax adjustments, and industry clean-up measures, forcing the sector to transition from extensive growth to contraction and restructuring. It is within this context of repeated policy testing that the current round of amendments targeting digital financial assets becomes particularly significant; it no longer focuses solely on the mining segment but attempts to build a regulatory framework for the entire digital asset ecosystem.

The inclusion of digital financial assets in the banking law is not an isolated measure but is embedded in Kazakhstan's broader "Digital Silk Road" national strategy. The government hopes to leverage digital infrastructure development and financial digital transformation to secure a new position in regional trade and capital flows, with digital financial assets seen as a key component of this strategic matrix. In contrast to neighboring countries that remain vague or deliberately delay their stance on cryptocurrency regulation, many Central Asian nations have maintained ambiguity on the issue to avoid prematurely taking sides in uncertain areas. In stark contrast, Kazakhstan has directly chosen to embed relevant rules into fundamental banking legislation, enhancing the policy's binding force and predictability through the approach of "writing it into banking law." This level of radicalism stands out in the region and naturally positions Kazakhstan as a regulatory testing ground.

Three Categories of DFA: Bitcoin Finally Gets a Clear Identity

The new law categorizes digital financial assets into three major classifications: the first category consists of digital assets backed by fiat currency, aimed at tokenized tools supported by national or other sovereign currencies; the second category includes asset tokenization products, which represent and circulate traditional assets such as stocks, bonds, and real estate in a blockchain format, bridging traditional finance and distributed technology; the third category refers to electronic financial instruments, which more broadly point to various financial contracts and rights certificates issued, recorded, and circulated in digital form. The common characteristic of this classification method is that all categories have a direct or indirect anchoring relationship with the existing financial system, linking emerging digital forms with traditional financial structures through underlying assets, legal tender, or existing financial contracts.

What truly constitutes the market focus is the positive inclusion of "unsecured digital assets" in the legal text. According to multiple sources, this amendment explicitly brings digital assets that are not backed by fiat currency or real-world assets into the regulatory purview, defining them with Bitcoin as a representative. Legal experts have commented that this move makes Kazakhstan the first country in Central Asia to clearly define Bitcoin's status at the legal level, no longer viewing it merely as a technological experiment or gray asset, but categorizing it as a regulated financial asset. Industry analysts believe that this classification of digital financial assets reflects a "precise grasp" of the essential differences between different types of cryptocurrency assets, acknowledging the existence and value of decentralized assets while incorporating them into a layered management system through classification.

From a regulatory perspective, this DFA classification is not merely a technical label but an attempt at layered management centered on underlying support and risk characteristics. Taking fiat-backed digital assets as an example, their credit and volatility primarily stem from the issuing entity and the anchor currency itself, allowing regulatory paths to directly reuse traditional payment and deposit regulatory logic; asset tokenization products more closely follow the regulatory frameworks of securities, trusts, or funds, controlling risks through disclosure, custody, and investor protection mechanisms; while unsecured digital assets, due to the lack of real-world collateral, are viewed as high-volatility, high-risk assets. However, in this legislation, they are included in regulation rather than being excluded, indicating that regulators clearly hope to impose stricter capital constraints and behavioral regulations on them while acknowledging their financial attributes through differentiated rules and risk weight settings.

National Bank Licensing: Exchanges Enter Central Bank's Sight

Equally noteworthy as asset classification is the concentration and restructuring of regulatory authority. According to public information, this amendment clearly assigns the Kazakhstan National Bank the leading role in issuing licenses for cryptocurrency exchanges, meaning that cryptocurrency trading activities, which were previously marginalized and subject to inter-departmental coordination, are now formally included in the central bank's direct observation and management scope. For exchanges, operating legally in the local market will no longer be merely a matter of business registration or communication with individual regulatory departments; they must now follow a licensing path similar to that of traditional financial institutions, complying with the National Bank's systematic requirements regarding capital, risk control, governance, and reporting obligations.

