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Proposals to amend the insurance legislation of Kazakhstan

Proposals for introducing changes and additions to the insurance legislation of the Republic of Kazakhstan#

Specific legislative initiatives and draft regulations in four areas: access of the association of actuaries to UST data (block 1), simplification of insurance reporting organizations (block 2), institute of an independent actuary and independent verification of reserves (block 3), professional development program for actuaries (block 4). Every sentence contains the proposed rule, rationale, and draft language.

Abbreviations used#

  • Law - Law of the Republic of Kazakhstan “On Insurance Activities” dated December 18, 2000 No. 126-II;
  • authorized body - Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market (ARFRDF);
  • association of actuaries - a self-regulatory organization of actuaries (subparagraph 1-3) of Article 3, Article 10-3 of the Law);
  • USBD, database - a unified insurance database (Article 80 of the Law);
  • organization - organization for the formation and maintenance of a database (Article 79 of the Law);
  • Resolution No. 191 - Resolution of the Board of the National Bank of the Republic of Kazakhstan dated August 27, 2018 No. 191 (Requirements for confirming the qualifications of an actuary - Appendix 4; Rules and terms for attracting an independent actuary - Appendix 5);
  • Resolution No. 177 - Resolution of the Board of the AFN of the Republic of Kazakhstan dated June 25, 2007 No. 177 “Requirements for an organization for the formation and maintenance of a database”;
  • Resolution No. 86 - Resolution of the Board of the National Bank of the Republic of Kazakhstan dated December 2, 2025 No. 86 (Rules for the submission of reports by an insurance (reinsurance) organization);
  • Resolution No. 84 - Resolution of the ARRFR Board dated December 26, 2025 No. 84 (Requirements for the assessment and structure of insurance liabilities in accordance with IFRS);
  • PPR is a professional development program for actuaries.

Offer table#

Number Norma Rationale Draft wording
1.1 Include the association of actuaries in the list of recipients of information from the Unified Database Database with the right to receive complete, maximally detailed anonymized information upon request. A new type of insurance report is being introduced - “an impersonal statistical insurance report.”
Amended norms: clauses 2, 4 and 5 of Article 80 of the Law.		 The database is formed from information transmitted by insurance organizations (subparagraph 1) of paragraph 3 of Article 80 of the Law) and is maintained at the expense of payments from market participants for its services (Resolution No. 177 provides for payment for services for the provision of information) - that is, the UIDS was created by the market and is financed by it. At the same time, the association of actuaries, which is directly entrusted by the Law with conducting actuarial research and updating survival rates under annuity insurance contracts (subparagraphs 1) and 2) of paragraph 3 of Article 10-3), is not included in the list of recipients (paragraph 4 of Article 80) and lacks data, without which the performance of these functions is impossible. The consolidated insurance report (subparagraph 3) of paragraph 2 of Article 80) contains only aggregates and is unsuitable for actuarial tasks: constructing tables of mortality, morbidity, disability, loss development triangles, assessing the frequency and severity of losses, tariff guidelines. Access will allow the association to form an actuarial repository of insurance market data and public industry statistics in the interests of the market and the regulator.
International experience: industry actuarial studies on insurer microdata are conducted by professional associations - CMI (Continuous Mortality Investigation) of the Institute and Faculty of Actuaries (IFoA, UK), experience studies of the Society of Actuaries (SOA, USA; industry tables are recognized by NAIC), tables DAV (Germany); In the USA, statistical data from insurers is centrally collected by licensed statistical agents.		 1. Paragraph 2 of Article 80 of the Law shall be supplemented with subparagraph 4):
“4) an impersonal statistical insurance report - an insurance report containing detailed information about insurance (reinsurance) contracts, insurance premiums, objects of insurance, insured events, stated claims and insurance payments in the context of individual contracts and insured events, presented in an impersonal form, excluding the possibility of identifying the subjects of the database.”
2. Part one of paragraph 4 of Article 80 of the Law is supplemented with subparagraph 3-3):
“3-3) association of actuaries;.”
3. Paragraph 5 of Article 80 of the Law shall be supplemented with subparagraph 5-1):
“5-1) the recipient of the insurance report specified in subparagraph 3-3) of part one of paragraph 4 of this article has the right to receive impersonal statistical insurance reports and consolidated insurance reports on all subjects of the database upon request free of charge for the purpose of conducting actuarial research, updating survival rates, generating industry actuarial statistics and statistical tables (mortality, morbidity, disability, accident rate), loss analysis and development of professional standards for actuarial activities;.”
1.2 Establish the procedure, timing and format for the organization to provide an impersonal statistical insurance report to the association of actuaries.
