Concept of regulation, insurance, telemetry and actuarial analysis of the market for rental electric personal mobility devices (ESIM) in the Republic of Kazakhstan#

Kazakh Chamber of Actuaries Almaty, 2026

Goal To create a unified infrastructure of regulation, insurance, telemetric control and actuarial analysis of the rental electric equipment market individual mobility (ESIM): to justify the risk-based principle of regulation, determine the object and classification, insurance and tariff architecture, telemetry requirements and data, the procedure for actuarial supervision and implementation stages.

Character and disclaimer. The concept is based on international experience and available statistics. There are no accumulated Kazakh statistics on losses on ESIM; therefore, conclusions about the mechanisms and direction of risk are reliable, and all quantitative guidelines (tariff corridors, limits) are indicative in nature and subject to calibration using internal data after the period of their collection (section 35). Value judgments are clearly marked.

Addressee. Financial market regulator (ARFRM; at the AIFC site - AFSA), authorized traffic authorities, local executive bodies, insurance market, industry associations and operators.

The main idea. What should be insured and regulated is not the name of the device, but the measurable the risk it creates in the urban environment.

---

Part I. Problem statement and justification

1. Objectives of the concept#

1. Transparent insurance mechanism for rental electric scooters and other ESIM.
2. Protection of victims in road accidents and other incidents.
3. Fair tariffs based on actual operation, and not just formal characteristics.
4. Objective telemetry for each trip.
5. Independent database for insurance, actuarial and regulatory analysis.
6. Improved safety for users, pedestrians, motorists and infrastructure.
7. Identification of dangerous areas, routes and behavior patterns.
8. Incentivizing operators to operate the fleet safely.
9. Elimination of the operator’s monopoly on the collection, storage and control of data without independent checks.
10. Legislative readiness for the emergence of new types of rental electric power micromobility.

2. Problem and nature of risk#

The rental market is creating a new type of massive urban risk. Its features:

• the device belongs to the operator, but it is operated by a temporary, possibly inexperienced person user;
• trips take place in a dense urban environment near pedestrians, bicycles, cars and public transport;
• incidents are caused by user behavior, technical condition of the device, infrastructure, weather or actions of third parties;
• in case of an accident, it is difficult to quickly establish the facts: where and at what speed the user was driving, whether the device is in good working order, whether the rental agreement was valid, whether the trip was legal;
• without telemetry, the insurance market cannot correctly assess the frequency and severity of losses.

Regulation by device name does not work structurally: each new form factor is three-wheeled scooter with a seat, cargo conveyor, mini-scooter with a seat - falls out of the named list, and the operator displays it without coverage, and the victim remains without compensation. This is a change of principle, not an edit of the list. Compulsory insurance “for each scooter” without telemetry and actuarial analysis provides formal insurance, but not risk management system.

The problem is not local and not a one-time problem. Urban micromobility is growing faster legislation in each market (global volume - 300–500 billion dollars by 2030, mainly China [based on McKinsey materials]); therefore EU, Singapore, Latvia, Spain, Finland and France have moved to broad risk-based categories (Section 5). Risk materializes in Kazakhstan: in 2025 - 372 accidents with electric scooters, 3 deaths, 385 victims, 29,000 prosecuted, 15,680 devices seized.

Disclaimer: the risk profile decides the coverage, but does not set the tariff level - parametric thresholds (speed, mass, acceleration, zone) determine which devices fall into the mode and the price risk is provided only by internal loss statistics.

3. Who is affected?#

• Injured third parties - without mandatory CDS, they are deprived of guaranteed compensation; It is for their sake that insurance is introduced.
• Users are the dominant group of victims: 88.7% of incidents do not involve third parties (falls, collision with a stationary object) [17], which shifts the loss to self-injury and determines product design.
• Operators - bear uninsured liability and at the same time own telemetry parka. There are at least four major players in the market (JET, Yandex Go, Whoosh, Bolt), already calling for uniform rules.
• Insurers - potential underwriters; their readiness (capacity, reinsurance, telemetry processing) is an open issue (section 35).
• Regulator and local executive bodies - licensing, access to infrastructure, geofencing.
• Kazakhstan Chamber of Actuaries is an independent SRO [1]; actuarial partner of the regulator (tariff audit, reporting, standards), but not the issuer of the norm and not the insurer.

The small number of operators (tens versus hundreds of thousands of users) makes operator-centric The administratively convenient model (section 10) is an observation, not a proven conclusion.

4. Legal starting point and legal gap#

From July 1, 2026, compulsory insurance is expected to be extended civil liability of vehicle owners for electric scooters, leased by legal entities and individual entrepreneurs; the operator is obliged conclude a compulsory civil liability insurance agreement for each rental electric scooter.

For full implementation, it is necessary to decide: what is considered the object of insurance; How take into account actual use; how to insure an idle device; what data operator transmits; who stores independent telemetry; how to calculate the tariff; How take into account new types of devices.

