Comparison

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 us
Please notePazl develops software on the client’s assignment and does not provide digital asset services: we do not issue, hold or exchange digital assets and do not promise income. Projects that need a licence or registration (issuing digital financial assets, exchange, custody) are built for clients licensed by the National Bank of Kazakhstan or AFSA (AIFC), or for foreign markets. Unsecured digital assets are not a means of payment in Kazakhstan.What the law says →
Comparison

The two models point by point

The main difference: who can move the assets.

The two models point by pointCustodialNon-custodial
Who holds the keysThe operating company or its custodianThe user, on their own device
Lost phoneSupport restores accessThe user restores from their own backup
Operator status in KazakhstanHolding assets for clients is regulated; a licence or registration is neededJudged on how the product works; the lawyer decides
Fits bestApps of licensed companiesUsers who hold their own keys
What we buildAn app on top of a licensed custodian’s APIAn app, keys on the device, recovery
What the law says

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

Which to choose

Choose the model with your lawyer, before the first screen.

Custodial, if
  • The product is launched by a company with a licence or registration
  • Users expect support to restore access
  • A licensed custodian holds the assets
Non-custodial, if
  • 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
Breakdown

The hybrid: an embedded wallet

Easy sign-in, but the custody question remains.

Sign-in by email or passkeyThe wallet is created at sign-in; the user never sees a seed phrase.
A split keyPart of the key is with the user, part with the provider. What matters is whether the provider alone can sign a transfer.
Custodial or notIt depends on who can move the assets. We document the key setup for your lawyer.
Switching laterCustody sits in its own layer, so a mode where users hold the keys can be added later.
Step by step

How we work

Keys and recovery first, screens second.

  1. Map the keys

    Who signs, who restores and who can transfer, on one page.

  2. Choose the model with your lawyer

    Custodial, non-custodial or embedded.

  3. Prototype recovery

    The lost-phone path is tested first.

  4. Build and release

    iOS, Android or web, app store release, code with you.

Important

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

Read next

Development, design and the law.

Sources

Checked on 15 November 2026

  1. Law of the Republic of Kazakhstan No. 193-VII of 6 February 2023 "On Digital Assets in the Republic of Kazakhstan"
  2. 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.

Questions

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.

Your selectionCrypto walletPrice after the brief
The team gets your request; we reply during business hours.Price fixed in the contract before you pay.No calls unless you ask.
Request a quote
Project budget
Your request goes to the team. We reply by email, no cold calls.

Got a task? Write to us.

Describe your project on WhatsApp or by email. We reply during working hours and name the price after the brief.