Asset tokenization: digital financial asset platform development
In Kazakhstan, the lawful route to tokenizing an asset is a digital financial asset (DFA). A resident legal entity issues it on the platform of an operator registered with the National Bank. We build the software for that chain: the operator’s platform, issuer and investor areas, the registry and the smart contracts.
Software development, the client issuesWhat the law says
Law No. 193-VII on Digital Assets as in force since 1 May 2026, the Law on Permits and Notifications and the Law on Advertising.
- A DFA certifies a right
A DFA is a digital asset certifying a monetary or other claim to an underlying asset, or a financial instrument or financial asset, issued on the platform of a DFA platform operator (Art. 1(6-6)). The underlying asset is property whose value determines the value of the DFA (Art. 1(6-8)).[1]
- Three kinds of DFA
Stablecoins, whose underlying asset is money; DFAs whose underlying asset is financial instruments, property rights, goods or other property except money; and financial instruments in electronic digital form on the operator’s platform (Art. 5).[1]
- Issuer and platform
The issuer of a DFA is a legal entity resident in Kazakhstan (Art. 1(6-10)). Issuance takes place only on the platform of an operator that has passed registration with the National Bank, and operating without registration is not allowed (Art. 6(1), (7)).[1]
- Custody and circulation
The underlying asset is recorded and held by a custody organisation. The list of property that can underlie DFAs of the second kind, and how it is held, is set by an act of the Agency for Regulation and Development of the Financial Market (Art. 6(4)). DFAs circulate on the platform of a DFA operator or a trading platform operator (Art. 6(5)).[1]
- Who regulates
The National Bank approves the rules for issuing stablecoins, and other DFAs are regulated by the Agency for Regulation and Development of the Financial Market (Art. 4(1), (2)). Issuance in the AIFC and by AIFC participants has its own rules (Art. 6(22), (23), (25)).[1]
- Operator registries
Inclusion in the registries of DFA platform operators and trading platform operators is provided for by the Law on Permits and Notifications (Annex 2, items 84-3 and 84-4).[2]
- Advertising without guarantees
Advertising of digital assets may not guarantee income from them or give guarantees of future performance, including by announcing a rise in their market price (Law on Advertising, Art. 14, subparas 2 and 4).[3]
What we build
For the platform operator, the issuer and the investor.
Who does what
The client provides the regulatory status, we are responsible for the software.
| Who does what | The client | Pazl |
|---|---|---|
| Status | National Bank registration, an AFSA licence or a foreign regulator’s licence | Not a digital asset service provider, we develop software |
| Issuing DFAs | The issuer, on the operator’s platform | Issuance logic in the code and smart contracts |
| Client money and assets | The operator, the bank and the custody organisation | We neither accept nor hold them |
| Rules and wording | The client’s lawyer and compliance team | We turn requirements into the spec and the code |
How the work goes
From the issue structure to launch with the operator.
- Structure with your lawyer
Asset, issuer, platform operator, custody and transfer rules are set by the client’s lawyer.
- Specification
Roles, issue statuses, transfer rules and reports are written down before code.
- Test environment
Issuance, transfer and redemption are tested together with the operator’s team.
- Launch and handover
The live issue is run by the operator. Code, documentation and access stay with the client.
No income promises
We do not issue or sell DFAs, do not accept investors’ money and do not write income promises. This is not legal advice: your lawyer assesses the issue structure for your company, and the current wording of the laws should be checked on adilet.zan.kz.
Next to tokenization
Related services and the law.
Checked on 15 November 2026
- Law of the Republic of Kazakhstan No. 193-VII of 6 February 2023 "On Digital Assets in the Republic of Kazakhstan"
- Law of the Republic of Kazakhstan No. 202-V of 16 May 2014 "On Permits and Notifications"
- Law of the Republic of Kazakhstan No. 508 of 19 December 2003 "On Advertising"
This is not legal advice. Laws change: before launch, check the current version on adilet.zan.kz and talk to a lawyer or accountant.
Short and to the point.
Can an asset be tokenized in Kazakhstan?
Yes, as digital financial assets. The issuer, a resident legal entity, issues them on the platform of an operator registered with the National Bank (Art. 1(6-10), Art. 6(1)). We build the software for this set-up, while the status and the issue stay with the client.
Do you issue or sell tokens?
No. We develop software. The issuer runs the issue on the operator’s platform, and client money and assets sit with the operator, the bank and the custody organisation.
Who do you build these platforms for?
DFA platform operators and companies preparing for registration, issuers working with an operator, AIFC participants licensed by AFSA and projects for foreign markets.
Which assets can be tokenized?
The law allows DFAs whose underlying asset is money, financial instruments, property rights, goods or other property (Art. 5). For DFAs of the second kind the list of property is set by an act of the Agency (Art. 6(4)), so whether your asset fits is decided by your lawyer together with the platform operator.
How much does a tokenization platform cost?
We name the price after the brief, once your role, the operator and the scope are clear, and fix it in the contract.
Who owns the code?
You do: the code, repository and access are handed to the client, with a 6-month warranty on our work.
What do you want to tokenize?
Describe the asset and your role: operator, issuer or AIFC participant. We reply quickly and tell you where to start.