The current Law of the Republic of Kazakhstan “On Road Traffic” demonstrates a gap: it defines "electric scooter" and "small electric vehicle" separately, but does not introduce ESIM as a legal class [2]; everything that does not fall under these definitions is valid in regulatory vacuum.

5. International experience#

Latvia - post-Soviet precedent: electric scooters are included in the OCTA framework without a new one legislation [8]. Singapore combines operator licensing, insurance as a condition licenses and zonal speeds via telemetry [7]. EU TRL/fka offers harmonized PMD thresholds - 25 km/h, 250 kg, 2 m/s² [3]; German eKFV - 20 km/h, 500 W [6]; insurance trigger MID - over 25 km/h or 25 kg [4][5].

6. Risk statistics and actuarial data#

The risk profile is heterogeneous across device types. The likelihood and severity estimates are below - qualitative (value judgment regarding the ESIM population), not measured by Kazakhstani data.

The risk shifts along two axes: the probability falls with increasing stability (three-wheeled more stable than two-wheeled ones), the severity increases with mass and speed; tariff differentiation should take both into account. The severity is enhanced by behavior: head and face injuries - 42.1% of cases with helmets 8.4% [17]; Driving on the sidewalk doubles the risk of an accident [19]. These variables are recorded by telemetry and are suitable for tariffication.

Known (confirmed by source).

• Parametric thresholds: EU TRL/fka - 25 km/h, 250 kg, 2 m/s² [3]; German eKFV - 20 km/h, 500 W [6]; insurance trigger MID - over 25 km/h or 25 kg [4][5].
• Coverage levels: minimum MID - 6.45 / 1.3 million euros [4]; Spain - 70/15 million euros [9]; Italy - link to station. 2054 Civil Code [11].
• Actuarial benchmark: Institute of Actuaries of Australia - 135 AUST. dollars per scooter per year at ~22 injuries per 100,000 trips [15]; the only public reference point of order of magnitude.
• Frequency and severity: 15.4 injuries per million km (−29.8% for 2021–2024) [based on MMfE 2024]; severe injuries (ISS ≥ 16) - 2.8%, severe TBI - 2.3% [17].
• Single class: ETSC PIN Flash 47 unites electric scooters, segways, unicycles and self-balancing devices [18].
• Market standard: Lime/AXA operator policies (unlimited EOI, EUR 100 million UI) [14] and Bird/Allianz [16].
• Calculation base: MCI 2026 - 4,325 tenge [22]; The Code of Administrative Offenses already operates with MCI (Article 619-2; Art. 230).

Not enough (requires calculation).

• Kazakh statistics of losses on ESIM - there is none, proxy: [15] and MMfE;
• average severity of loss in Kazakhstan medical and compensation costs;
• trip-level exposures (trips, km, device-hours) from telemetry;
• frequency of losses per unit of exposure by type;
• distribution of claims for property damage.

At the start, the data quality is low (according to the logic of the IAA Product Risk Assessment [based on materials from the IAA MIWG]); a point tariff figure now would be a methodological error - a range of international proxies with subsequent calibration.

---

Part II. Object of regulation and classification

7. Determination of the object of regulation#

A narrow definition of an electric scooter (a two- or three-wheeled vehicle without a seat, for one man, with electric motor and limited speed) does not cover the future market. On it used and will appear: two- and three-wheeled electric scooters; unicycles; hoverboards; electric skateboards and platforms; seated mini-scooters; three- and four-wheel individual electrical means; small electric microcars for one person; other compact electrical equipment for rent. Regulation of “electric scooter” only will make it possible to bring to market devices comparable in risk outside of insurance, telemetry and safety requirements.

Suggested definition:

Rental electric personal mobility device (ESIM) - provided in short-term rental by a legal entity or individual entrepreneur electrical a vehicle or personal mobility device intended primarily for the movement of one person in an urban environment, having one or multiple wheels, driven by an electric motor, usable while standing or sitting, with or without steering wheel, and creating a risk of harm to life, health or property third parties.

Legislative formula - broad construction instead of narrow:

"rental electric personal mobility devices (ESIM), including electric scooters, small electric vehicles and other compact electric vehicles individual transportation provided for rent by legal entities or individual entrepreneurs",

with the authority of the authorized body to approve the list of classes, design requirements, maximum speed, routes, telemetry and insurance.

8. Classification by risk classes#

Classification is tied to measurable parameters (speed, mass, zone), and not to name (technological neutrality); device types are given as examples. Thresholds are calibrated against EU TRL/fka [3], German eKFV [6] and Singapore LTA zones [7]. Taxonomy is proposed as a leading option (value judgment).

Weight 250 kg (Class C) - ceiling PMD EU TRL/fka [3]; threshold 25 km/h (Classes A–B) – trigger MID and eKFV [4][5][6]. Class B includes devices without a classic steering wheel (increased risk falls and difficulty of control) and average seating devices. Class D requires separate admission regime, insurance, routing and technical control and when appearing on the market automatically falls under auto insurance requirements. Any device that does not fit into Classes A–C by parameters, defaults to Class D (arbitration protection); taxonomy is reviewed periodically.