Amended norm: Resolution No. 177 (new clause 15-1).		 The norm of Article 80 of the Law (sentence 1.1) requires subordinate implementation: composition of information, machine-readable format, deadlines, free of charge. Anonymized data does not allow identification of the subject and does not constitute an insurance secret; their processing complies with the Law of the Republic of Kazakhstan “On Personal Data and Their Protection”. Maximum detail (the level of an individual contract and an individual insured event) is a necessary condition for the applicability of data for actuarial calculations: aggregated data does not allow the construction of loss distributions and development tables. Resolution No. 177 is supplemented with clause 15-1:
“15-1. The organization provides the association of actuaries, upon request, with an anonymized statistical insurance report in an electronic machine-readable format no later than 10 (ten) working days from the date of receipt of the request. The composition of the information is determined by a request within the list of information contained in the database, with the maximum available detail - in the context of individual insurance (reinsurance) contracts and individual insured events, excluding information that allows identifying the subjects of the database. There is no fee for providing an anonymized statistical insurance report. The Association of Actuaries uses the information received exclusively for the purposes provided for in subparagraph 5-1) of paragraph 5 of Article 80 of the Law on Insurance Activities, and does not transfer it to third parties in detailed form.”
2.1 Enshrine in the Law the principle of reporting in the form of primary (basic) data: the regulator generates derivative indicators, groupings and calculation forms independently from primary data and the Unified Database Data System, without requiring them from insurers.
Amended norm: paragraph 2 of Article 74 of the Law.		 A significant part of the forms of Resolution No. 86 is derived from the primary journals: loss development triangles (Appendices 31–33 - calculation of the reserve for occurred but unreported losses using the chain ladder and Bornhütter-Ferguson methods) are constructed directly from the insurance payments journal; coefficients (Appendices 11, 37), aggregates and groupings (Appendices 25, 29, 38, 39) are derived arithmetically from the same primary data. Resubmitting derived forms increases the regulatory burden, creates the risk of discrepancies between the derived forms and the primary data, and does not provide new information. The regulator can receive most of these indicators from the Unified Database Database, the recipient of all types of reports of which it is (subparagraph 1) of paragraph 4 of Article 80 of the Law), or calculate it independently.
International experience: principle of “collect once, use many” - the Bank of England Transforming Data Collection program (rejection of template derived forms in favor of granular data), collection of detailed EIOPA data within the framework of Solvency II, statistical agents NAIC system (USA).		 Paragraph 2 of Article 74 of the Law should be supplemented with part two:
“The list of forms of financial and other reporting does not include forms, all indicators of which can be obtained by calculation from primary data contained in other forms of reporting presented by an insurance (reinsurance) organization, or in a unified insurance database. Derived indicators (aggregated, grouped and calculated values) are formed by the National Bank of the Republic of Kazakhstan and the authorized body independently on the basis of primary data.”
2.2 Exclude derivative reporting forms from Resolution No. 86, preserving the primary journals (bonuses, payments, losses, existing contracts).
Changeable norms: paragraphs 8–10 of Resolution No. 86; appendices 11, 25, 29, 31–33, 37–39.		 The forms to be excluded duplicate the primary data: Appendix 11 (combined ratio) and Appendix 37 (loss ratio) - arithmetic ratios of indicators of forms on bonuses, payments and expenses; Appendix 25 (statistics of insurance payments) - aggregate of the payment log; Appendix 29 (contracts for the last 12 months) - a selection from the journals of existing contracts (Appendices 23, 26–28); appendices 31–33 (calculation of the reserve for undeclared losses by three methods, including development triangles) are derivatives of the payment log, while the calculation tables themselves are already formed by the actuary according to appendices 1–4 to Resolution No. 84 and are attached to the mandatory actuarial report (clause 3 of the Requirements approved by Resolution No. 191) - that is, they are submitted to the regulator twice; Appendices 38–39 (classification of bonuses and payments by type of economic activity and region) - groupings formed from the information of the Unified Database Database. Primary forms (including appendices 5–8, 10, 23, 24, 26–28, 30) are preserved. In Resolution No. 86:
1) in the list of reports (clause 8) and in clauses 9–10, exclude lines and references related to appendices 11, 25, 29, 31, 32, 33, 37, 38, 39;
2) appendices 11, 25, 29, 31, 32, 33, 37, 38, 39 shall be declared invalid;
3) add clause 8-1:
“8-1. Information contained in the unified insurance database, as well as indicators that can be obtained by calculation from the primary data of the submitted reporting forms, are not subject to inclusion in reporting forms and re-request from organizations.”
