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The Comprehensive Plan is a Government Resolution-level industrial- policy instrument — the Kazakh equivalent of an executive-branch five-year sector strategy — adopted under the authority of the Prime Minister's office and operationalised through the Ministry of Industry and Infrastructure Development (MIID). It is not a primary- legislation instrument and does not by itself amend the Subsoil Code or the Tax Code; instead it sets sector targets, allocates inter- ministerial responsibilities, and authorises the budget envelope through which sectoral programmes (geological exploration, technogenic mineral-formation reuse, enterprise capital modernisation, regulatory reform) are funded.
The plan has four operative layers:
1. Diagnostic. Identifies four sectoral problems: (i) low geological-exploration coverage of rare/REE-prospective regions, (ii) weak commercial exploitation of technogenic mineral formations (mine tailings, slags from copper, lead-zinc and uranium operations that historically contained REE / rare metals as by-products and were stockpiled rather than processed), (iii) depreciated capital stock at legacy Soviet-era processing enterprises, and (iv) an underdeveloped regulatory framework (separate fiscal regime, classification of REE-bearing reserves, licensing pathway). 2. Inter-ministerial coordination. MIID is named as lead. The Ministry of Energy is the technical owner for uranium-by-product REE streams (Kazakhstan is the world's largest uranium producer via Kazatomprom). The Ministry of Foreign Affairs is named as the FDI-attraction owner — the channel through which the EU CRMA strategic-partnership and US/UK/Korea critical-minerals MOUs are negotiated. Samruk-Kazyna and Tau-Ken Samruk are the state-equity vehicles. BDK is the state development-bank financing vehicle. KAZNEDRA is the geological-information operator running mineral.gov.kz. 3. Quantitative targets. USD 25m of state seed-investment designed to crowd-in FDI; 40% increase in production volume of rare and rare-earth metals over 2024-2028; launch of at least five new production facilities including modernisation of Zhezkazganredmet RSE. 4. Digital infrastructure. The mineral.gov.kz public geological-information portal is launched as part of the subsoil-use digitisation programme, exposing previously-classified REE / rare-metal reserve information to investors. This pairs with the broader 2025 Subsoil Code amendments (filed separately as 2025-12-26-kazakhstan-subsoil-code-amendments-uranium-priority) that established the National Geological Service and Unified Subsoil Use Platform.
The plan thereby functions as the parent strategy framework under which downstream legal-codification instruments (the 2025 Subsoil Code amendments) and bilateral FDI instruments (the 2025-11-06 US-Kazakhstan Critical Minerals MOU, EU-Kazakhstan CRMA strategic-partnership signed June 2024) operate. It is the umbrella under which Kazakhstan articulates its 124-deposit REE pipeline to Western FDI partners.
partner.** The plan and its FDI-attraction architecture is the enabling instrument for the EU CRMA strategic-partnership, the 2025-11-06 US-Kazakhstan Critical Minerals MOU, and bilateral REE cooperation talks with Korea, Japan, the UK and Germany. The USD 25m state-seed envelope is small in absolute terms but is designed to crowd-in multi-hundred-million-dollar external capital through the JV / off-take pathway.
by EU CRMA and US Department of State as one of a handful of geographically-significant REE-resource jurisdictions outside China; the plan's success would by 2028 add modest but material marginal-volume supply (40% growth from a low base) into Western off-take. Cumulative impact compounds with India REPM (sintered REE magnets PLI), the 2025-11-14 Indonesia Permen ESDM 18 REE Management framework, and the Western IRA / EU CRMA demand pull.
Plan's diagnostic that the regulatory framework is underdeveloped is the policy rationale for the December 2025 Subsoil Code amendments package (uranium-priority + National Geological Service + Unified Subsoil Use Platform). Reading the two instruments as a stack: 2023 sets the strategic goal, 2025 hardens the legal framework.
upside driver.** Kazakhstan's Soviet-era copper, lead-zinc and uranium operations stockpiled vast tailings volumes that contain REE / rare-metal residues. The plan identifies commercial exploitation of these formations as a target — a lower-capex, faster-payback pathway than greenfield REE mining and one of the few credible levers for adding non-Chinese REE supply on a short horizon.
cluster as a strategy-level instrument (parallel to the South Africa 2025-05-20 Critical Minerals & Metals Strategy, Zambia 2024-08-27 National Critical Minerals Strategy, and Uzbekistan 2025-03-07 Critical Minerals National Programme). It is the Central Asian variant of the EM critical-minerals strategy template — strategy + state vehicle + FDI attraction architecture, distinct from the Indonesia hilirisasi export-ban-led variant.
programme level (geological exploration, technogenic mineral-formation processing, enterprise modernisation, regulatory reform)? The USD 25m headline is the FDI-attractant seed; the full programme spend should be larger and is buried in the subsidiary financing-plan annexes to Resolution P2300001221.
plan have been opened to public investment via mineral.gov.kz versus reserved for the state operator? This determines the realistic non-state FDI pipeline.
to incorporate the institutional architecture introduced by the December 2025 Subsoil Code amendments (National Geological Service, Unified Subsoil Use Platform)? If so, the plan's governance layer would shift from KAZNEDRA to the new National Geological Service.
facilities have actually broken ground by mid-2026? Public reporting suggests the Zhezkazganredmet RSE modernisation and one or two greenfield facilities are in early-CAPEX phase but the IPTM-relevant question is on-time delivery against the 2028 horizon.