---

Part III. Insurance and tariff

9. Principles of insurance#

Basic principle: the operator enters into a compulsory insurance contract for each rental ESIM, but the insurance load takes into account the actual use of the device. Hence:

• the device is registered and has valid insurance status;
• coverage is available for every active trip;
• the premium consists of a fixed and variable part; the variable depends on the number of trips, mileage, driving time and risk profile.

This eliminates the unfairness of the operator paying the same for something actively exploited. device and for idle time (warehouse, repair, non-use).

Insurance takes into account two conditions. Inactive (standing in a parking lot, warehouse, repair, disconnected from rental, not transferred to the user) - civil liability risk to third parties minimal. Active Ride (unlocked, leased, moving or ready to ride) traffic, under the control of the tenant) - creates a risk for pedestrians, cars, property and infrastructure; Full insurance coverage applies.

10. Fork - subject of insurance#

Judgment: operator-centric model is preferable - operators own telemetry, are few in number for supervision and already have insurance built in; “built-in rental” - its commercial form. The test requires an assessment of insurers' readiness (section 35).

11. Insurance tariff model#

The net premium is calculated using the standard formula frequency × severity × exposure [20]; frequency is measured per unit of exposure (travel, km, device-hours), severity - Average loss per case by type of coverage. Combined tariff.

Fixed part (for each registered object): contract administration, device registration, minimal risk, availability of coverage, costs of maintaining the system.

Variable part (based on actual use): number of trips; mileage; duration; Times of Day; city; district; route type; driving on a sidewalk, bike path or road; average and maximum speed; sudden braking; falls; collisions; violations geofencing; history of insurance claims; technical condition; device class; risk rating operator.

Increasing coefficients: high accident rate; incomplete telemetry; frequent violations speed; a lot of night trips; operation in hazardous areas; heavier/faster devices; frequent malfunctions; insufficient user control.

Reducing factors: complete and timely telemetry; low accident rate; quality service; effective geofencing; auto speed limit; fast blocking violators; transparent history of repairs; good risk rating.

Tariff levels. Basic - operators performing the minimum (registration, telemetry, insurance for each device, safety requirements). Reduced - low-level operators risk (full telemetry, low accident rate, maintenance, speed control, working geofences, low loss). Increased - high-risk operators (high accident rate, incomplete data, frequent violations, poor condition of the fleet, high loss rates).

Indicative corridor of the first stage (order of magnitude, subject to calibration based on data): large cities - 40,000–80,000 tenge per device per year; cities of lower intensity - 30,000–45,000 tenge per year; plus a variable portion for actual trips, kilometers or minutes. After statistics have been accumulated, tariffs are recalculated based on actual data; landmark order of magnitude - Australian 135 aust. dollars per scooter per year [15].

12. Levels of insurance products#

• Level 1. Mandatory SGO - liability to third parties for each device; coverage is specific to your device, carrier, and trip.
• Level 2. Voluntary user insurance - tenant injuries: accidental accident, disability, death, medical and emergency expenses. Connects automatically in as part of the rental, at the user's choice, for an additional payment, an annual subscription or microinsurance for one trip.
• Level 3. Operator liability - damage due to technical failure, improper maintenance, battery fire, improper parking, abandoned device, in a warehouse or charging station, software error, incorrect limitation speed.

For Class A, coverage for user injury is voluntary at the start; for Classes B, C, D - mandatory (higher severity profile).

13. Minimum coverage limits and indexation#

The calibration of limits is focused on the minimum MID - 6.45 million euros for harm to life and health and 1.3 million euros for property damage [4], scaled to Kazakh medical costs and compensation standards; the upper range is Spain (70/15 million euros [9]). Landmark coverage structures - operator policies Lime/AXA (unlimited EOI, 100 million euros UI [14]) and Bird/Allianz [16]; Kazakhstan's mandatory minimum is set below commercial levels, but above the compensation significance threshold.

Limits and scales are tied to the MCI (2026 - 4,325 tenge [22]) for automatic annual indexation without legislative amendments. Alternative - fixed amounts with risk lag behind inflation. Judgment: linking to MCI is preferable.

---

Part IV. Telemetry, data and infrastructure

14. Infrastructure participants#

Rental operator is a legal entity or individual entrepreneur providing ESIM for short-term rental. Responsible for: registering each device; technical serviceability; insurance coverage; user identification; collection and transmission of telemetry to an independent database; speed control and geofences; blocking faulty and dangerous devices; informing the user; fixation incidents; storing the history of repairs and inspections.

Insurance company - enters into a mandatory insurance contract for each device; coating related to device, operator, and trip. Receives data to check the current coverage, settlement, loss assessment, tariff calculation and integrity control operator.