3.1 Rethink the concept of an independent actuary: an independent actuary does not have the right to be on the staff of any insurance (reinsurance) organization; mutual (including chain - “in a circle”) verification by actuaries of each other is excluded.
Changed norms: subparagraph 29) of Article 3, part three of paragraph 4 and paragraph 6 of Article 11-1 of the Law; paragraph 6 of the Rules (Appendix 5 to Resolution No. 191).		 The current design allows for a systemic conflict of interest: part three of paragraph 4 of Article 11-1 of the Law directly allows a full-time actuary of one insurance organization to act as an independent actuary in another; the ban on mutual verification is limited to one calendar year (subclause 2) of clause 6 of the Rules) and does not cover chains of three or more participants (“A checks B, B checks C, C checks A”). In practice, actuaries of insurance organizations check each other on a mutual basis - a circular dependence arises, in which no check is independent. The requirement for membership in the association of actuaries (subparagraph 2) of paragraph 6 of Article 11-1) already creates a mechanism for disciplinary oversight of independent actuaries; the proposed rule creates an institution of practicing independent actuaries outside the insurer's staff.
International experience: Canada - external review of the appointed actuary's work is carried out by a qualified actuary independent of the insurer (OSFI Guideline E-15 “Appointed Actuary: Legal Requirements, Qualifications and External Review”); UK – standard for independent review of actuarial work IFoA APS X2 “Review of Actuarial Work”; IAIS Control Independence Principles (ICP 8); in auditing practice, similar risks are eliminated by prohibiting cross-control and rotation.		 1. Subparagraph 29) of Article 3 of the Law shall be amended as follows:
“29) an independent actuary is an individual who meets the requirements of this Law, who is not in an employment relationship with any insurance (reinsurance) organization, including a branch of an insurance (reinsurance) organization - a non-resident of the Republic of Kazakhstan, and who is engaged to conduct an independent assessment of the actuary’s calculations.”
2. In part three of paragraph 4 of Article 11-1 of the Law, the words “except for cases of engagement as an independent actuary” should be deleted.
3. Subparagraph 1) of paragraph 6 of Article 11-1 of the Law should be stated as follows:
“1) not be in an employment relationship with any insurance (reinsurance) organization and not be in an employment relationship with the insurance (reinsurance) organization being inspected during the last 2 (two) years preceding the assessment;.”
4. Subparagraph 2) of paragraph 6 of the Rules (Appendix 5 to Resolution No. 191) should be stated as follows:
“2) in relation to actuarial calculations of an independent actuary or actuarial calculations performed under his leadership, an assessment was carried out by a full-time actuary of the audited insurance (reinsurance) organization, directly or through a sequence of assessments with the participation of other actuaries, within 3 (three) calendar years preceding the end date of the assessment;".
3.2 Establish a mandatory scope of independent actuarial review: full independent recalculation of reserves and liabilities, recalculation of valuation components according to IFRS 17, retrospective analysis of the development of reserves (run-off analysis), data quality check; supplement the content of the actuarial report of an independent actuary with the results of these procedures.
Amended norms: Rules (Appendix 5 to Resolution No. 191) - new paragraphs 8-1, 8-2; forms of appendices 2 and 2-1 to the Rules.		 The current Rules only require attaching “calculations made by an independent actuary” (clause 9), without defining the depth of the check: in practice, the assessment can be reduced to confirming the methodology of the in-house actuary without reproducing the calculations, which depreciates the annual mandatory assessment (clause 4 of the Rules).