At the commercial banking level, the law opens new boundaries for banks to participate in financial technology and digital asset-related businesses. Research briefs indicate that regulators have clearly empowered banks to engage in financial technology investments and collaborations within a certain scope. Although specific ratios and details are still pending verification, the directional change is sufficient to reshape the relationship between banks and cryptocurrency institutions. In the past, banks often maintained distance from cryptocurrency businesses through account blocking and risk control exclusions; now, they are allowed to participate as partners, infrastructure providers, and even investors within the institutional framework, thus building a pathway for traditional finance and the cryptocurrency industry to move from opposition to co-construction.

This model has potentially far-reaching implications for KYC, fund flow monitoring, and risk isolation. On one hand, the central bank's leading role in license issuance, combined with deep participation from commercial banks, can guide more cryptocurrency fund flows into regulated account systems, thereby enhancing customer identity verification and suspicious transaction monitoring capabilities. On the other hand, establishing an effective "buffer zone" between bank balance sheets and high-volatility digital assets to prevent risks from penetrating the core systems of traditional finance will become a key challenge for subsequent regulatory design. It is also worth noting that the current public information does not disclose details regarding specific anti-money laundering measures or the standards for which digital assets can circulate in the country, creating a regulatory gap that somewhat weakens external judgment on the enforcement strength and implementation path of the new regulations, while also leaving considerable room for future rule adjustments and interpretations.

Central Asia Regulatory Race: Who is Waving to Capital

In the broader geopolitical context of Central Asia, Kazakhstan's recent amendments undoubtedly raise the stakes in the regional regulatory competition. In contrast, many neighboring countries remain cautious regarding cryptocurrency compliance, taxation, and licensing systems: some only address the administrative management of electricity for mining, while being vague about trading and custody businesses; others indirectly restrict domestic residents' participation in the digital asset market through foreign exchange controls and capital flow rules, without establishing a dedicated licensing framework. Against this backdrop, the label of "the first country to clearly define Bitcoin's legal status in legal texts" becomes one of the signals Kazakhstan is trying to send to international capital and industry institutions, conveying a relatively open yet not entirely permissive stance.

For mining companies, after experiencing the policy rollercoaster of earlier years, a written DFA regulatory framework at least provides greater certainty in terms of rule visibility, allowing them to make more refined medium- to long-term plans around taxation, electricity, and compliance costs. For international exchanges and fintech companies, the central bank's licensing and the backing of banking law mean that if they are willing to accept local regulatory requirements, they have the opportunity to establish licensed entities and connect with local banking channels to build regional business hubs in Central Asia. In a context where many countries still view cryptocurrency businesses as a "regulatory vacuum" or "high-risk gray area," such institutional arrangements have the potential to create a "compliance lowland," attracting emerging financial institutions seeking to expand within a compliant framework.

However, the tension between regulatory friendliness and policy reversals cannot be overlooked. Kazakhstan's previous rapid shifts in the mining industry have already provided a vivid example to the market: when energy, public opinion, or the macro-financial environment changes, policies that were originally packaged as "friendly" may be revised or tightened in the short term. Now, as the discourse of "a new regulatory model in Central Asia" begins to circulate in the industry, avoiding excessive marketing of the "cryptocurrency-friendly jurisdiction" label will become a common challenge for policymakers and market participants. For institutions seeking to establish a presence, rather than being driven by marketing rhetoric, it is better to return to the legal texts and regulatory practices themselves to assess whether this institutional framework is a sustainable infrastructure or a temporary arrangement that can easily be rewritten before the next cycle's turning point.