Actuarial company / single actuarial center - independent analytical function (not operator and not the insurer). Receives anonymized data; analyzes accident rates; defines risk by city, street, operator and class; identifies the causes of incidents; calculates frequency and severity; generates risk maps and tariff coefficients; prepares proposals regulator and market.

Regulator - approves insurance requirements and the minimum content of transmitted data; controls the execution and completeness of telemetry; analyzes the market; coordinates tariff approaches; takes action against violators.

Local executive bodies (akimats, city services) - use data for infrastructure management: identifying dangerous streets and intersections and places of frequent falls; movement restrictions; reduced speed limits; bicycle path planning; regulation parking; reducing conflicts between pedestrians, cars and micromobility.

15. Telemetry of each trip#

Each trip is fully telemetered. Minimum data content: Operator ID; ID devices; Trip ID; anonymized user ID; start and end time; GPS route; duration; mileage; average and maximum speed; speed by section; stops; sudden acceleration and braking; fall or blow (if recorded); battery level; technical status; traffic zone and its type (road, bicycle path, sidewalk, pedestrian zone, park, prohibited area); fact of speeding; fact of geofence violation; end of the trip in a permitted or prohibited place; photo of completion (if applicable); fact of appeal incident.

16. Independent database#

Data is transmitted not only to the operator, but also to an independent database. Operator - interested face; With a data monopoly, the insurer, actuaries, regulators and victims depend on information he controls. Possible holders of an independent base: a single actuarial center; accredited actuarial company; infrastructural organization of the insurance market; organization under a professional association; state or quasi-state platform; independent data controller approved by the regulator. Key requirement: the operator cannot retroactively change information about trips, speeds, routes, accidents and technical condition.

The database provides: receiving data from all operators; single format; control of transmission completeness; protection against retroactive changes; storage of travel history, incidents and technical device history; access of insurers to data on insured events; actuaries' access to anonymized data; regulator access to aggregated and control information; analytics by city, region, operator and class. Storage period - at least 3 years for actuarial analysis and settlement.

17. Data standard and API#

Fork is an open international standard versus a proprietary protocol. Judgment: open standards MDS Provider API [21] (deployed in 200+ cities in 21 countries) and GBFS [23] (1,000+ services in 45+ countries), already implemented by Lime and Bird, are preferable to their own protocol; MDS Policy API [24] transmits geofencing rules (speed zones, prohibited zones driving and parking) to the parks in real time. JET (more than 75,000 devices in several countries) already has an existing telemetry infrastructure.

The data transfer API provides for: device registration; technical update status; start and end of the trip; transmission of route, speed, events, violations, accidents and repairs; confirmation of reception; completeness control; error log. Mode transmissions - close to real time or with a delay of no more than 24 hours.

Control of data completeness. The operator should not transmit only “good” trips. System controls: the number of active devices; number of trips started and completed; share of trips without route, without speed, with GPS errors, with loss of connection; inconsistency between operator data and independent base. Incomplete transfer affects the risk rating and tariff.

18. Registers of devices, trips and incidents#

Device registry is uniform for all rental E-SIMs. For each device: unique ID; serial number; QR code or other public identifier; operator; Class; model; date of entry into operation; technical specifications; maximum design speed; weight; presence of a seat, number of wheels, presence of a steering wheel; Availability of GPS and shock/fall sensors; insurance status; date of the last technical inspection; history of repairs and blockages; total mileage; number trips and incidents.

Register of trips - for each trip allows you to set: the operator; device; time start and end of the lease; route; speed; violations; incident; insurance action coatings; technical condition at the time of the trip.

Incident register - not only insured events, but all significant incidents: falls user; collision with a pedestrian, car, cyclist, or other scooter; property damage; injury to the user or third party; hitting an obstacle; fall due to the road surface; an accident due to a malfunction or improper parking; complaint citizen; calling the police; contacting the insurance company.

19. Classification of causes of incidents#

For actuarial analysis, a probable cause is recorded: user violation of rules; speeding; movement in a prohibited area; driving on the sidewalk in excess permissible speed; passenger transportation; driving while intoxicated; inattention; technical failure (brake failure, wheel failure, battery problem); bad road surface; lack of cycling infrastructure; conflict with a car or pedestrian; improper parking; weather conditions; insufficient lighting; actions of third parties; the reason has not been established.

20. Insurance module and technical architecture#

Insurance module connects the device, operator, insurance company, contract, trip, user, event, telemetry and payout. For each incident it allows you to determine: whether the device was insured; whether the contract was valid at the time of the trip; was it active rent; who was the operator and which user was controlling; place and speed; presence of a violation or malfunctions; relevance to the insured event.

System modules: unified register of devices; register of operators (parks, licenses, insurance status, risk rating); travel registry; incident register; insurance module; actuarial module (risk, loss ratio, ratios); regulatory panel (market, operators, insurance, accidents, violations); city ​​analytical panel (dangerous zones, infrastructure decisions); API for operators and insurance companies.

