Custodial vs non-custodial wallet
The difference is who holds the keys. In a custodial wallet a company holds users’ assets, and in Kazakhstan that is a regulated activity requiring a licence or registration. In a non-custodial wallet the user holds the keys. We write software for both models and never hold the keys ourselves.
Both models, keys never with usThe two models point by point
The main difference: who can move the assets.
| The two models point by point | Custodial | Non-custodial |
|---|---|---|
| Who holds the keys | The operating company or its custodian | The user, on their own device |
| Lost phone | Support restores access | The user restores from their own backup |
| Operator status in Kazakhstan | Holding assets for clients is regulated; a licence or registration is needed | Judged on how the product works; the lawyer decides |
| Fits best | Apps of licensed companies | Users who hold their own keys |
| What we build | An app on top of a licensed custodian’s API | An app, keys on the device, recovery |
What Kazakhstan law says
The Law on Digital Assets and the Law on Permits as in force on 15 November 2026.
- A wallet is a tool for keys
A digital asset wallet is a software or hardware tool used to store cryptographic keys (Article 1, subparagraph 4-2 of the Law on Digital Assets).[1]
- Holding is part of circulation
The circulation of digital assets includes buying, selling, exchanging, transferring and holding them (Article 1, subparagraph 4-3). If an app holds users’ assets, that is a question of the operator’s status, not just a feature.[1]
- Client wallets follow National Bank rules
The requirements for opening and servicing clients’ digital asset wallets are set by the National Bank of Kazakhstan (Article 12-1, paragraph 7).[1]
- Custody is a licensed activity
The list of licences includes a licence for activity on the securities market and the digital asset market; its first sub-type is custody (Annex 1, item 54 of the Law on Permits and Notifications).[2]
Which to choose
Choose the model with your lawyer, before the first screen.
- The product is launched by a company with a licence or registration
- Users expect support to restore access
- A licensed custodian holds the assets
- Users hold their own keys and sign their own actions
- The company does not want control over other people’s assets
- The app works with dApps and contracts directly
The hybrid: an embedded wallet
Easy sign-in, but the custody question remains.
How we work
Keys and recovery first, screens second.
- Map the keys
Who signs, who restores and who can transfer, on one page.
- Choose the model with your lawyer
Custodial, non-custodial or embedded.
- Prototype recovery
The lost-phone path is tested first.
- Build and release
iOS, Android or web, app store release, code with you.
We do not hold the keys
Pazl writes the software and has no access to users’ keys or assets. A custodial wallet for users in Kazakhstan is launched by a client with a licence or registration, and the app runs on top of its custodian’s API. Your lawyer decides which status you need.
Read next
Development, design 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"
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.
Which is safer, custodial or non-custodial?
Neither by default. Custodial puts the risk on the custodian’s security and reliability; non-custodial puts it on the user’s device and backup. Good recovery design matters more than the label.
Is an embedded wallet custodial?
It depends on who can move the assets. In some setups the provider cannot sign a transfer alone; in others it can restore the key. That is why we document the key setup in writing for your lawyer.
Can we start with one model and switch later?
Yes, if it is planned from the start: custody is kept apart from the rest of the app, and the second mode is added later. Moving existing users’ assets needs their action and a careful migration flow.
Will you build a custodial wallet for users in Kazakhstan?
We will write the app if your company, holding a licence or registration, is the operator and a licensed custodian holds the assets. Without that status, we suggest the non-custodial model.
How much does wallet development cost?
There is no separate price in our price list. We name it after the brief and fix it in the contract. A custodial build depends on the custodian’s API, a non-custodial one on the recovery method.
Not sure which model fits?
Describe your users and assets; we reply quickly with a model and a scope.