International experience: (a) Solvency II - the actuarial function is required to compare the best estimates with actual experience (back-testing): Article 48(1) Directive 2009/138/EC, Article 272 Delegated Regulation (EU) 2015/35; (b) IFRS 17 - paragraph 130 requires disclosure of the development of losses: actual losses compared to previous estimates (claims development), paragraphs 104–105 - disclosure of reconciliations of movement of liabilities and experience adjustments; (c) USA - annual statement of the appointed actuary on reserves (NAIC Statement of Actuarial Opinion), ASOP 36 (opinions on loss reserves), ASOP 43 (estimates of outstanding claims), ASOP 23 (data quality) standards, including retrospective tests of previous estimates; (d) Canada - External Detailed Review of Designated Actuary's Data, Assumptions and Methods (OSFI E-15); (e) Lloyd's (UK) - annual independent actuarial opinion (Statement of Actuarial Opinion) on technical reserves of syndicates; (f) MAA - ISAP 1 (general actuarial practice). Run-off analysis is a standard tool for identifying systematic understatement of reserves: comparison of actual development with reserves formed as of past dates makes the understatement observable.		 The rules (Appendix 5 to Resolution No. 191) are supplemented with paragraphs 8-1 and 8-2:
“8-1. A mandatory assessment of actuarial calculations by a full-time actuary includes:
1) a complete independent recalculation of insurance reserves and insurance liabilities for all classes of insurance and groups of contracts based on the primary data of the insurance (reinsurance) company, including independent verification of the completeness and quality of the data by reconciling the journals of contracts, losses and payments with accounting data;
2) when assessing insurance liabilities in accordance with IFRS 17: recalculation of estimates of future cash flows (best estimate); checking the validity of discount rate curves; recalculation of the risk adjustment for non-financial risk with disclosure of the applied level of confidence; checking the movement of margin for services provided for in the contract and the loss component for onerous groups of contracts; checking the legality of applying the method based on the distribution of the premium; assessment of the reinsurer's share in insurance liabilities;
3) retrospective analysis of the development of reserves (run-off analysis): comparison of actual insurance payments and current estimates of liabilities with reserves formed as of previous reporting dates for at least 5 (five) previous years or for the entire available period of the organization's activities, broken down by insurance classes, with an analysis of the sources of deviations (experience, changes in assumptions, changes in methodology) and loss development tables;
4) conclusions on sufficiency insurance reserves and insurance liabilities, about significant discrepancies with the calculations of the staff actuary and recommended adjustments.
The results of the procedures provided for in this paragraph are included in the actuarial opinions of the independent actuary.
8-2. If a significant understatement of insurance reserves or insurance liabilities is detected, the independent actuary informs the authorized body within 5 (five) business days from the date of detection.”;
forms of appendices 2 and 2-1 to the Rules should be supplemented with sections “Results of independent recalculation”, “Results of a retrospective analysis of the development of reserves (run-off analysis)” and “Comparison with the calculations of a staff actuary”.
4.1 Transfer to the association of actuaries a record of the actuaries completing the PPR and confirmation (credit) of the activities completed; introduce an open register of passing the PPR on the association’s Internet resource.
Changeable norms: paragraph 3 of Article 10-3 of the Law; clause 5 of the Requirements for confirming the qualifications of an actuary (Appendix 4 to Resolution No. 191).		 Confirmation of qualifications every three years is established by paragraph 4 of Article 40 of the Law, however, today the authorized body (clause 5 of the Requirements) records information about completion of the PPR, which is an administrative function unusual for the supervisory body and excludes the professional community from managing its own development system. The Association of Actuaries already maintains a public list of members on its Internet resource (clause 2 of Article 10-3 of the Law) - the PPR register is its natural extension. The openness of the register ensures transparency: insurance organizations, auditors and the regulator see the current status of the professional development of each actuary.
International experience: in all leading jurisdictions, CPD accounting and control is carried out by professional associations (IFoA - UK, SOA and CAS - USA, CIA - Canada, Actuaries Institute - Australia), and the regulator supervises the system as a whole; The status of members is published in open registers (directories) of associations.		 1. Paragraph 3 of Article 10-3 of the Law shall be supplemented with subparagraphs 3-1) and 3-2):
“3-1) maintaining records of the completion of professional development programs by actuaries and confirmation (credit) of completed activities;
3-2) maintaining an open register of completion of professional development programs by actuaries and its placement on the Internet resource of the association of actuaries;.”
2. Clause 5 of the Requirements (Appendix 4 to Resolution No. 191) should be stated as follows:
“5. Information on the completion of the PPR program activities, accompanied by supporting documents, is submitted by a licensed actuary to the association of actuaries. The Association of Actuaries checks and confirms (counts) the declared activities, maintains an open register of completion of professional development programs, posted on its Internet resource, and no later than March 1 of the year following the reporting period, sends to the authorized body summary information on the fulfillment of the requirements of the PPR program by licensed actuaries.”
4.2 Directions (thematic areas) of the PPR are approved by the association of actuaries in accordance with the strategy for the development of the actuarial profession.
Changeable norms: paragraph 3 of Article 10-3 of the Law; paragraph 3 of the Requirements (Appendix 4 to Resolution No. 191).		 The list of PPR activities (Appendix 1 to the Requirements) is static and does not reflect the current priorities for the development of the profession (IFRS 17, solvency, modeling, data analysis, new risks). Professional priorities are determined more quickly and accurately by the professional community itself: in international practice, thematic priorities of CPD are set by associations (IFoA, SOA) based on program documents for the development of the profession. The development strategy for the actuarial profession is a program document of the association that ensures the systematic development of competencies in the market. 1. Paragraph 3 of Article 10-3 of the Law shall be supplemented with subparagraph 3-3):
“3-3) approval of directions (thematic areas) of professional development programs for actuaries in accordance with the strategy for the development of the actuarial profession;.”