21. Access to data and protection of personal data#

Data is transferred to the actuarial database primarily impersonally or pseudonymised: for analysis of fairly impersonal IDs of the user, trip, device and operator, route, speed, fact of incident and risk parameters. Personal data is disclosed only in cases provided for by law: insured event; road accident; appeal of the victim; request authorized body; legal dispute; crime investigation.

Access is limited: operator - data of their devices, trips, users and incidents; insurer - data for the contract and settlement (aggregates plus records for specific insurance cases); actuarial company / Chamber - anonymized data for risk analysis, tariff calculation and annual reporting; regulator - control, aggregated and, if necessary, detailed information; akimats - city analytics, risk maps, data on infrastructure problems.

---

Part V. Safety and Operation

22. Technical safety and device testing#

Mandatory requirements for devices: working brakes, steering (if provided), wheels and battery; battery protection from fire; maximum limit speed; remote blocking; GPS module and telemetry transmission; lighting elements; sound signal (if required); unique marking; regular technical inspection; line release ban faulty device; digital repair magazine.

The operator checks the devices: before commissioning; periodically according to schedule; after user complaints; after an accident, fall or blow; after reaching a certain mileage; after a technical error; after a long period of inactivity. If the device shows signs of malfunction automatically excluded from the rental until the problem is resolved.

23. User security#

The application implements: user identification; age confirmation; familiarization with traffic rules and agreement with the rental rules; travel ban in prohibited areas; automatic speed limit, incl. reduced in pedestrian areas; warnings about violations; blocking the user for serious violations; ban on passenger transportation; prohibition of completing a trip in a prohibited place; parking control; recording complaints.

24. Geofences and speed limits#

The system supports geofencing. Types of zones: normal traffic; reduced speed; pedestrian; park; traffic ban; parking ban; mandatory parking; dangerous plot; zone of increased insurance risk. A speed limit is set for each zone: bike lane - standard speed limit; edge of the roadway - standard, taking into account law; sidewalk and pedestrian zone - reduced; park, square, embankment - special mode; dangerous intersection - reduced speed or prohibition; crowded area - prohibition or minimum speed. For Classes C and D, this functionality is a condition of the license; for Classes A and B, a best practice recommendation.

25. Operator's responsibility#

The operator is responsible for: lack of insurance; incomplete or distorted data; release faulty device; lack of technical control; violation of speed requirements; absence geofencing in mandatory areas; inadequate handling of complaints; concealment of incidents; violation of the order of data storage. Enforcement measures: warning; fine; increased tariff; temporary restriction of activities; prohibition of exploitation of part of the park; disconnection from the system; ban on rental services. Penalty scales are tied to the MCI (the Code of Administrative Offenses already uses the MCI: Art. 619-2 — 25/40 MCI; Art. 230 - from 160 to 1,000 MCI per device [22]).

---

Part VI. Actuarial analysis and supervision

26. Actuarial module and analysis#

The analysis is carried out in sections: operator; city; district; street; crossroads; zone type; class and device model; age; mileage; number of trips; Times of Day; day of the week; season; average and maximum speed; frequency of sudden braking, falls and collisions; number of insurance cases; average payout; overall loss ratio; frequency of complaints; completeness of telemetry.

Based on the results, the following are formed: tariff coefficients; risk ratings of operators, cities, districts, streets and intersections, device classes; recommendations for increasing/reducing tariffs; proposals for limiting speed, banning traffic in certain places, changing rules operation and technical requirements.

27. Risk rating of operators#

• Low risk - full telemetry, low accident rate, quick troubleshooting, speed control, geofencing, blocking violators, low loss rate → reduced rate.
• Average risk - basic requirements are met, average accident rate or imperfect control → standard tariff.
• High risk - high accident rate, incomplete data, frequent violations, poor condition fleet, high unprofitability → increased tariff.
• Unacceptable risk - systematic concealment of data, release of faulty devices, lack of insurance and telemetry, ignoring safety requirements → restrictions, fines, suspension of activities or disconnection from the system.

28. City risk map#

Based on telemetry and incidents, a risk map is formed: places of frequent falls; places collisions with pedestrians and cars; dangerous intersections and sidewalks; excess zones speed and improper parking; areas with poor coverage; places where you need cycling infrastructure, speed limit or traffic ban. Card in use insurers and akimats.

29. Actuarial methodology#

The IAA Product Risk Assessment methodology is used (risk weight and risk score scales, ten product characteristics; supplier assessment by operational area) [adapted from IAA MIWG]. Net premium—frequency × severity × exposure [20]. Minimum data set for calibrated model: exposure (travel, km, device-hours by class); frequency losses by type (user injury / third party / property); medium weight with anchor for Kazakhstani medical expenses; risk factors (class, zone, time, history operator’s unprofitability, user experience); separate modeling of long-tailed reserves (severe injuries, disability, death) against a layer of small frequent losses.

