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Law No. 86-VII ZRK "On Industrial Policy" is the horizontal framework statute that defines and authorises Kazakhstan's full toolkit of industrial-policy instruments. It does not itself disburse subsidies or designate SEZs; instead it sets the legal architecture under which subsequent Government Resolutions, Presidential Decrees, and ministerial orders operate. Three features make it the load-bearing instrument for the Kazakh industrial-policy stack:
1. Defines the catalogue of state-support measures (Article 24). The law enumerates the permitted forms of state support available to industrial entities: direct subsidies, in-kind grants (state property contributed to industrial projects), SEZ participant status, industrial-zone resident status, offtake guarantees (long-term state purchase commitments), preferential public-procurement access, long-term tariff agreements (especially for energy and rail tariffs in metallurgy), and concessional financing through BDK. This is the article amended by Law 86-VIII ZRK of 21 May 2024 to refine the eligibility criteria and reporting obligations.
2. Sets the institutional architecture. MIC (formerly MIID) is named as the lead policy owner. BDK is the principal industrial- finance vehicle. QazIndustry is the state operator implementing programme-level instruments. Samruk-Kazyna and Tau-Ken Samruk are the state-equity vehicles. The Ministry of Foreign Affairs is named as the FDI-attraction owner. This architecture is inherited by the downstream programme-level instruments (the 2023 REE Comprehensive Plan, the 2024 Investment Policy Concept, the 2025 Subsoil Code amendments).
3. Establishes the "single card of industrialization" monitoring framework. A unified-registry instrument that tracks every subsidised industrial project, its state-support footprint, and its performance against pledged outcomes — the digital compliance backbone that allows MIC to enforce conditionality on subsidised projects and that exposes the industrial-policy spend to public reporting.
The law has been amended eleven times since adoption:
The 86-VIII ZRK amendment of 21 May 2024 is the highest-profile recent revision: it tightens the eligibility framework for state- support measures and is the immediate predecessor to the 18 October 2024 Investment Policy Concept until 2029 (Government Resolution USD-150bn FDI target, BDK 6%/10-year concessional infrastructure- finance regime), which is the most consequential implementing instrument under the law.
pipeline.** Every Kazakh critical-minerals investment instrument — the 2023-12-28 REE Comprehensive Plan, the 2025-12-26 Subsoil Code amendments, the 2025-11-06 US-Kazakhstan Critical Minerals MOU, the June 2024 EU-Kazakhstan CRMA Strategic Partnership, and the bilateral REE/uranium cooperation talks with Korea, Japan, Germany and the UK — operates inside the state-support architecture this law defines. Without Article 24 there would be no legal basis for the offtake guarantees, SEZ regimes, and BDK concessional financing that Western FDI partners rely on when structuring Kazakh REE / uranium JVs.
thirteen SEZs (including Astana NIT, Khorgos-East Gates, Pavlodar-2, NIPT, MorPort Aktau, Saryarka-Karaganda) plus industrial-zone regimes hosting Western manufacturing FDI (Kazakhmys, ERG, Eurasian, Kazatomprom). All operate under participant-status criteria set by the Law on Industrial Policy. Recent EV / battery-cell / smelter FDI announcements (Chinese battery-cell prospecting, Korean JV smelters, EU-aligned REE separation plants) are routed through SEZ status pathways enabled by this law.
Article 24's authorisation of long-term state offtake guarantees is what allows MIC and Samruk-Kazyna to commit to multi-decade purchase contracts for output from new metallurgical and rare-metal facilities — a critical de-risking lever for Western capital structuring large-CAPEX greenfield REE / uranium JVs with Kazakh state vehicles. This mechanism is materially more generous than what Mongolia, Uzbekistan, or Tajikistan can offer under their respective industrial-policy frameworks.
sits in the EM upstream-capture cluster as the parent legal- framework instrument (parallel to Indonesia's UU Cipta Kerja, South Africa's MPRDA, Zambia's Mines and Minerals Development Act, and Uzbekistan's Subsoil Code) — but distinct from those in being a horizontal industrial-policy statute rather than a sectoral subsoil-resources statute. The Kazakh stack therefore has two parallel parent instruments: this law on the industrial-policy / investment-attraction side, and the Subsoil Code on the minerals-extraction side.
eleven amendments in three and a half years, the law has not been repealed or restructured; the amendment pattern is refinement-and-expansion rather than reversal. This stands in contrast to Indonesia (PP 19 royalty changes, PP 28 nickel- smelter moratorium, UU 2/2025 Minerba fourth amendment) where the industrial-policy framework has been amended in substantively destabilising ways. The Kazakh framework's policy-stability profile is one of its principal selling points to Western FDI counterparties.
21 May 2024 to Article 24? Public reporting suggests refinement of eligibility criteria for state-support measures but the granular text of the amending act is not freely available in English; only the consolidated post-amendment text is on Adilet.
January 2026) materially altered the SEZ participant criteria or the BDK concessional-financing regime? This amendment is the most recent and its effective date is imminent — worth a follow-up wake-discovery sweep in early 2026.
BDK concessional loans + foregone revenue from SEZ tax exemptions) authorised under the law? Public budget reporting rolls these up to a single industrial-policy line; the underlying disaggregation matters for sizing the trade-distortion footprint vis-à-vis WTO subsidies disciplines.
toolkit (offtake guarantees, long-term tariff agreements) under ASCM disciplines? Kazakhstan acceded to the WTO in November 2015; any consultations or panel requests targeting the instruments authorised by this law would be precedent-setting for the EM industrial-policy template.