2. Paragraph 3 of the Requirements (Appendix 4 to Resolution No. 191) should be supplemented with part two:
“The directions (thematic areas) of the activities of the PPR program are annually approved by the association of actuaries in accordance with the strategy for the development of the actuarial profession and are published on the Internet resource of the association of actuaries.”
4.3 Reform the PPR accounting system: transition from points to professional development hours, annual minimum, mandatory categories (including ethics and professional standards), limits for certain types of activities, PPR journal.
Changed standards: clauses 3 and 4 of the Requirements and Appendix 1 to the Requirements (Appendix 4 to Resolution No. 191).		 The current point system (1200 points for 3 years) allows for the formal fulfillment of the standard in one event and does not reflect real continuous development: passing one international exam gives 1200 points (the entire standard), teaching - 800 points per semester (including for re-reading a basic course that does not provide new knowledge), participation in the congress - 800; there is no annual minimum - activity can be concentrated in a short period and not develop for almost three years; there is no mandatory component on ethics and professional standards; categories of the type “contribution to development” are subjective (detailed analysis is in the document “CPD Requirements for Actuaries”, docs/Law).
International experience: leading associations (IFoA, SOA, CAS, CIA, Actuaries Institute) take into account CPD in hours with annual minimums; in the USA, UK, Canada and Australia, professionalism and ethics are a mandatory part of CPD; international exams are counted, but do not cover the entire standard; Limits apply for teaching and self-study. The clock system is transparent (1 hour of activity = 1 hour of PPR), reflects actual development costs and is easy to administer.		 Clauses 3 and 4 of the Requirements (Appendix 4 to Resolution No. 191) and Appendix 1 to the Requirements should be worded as follows:
“1. The completion of the CPD program is recorded in hours of professional development: 1 (one) academic hour of participation in the event is equal to 1 (one) hour of CPD; For teaching and public speaking, a preparation ratio of 2:1 is applied (2 hours of training for 1 hour of speaking).
2. To confirm qualifications, a licensed actuary accumulates at least 90 (ninety) hours of PPR during the reporting period, including at least 20 (twenty) hours in each year of the reporting period.
3. The standard for the reporting period includes: at least 45 (forty-five) hours - technical skills (actuarial methods, liability assessment and IFRS 17, pricing, solvency and risk management, modeling and data analysis); at least six (6) hours - professionalism, ethics, standards of actuarial practice and legislation; at least 10 (ten) hours - business skills and communications; the remaining hours are at the choice of the actuary from the recognized types of activities.
4. Activity Limits: Teaching, speaking and publishing - no more than fifteen (15) hours in the aggregate per year, hours accrued for developing and teaching new or advanced courses and not for re-teaching courses in the minimum required actuarial training program; structured self-study - no more than 10 (ten) hours per year; successful completion of the International Actuarial Association exam - forty (40) hours in the technical skills category.
5. A licensed actuary maintains a PPR journal, in which for each activity the acquired knowledge and its applicability in professional activities are indicated; the journal and supporting documents are submitted to the association of actuaries, which carries out selective verification of the declared activities.”

For reference: sources of international practice#

  • Solvency II: Directive 2009/138/EC, Article 48 (actuarial function, comparison of best estimates with experience); Delegated Regulation (EU) 2015/35, Article 272.
  • IFRS 17 “Insurance Contracts”: paragraph 130 (disclosure of loss development - actual losses versus previous estimates), paragraphs 104–105 (reconciliations of movement of liabilities, adjustments based on experience).
  • Canada: OSFI Guideline E-15 “Appointed Actuary: Legal Requirements, Qualifications and External Review”; External peer review of the work of the appointed actuary (CIA).
  • USA: NAIC Statement of Actuarial Opinion (appointed actuary); ASOP 23 (Data Quality), ASOP 36 (Opinions on P&C Claims Reserves), ASOP 43 (Outstanding Claims Estimates) - See the ASOP Library in ASOP/ASB/.
  • Great Britain: Lloyd's Statement of Actuarial Opinion (annual actuarial opinion on technical reserves); IFoA APS X2 “Review of Actuarial Work”; CMI (industry mortality tables based on insurer data).
  • IAA: ISAP 1 “General Actuarial Practice”.
  • Data collection by regulators: Bank of England “Transforming Data Collection”; granular reporting EIOPA (Solvency II); statistical agents NAIC.
  • CPD: requirements of IFoA, SOA, CAS, CIA, Actuaries Institute; detailed model for Kazakhstan - “CPD Requirements for Actuaries” (PDF in docs/Law/).