Telemetry is a prerequisite for pricing, not convenience: without trip-level data, you can’t measure exposure, verify compliance with zones, and distinguish high-risk parks. Telemetry provides exposure measurement, identification of high-risk areas and windows, verification of requirements, monitoring of operator loss (experience rating) and dynamic monitoring as new devices are released. The usage-based insurance (UBI) model is technically ready: speed, acceleration and zone profiles are sufficient for a tariff with behavioral adjustment; design the data architecture with UBI in mind from the very beginning, even when starting flat rates.

30. Actuarial supervision of the Chamber#

It is advisable to assign the Kazakhstan Chamber of Actuaries (direction not approved mandate): independent actuarial audit of tariffs on the ESIM market (against dumping - lower rates actuarial value - and excess load); annual public actuarial market report (frequency, severity, adequacy of tariffs, adequacy of reserves); actuarial standards for ESIM reserves and tariffs (2026–2027) based on the IAA methodology and international standards [1].

31. The principle of “data instead of disputes”#

The system moves from subjective disputes to objective data. In case of an incident, quickly it is established: where and at what speed the user was driving; in what zone? was it active rent; whether the device was in good working order; were there any violations; whether the policy was valid; who is responsible face; Are there any grounds for payment? This protects victims, bona fide users, operators, insurers, regulators and city services.

---

Part VII. Implementation

32. Pilot project#

Before the full launch - a pilot in several cities (Almaty, Astana, Shymkent, Karaganda and one medium-sized city) lasting 6–12 months. As part of the pilot: register operators and devices; connect telemetry transmission; launch the insurance module; collect travel and incident data; calculate the first loss ratio; build a risk map; prepare tariff proposals.

33. Implementation stages#

• Stage 1. Regulatory preparation - clarification of the definition of the object; category consolidation ESIM and risk-based taxonomy in the Law “On Road Traffic”; requirements for operators; minimal telemetry composition; requirements for an independent base; insurance model; technical standard parameters (or EAEU regulations) according to EU TRL/fka [3] and eKFV [6]; mandatory SHS for operators of Classes A–B (target – 2027).
• Stage 2. Technical preparation - device register; API; connecting operators and insurers; actuarial module; data transmission testing; pilot telemetric repository (Almaty, Astana) on MDS/GBFS [25][23][21].
• Stage 3. Pilot - launch in selected cities; collection of statistics; checking data completeness; incident analysis; primary tariff coefficients; first market actuarial report Chambers.
• Stage 4. Scaling - distribution to the entire market; connection of all operators; risk ratings; tariff coefficients and experience rating; regular actuarial revaluation; compulsory Class C insurance.
• Stage 5. Expansion to new devices - unicycles, hoverboards, sedentary mini-scooters, small four-wheeled vehicles; separate rules for Class D; repository integration with MaaS platforms; harmonization with partners in the EAEU (2028–2030).

Transitional mechanism. For the first 12–18 months of compulsory insurance, for now the commercial market lacks data on losses, a state pool with reinsurance support, absorbing early market risk before the accumulation of internal statistics.

34. What is required to solve#

Each point is an entry into a future actuarial study or proposal.

1. Data collection, 12–18 months. Exposure, frequency by type, average severity in Kazakhstan costs; for the transition period - indicative rates for international proxies [15][based on MMfE 2024] with a preliminary note.
2. Tariff modeling. Full frequency × severity × exposure model [20] at operator data (JET, Yandex Go, Whoosh, etc.) according to the IAA methodology, with reconciliation with the standard 135 aust. dollars [15]; a joint project between the Chamber, the regulator (AFSA) and operators.
3. Readiness of insurers. Underwriting capacity, reinsurance, processing telemetry; necessity and conditions of a transitional state pool.
4. Telemetry requirements (draft). Composition (GPS [21], speed, acceleration/braking, zone, identifiers, incident flag), transmission mode (≤24 hours), storage (≥3 years), levels access.
5. Actuarial standards for reserves and ESIM tariffs based on IAA methodology and standards concepts.
6. Harmonization in the EAEU. Mapping the approaches of Russia, Belarus, Kyrgyzstan and Armenia; unified technical regulations and mutual recognition of insurance. No partner has accepted yet comprehensive regulation - there is a window to set the standard.
7. UBI Perspective. Design the data architecture based on the behavior tariff, even with starting flat rates.

35. Expected effects#

• State - transparent market, control of operators, reduction of accidents, objective data for regulation.
• Insurance market - accurate rates, less uncertainty and fraud, quality settlement.
• Operators - fair tariff, opportunity to reduce premium due to security, protection from unfounded claims, clear rules.
• Citizens - protection of victims, increased security, clear compensation mechanism, reduction of chaotic movement.
• Cities - risk maps, identification of dangerous areas, data for cycling infrastructure, parking regulation, reducing conflicts.

