On June 8, 2026, amendments to the labor legislation of the Republic of Kazakhstan come into force. According to the official website of the President of Kazakhstan, on June 3, 2026, the Head of State signed a law introducing amendments and additions to legislative acts aimed at improving labor legislation.
According to explanations provided by the Ministry of Labor and Social Protection of the Population, the key changes include a prohibition on using civil law contracts to conceal employment relationships, a revised procedure for compensating employees who temporarily perform the duties of absent employees, and expanded mandatory requirements for collective bargaining agreements.
For businesses, the most sensitive issue concerns civil law service contracts (GPC contracts).
If a contractor effectively works as a regular employee, follows a work schedule, performs ongoing job functions, complies with internal company policies, and receives regular remuneration, such a contract may be reclassified as an employment relationship.
For accounting and HR departments, this may create significant tax and labor risks, including:
- additional assessment of individual income tax (IIT);
- additional assessment of social contributions and payroll-related charges;
- claims regarding pension contributions;
- labor law penalties and administrative fines;
- employment disputes initiated by contractors.
Recommended Actions
- Conduct an inventory of all civil law contracts.
- Review contracts concluded with individual entrepreneurs and individuals.
- Identify contractors performing work on a permanent basis.
- Assess the presence of employment relationship indicators.
- Reclassify relationships into employment contracts where necessary.
- Verify that employment contracts have been properly registered in the Unified Employment Contract Registration System (ЕСУТД).
Conclusion
The formal title of a contract is no longer sufficient protection. Regulatory authorities assess the actual substance of the relationship rather than the wording of the agreement.
For companies using accounting outsourcing services, this issue is particularly important, as the risks often arise not from tax reporting itself but from deficiencies in primary HR documentation and contractual arrangements.