Regulation of Unsecured Assets: Kazakhstan's Reverse Choice

In a global comparison, Kazakhstan's positive legal inclusion of unsecured digital assets appears quite counterintuitive. In the mainstream financial regulatory context of Europe and the United States, "unsecured" is often directly equated with high-risk or even speculative instruments, with corresponding policies focusing more on limiting retail exposure, strengthening disclosure and marketing constraints, and even in some jurisdictions, treating certain decentralized assets as illegal securities or unauthorized investment products. In emerging markets, there are also cases of outright bans on trading or payments. Against this backdrop, categorizing assets like Bitcoin as regulated financial assets at the banking law level, rather than merely marking them as sources of systemic risk, constitutes an important difference in Kazakhstan's regulatory attitude.

This difference is not only reflected in legal language but also in the redefinition of the term "unsecured." When regulators acknowledge that assets like Bitcoin can be held, traded, and recorded within a compliant framework, and that both the National Bank and commercial banks are involved in building the relevant infrastructure, their role shifts from "regulatory issues" to "regulatory subjects." They are no longer just items on a risk list but new types of assets that need to be measured, constrained, and allowed to exist within the financial system. This change in perspective could potentially influence the inherent labels of unsecured assets in global policy discussions in the medium to long term, providing other countries with a third path that differs from the binary opposition of "prohibition" and "permissiveness."

For resource-dependent countries or emerging economies that hope to find new engines of growth through financial innovation, Kazakhstan's approach undoubtedly provides a model for observation. If this model, centered on DFA classification and incorporating unsecured assets like Bitcoin within the banking regulatory framework, can achieve a balance between controllable risks and capital inflows in practice, it is not out of the question that it could be partially replicated or localized in other countries in the future. In such a scenario, a "regulated Bitcoin economic belt" formed by multiple emerging economies will gradually take shape, where assets like Bitcoin will no longer just be tools for cross-border arbitrage but will become important interfaces through which these countries attempt to connect with global capital and technology networks through institutional design.

Betting on a New Regulatory Order and Unresolved Questions

Overall, the revision of the "Law on Banks and Banking Activities" holds multiple symbolic meanings in the context of cryptocurrency regulation in Central Asia and even globally. Bitcoin, as an unsecured digital asset, has been directly written into legal texts, breaking its long-standing "gray identity" in most jurisdictions; the National Bank has gained the leading role in issuing licenses for cryptocurrency exchanges, bringing this emerging market into the central bank's regulatory concepts and toolbox; and commercial banks are allowed to participate in financial technology and digital asset-related businesses within the institutional framework, indicating a higher-dimensional intersection between traditional finance and the cryptocurrency industry. These changes together represent Kazakhstan's public bet on the future financial order and its proactive reshaping of its role in the Central Asian financial landscape.

However, key information that will determine whether this new regulation can transition from a "model house" to a "livable city" still has many gaps. Research briefs clearly point out that there has yet to be a public and detailed explanation regarding the specific rules for anti-money laundering measures and the standards for the list of digital assets that can circulate in the country. These seemingly technical clauses will directly determine the breadth of regulatory boundaries, the level of compliance costs, and will also affect the final conclusions drawn by international institutions when assessing local risk levels. If future supporting rules lean towards tightening in execution, the new regulations may remain largely symbolic; conversely, if an appropriate balance is achieved between risk control and innovation, it may have the opportunity to become a model system that can be referenced in the region.

Looking towards future developments, three main lines are worth continuous observation. First is the pace of license issuance: whether the National Bank will cautiously pilot a few institutions or choose to accelerate the licensing process under the premise of controlling risks will directly reflect the regulator's true attitude towards this market. Second is the actual depth of bank participation: whether commercial banks will view digital assets as a symbolic layout of marginal business or genuinely step into the forefront in areas such as payments, custody, and investment financing will affect the speed of infrastructure development for the entire ecosystem. Third is the migration and experimentation of international capital and cryptocurrency companies: whether leading mining companies, trading platforms, or fintech firms choose Kazakhstan as a regional hub will be an important indicator of this system's attractiveness to the global market. The new regulatory order has already been written into law, but whether it constructs a solid fortress or remains an unfinished blueprint still requires time, market, and policy practices to provide answers.

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