36. Risks and limitations of the concept#

• Insufficient data at the start - no accumulated statistics on ESIM; proxy ([15], MMfE) require calibration to the Kazakh environment. The solution is a data collection period of 12–18 months, intermediate rates for international proxies.
• Tariff dumping - rates below actuarial value for the sake of market share with risk insolvency. The solution is the minimum tariff thresholds of the regulator according to the conclusion of the Chamber, reviewed annually.
• Regulatory arbitrage through misclassification - registration of a heavy device how easy it is. The solution is verification of mass and speed using telemetry, reclassification and retroactive premium adjustment.
• Classification obsolescence - new form factors outside the taxonomy. Solution - technological neutrality (everything outside Classes A–C → Class D) and taxonomy revision every two years.
• Low coverage among small operators – insurance evasion. The solution is insurance as a condition of the municipal operating permit.
• Uncertainty of distribution of responsibilities between operator and user in scenarios Road accident. The solution is to extend an analogue of Art. 2054 of the Civil Code on ESIM operators in legislative amendments.

37. Main principles of the concept#

Rental ESIM is considered not as a device rented through an application, but as a digital one insured object. Here are the general principles:

1. The object of regulation is not an electric scooter in the narrow sense, but the entire category of rental electric scooters, determined by measurable risk parameters.
2. Each object is registered and has insurance status.
3. Insurance is related to a specific device and a specific trip.
4. Insurance load takes into account actual usage.
5. An idle device carries minimal risk; during an active trip, full insurance regime.
6. All telemetry is transferred to an independent database, protected from retroactive changes.
7. Actuarial calculations are carried out on real data; low-risk operators pay less, high - more.
8. New types of micromobility are included in the regulatory system in advance so that the law does not lagged behind the market.
9. Minimum limits and fines are tied to the MCI for automatic indexing.
10. The Kazakhstan Chamber of Actuaries acts as an independent actuarial partner of the regulator.

The goal is not formal compulsory scooter insurance, but a digital infrastructure for safe urban micromobility, where insurance, telemetry, security and tariffs are linked by a single data system.

---

The concept was prepared by the Public Association “Kazakhstan Chamber of Actuaries”. All quantitative guidelines are indicative in nature and are subject to calibration based on internal data; value judgments are marked in the text.

Kazakhstan Chamber of Actuaries BIN 260540032980 Almaty, st. Begalina, 7 info@actuaries.org.kz | https://actuaries.org.kz/ [1][26]

---

Application. Glossary of terms and abbreviations#

Actuarial and insurance terms.

• Exposure (exposure) is a measure of the amount of risk: travel, mileage (km) or device-clock; frequency measurement base.
• Loss frequency—the number of insured events per unit of exposure.
• Severity of loss - the average amount of loss per case.
• Net premium is the product of frequency and severity (before loads and expenses).
• Risk profile - the combination of probability, severity and exposure that determines cost risk regardless of the device name.
• Tariff taking into account experience (experience rating) - tariff adjustment based on actual history unprofitability.
• Usage Based Insurance (UBI) - calculates premium based on travel behavior (speed, acceleration, zone) rather than from a flat rate.
• Reserves - funds for future payments; heavy (long-tailed) losses are modeled separately from small frequent ones.
• Credibility — the degree of confidence in the portfolio’s own statistics when mixing with an external standard.
• Technological neutrality - a single mode for any device with a comparable risk profile regardless of the name.
• Regulatory arbitrage - departure from a strict regime through a formally different classification.
• Tariff dumping - rates below actuarial value for the sake of market share.
• Geofencing (geofencing) - software limitation of zones and speed via GPS, observed by telemetry.
• Two-sided risk - disclosure of the consequences of both underestimation and overestimation of a value.
• Evaluative (expert) judgment - a statement that is not directly derived from the norm, data or calculation, and labeled as a judgment.

Device categories and rights.

• ESIM - electric means of personal mobility; in the concept - rental ESIMs as a single risk-oriented class (electric scooters, hoverboards, unicycles, mini-scooters with seat, three/four-wheeled electric vehicles, microcars).
• ETS is an electric vehicle.
• SGO - civil liability insurance (to third parties, in extended coverage - and in front of the user).
• GPO - civil liability.
• MCI - monthly calculation indicator (2026 - 4,325 tenge).
• Administrative Code - Code of the Republic of Kazakhstan on Administrative Offences.
• SRO is a self-regulatory (professional) organization.
• BIN — business identification number.
• EAEU - Eurasian Economic Union.
• ARRFR - Agency of the Republic of Kazakhstan for regulation and development of the financial market.
• AFSA - Astana Financial Services Authority, a regulator at the AIFC site.

International standards, methodologies and notations.

• IAA - International Actuarial Association; methodology Product Risk Assessment evaluates the product and supplier using the “risk weight” and “risk score” scales.
• MDS - Mobility Data Specification (Open Mobility Foundation): open exchange standard data; Provider API - transfer of travel data to the regulator, Policy API - transfer rules for geofencing in parks.
• GBFS - General Bikeshare Feed Specification: open public status standard devices.
• MaaS - Mobility as a Service.
• PMD - Personal Mobility Device (EU category, EU TRL/fka).
• PLEV - Personal Light Electric Vehicle (German eKFV category).
• eKFV - Elektrokleinstfahrzeuge-Verordnung, German regulation of small electrical TS.
• MID - Motor Insurance Directive, EU Motor Insurance Directive.
• OCTA - compulsory liability insurance for vehicle owners (Latvia).
• VMP Type A/B - vehículos de movilidad personal and their risk classification (Spain).
• PMA - Personal Mobility Aids (Singapore).
• EDPM — engins de déplacement personnel motorisés (France); free-floating - free rental without stations.
• MMfE - data from the Micromobility for Europe association.
• ETSC PIN Flash - report of the European Transport Safety Council.
• ISS — Injury Severity Score (ISS ≥ 16 — severe injury).
• TBI - traumatic brain injury.

---

Sources#

[1] Kazakhstan https://actuaries.org.kz/ [2] About road traffic - ILS "Adilet". https://adilet.zan.kz/rus/docs/Z1400000194 [3] XPR137_-EC-study-on-the-need-for-harmonised-rules-to-support-micro-mobility.pdf. https://www.trl.co.uk/uploads/trl/documents/XPR137_-EC-study-on-the-need-for-harmonised-rules-to-support-micro-mobility.pdf [4] ERSO-TR-PersonalMobilityDevices-20241217.pdf. https://road-safety.transport.ec.europa.eu/document/download/6ed38dab-eb7c-42e0-a4a7-06bdd20677ec_en?filename=ERSO-TR-PersonalMobilityDevices-20241217.pdf [5] Motor insurance - Finance - European Commission. https://finance.ec.europa.eu/banking/insurance/motor-insurance_en [6] Personal Light Electric Vehicles – Questions and Answers. https://www.bmv.de/SharedDocs/EN/Articles/StV/Roadtraffic/light-electric-vehicles-faq.html [7] Regulations for Personal Mobility Aids. https://www.lta.gov.sg/content/ltagov/en/getting_around/active_mobility/rules_and_public_education/rules_and_code_of_conduct/personal_mobility_aids.html [8] Latvian Transport Bureau - E-scooter Insurance. https://www.ltab.lv/en/jaunumi/no-1-julija-octa-ari-elektroskrejriteniem-kas-janem-vera-to-ipasniekiem/ [9] Spain's new obligations to insure and register personal mobility vehicles. https://www.europarl.europa.eu/doceo/document/E-10-2026-000657_EN.html [10] BOE-A-2026-2140. https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-2140 [11] Assicurazioni monopattini - MIMIT. https://www.mimit.gov.it/it/mercato-e-consumatori/tutela-del-consumatore/assicurazioni/monopattini [12] How should new electric mobility devices be insured?. https://www.lvk.fi/en/obligation-to-insure/obligation-to-insure/light-electric-mobility-devices/ [13] Trottinettes électriques et EDPM : la réglementation en vigueur. https://www.ecologie.gouv.fr/politiques-publiques/trottinettes-electriques-edpm-reglementation-vigueur [14] Lime electric scooter rental Insurance. https://cdn.li.me/content/uploads/France-Motor-Liability-and-PA-Certiifcate-Scooter_ENG.pdf [15] Actuaries Institute - Micro-mobility Risk Assessment. https://content.actuaries.asn.au/resources/resource-ce6yyqn64sx3-786882053-7014 [16] General Third Party Liability Insurance for the time of use of a Bird Unit. https://www.bird.co/wp-content/uploads/2022/03/Bird-Rides-Allianz-Rider-Liability-IPID-English.pdf [17] E-Scooter-Associated Injury Types and Injury Severity - PMC - NIH. https://pmc.ncbi.nlm.nih.gov/articles/PMC13026923/ [18] IMPROVING THE ROAD SAFETY OF E-SCOOTERS. https://horizoneuropencpportal.eu/sites/default/files/2025-01/etsc-improving-the-road-safety-of-e-scooters-2024.pdf [19] Characteristics and Risk Factors for Electric Scooter-Related. https://www.mdpi.com/1660-4601/19/16/10129 [20] Chapter 7 Premium Foundations | Loss Data Analytics. https://openacttexts.github.io/Loss-Data-Analytics/ChapPremiumFoundations.html [21] mobility-data-specification/provider/README.md. https://github.com/openmobilityfoundation/mobility-data-specification/blob/main/provider/README.md [22] MCI for 2026 - PRG. https://prg.kz/document/?doc_id=1026672 [23] General Bikeshare Feed Specification: Home. https://gbfs.org/ [24] mobility-data-specification/policy/README.md. https://github.com/openmobilityfoundation/mobility-data-specification/blob/main/policy/README.md [25] About MDS - Open Mobility Foundation. https://www.openmobilityfoundation.org/about-mds/ [26] Society of Actuaries of Kazakhstan. https://actuary.kz/