Asia. National jurisdiction.

Kazakhstan KZ

Part I

Domestic law

Comprehensive data protection1

  • PD LawLaw of the Republic of Kazakhstan No. 94-V 'On Personal Data and Their Protection'Kazakhstan's core personal data law governing consent-based collection and processing, data subject rights and security duties of owners and operators. It requires personal data of Kazakh data subjects to be stored in databases in Kazakhstan and controls onward cross-border transfers.
    Synopsis

    Kazakhstan's core personal data law governing consent-based collection and processing, data subject rights and security duties of owners and operators. It requires personal data of Kazakh data subjects to be stored in databases in Kazakhstan and controls onward cross-border transfers.

    Key themes
    • consent
    • localisation
    • cross-border transfers
    • breach notification
    • responsible person
    • automated decisions
    • registers
    Unique features

    Strict localisation of databases plus one-working-day breach reporting; 2026 amendments ban solely automated decisions and state that self-publication is not consent to further processing.

    SaaS relevance

    Foreign SaaS collecting Kazakh users' data must keep a primary database in Kazakhstan (cross-border copies allowed under art 16) and appoint a responsible person.

    Extraterritorial
    Limited
    Breach notification
    Authority within 1 working day; data subject notified via e-gov channels
    DPO
    Yes
    Cross-border transfers
    Localisation of databases in Kazakhstan (art 12(2)); transfer to adequate states or on consent/treaty/statutory grounds (art 16); no official adequacy list
    Maximum penalty
    Administrative up to 2,000 MCI (~KZT 8.65m in 2026) for large business; criminal (Criminal Code art 147) up to 3,000 MCI or 2 years' restriction/deprivation of liberty
    Key dates
    • Adopted
    • In force
    • Localisation (art 12(2)) since 2016; 2026 amendments: identifier-based definition of personal data from 2026-07-11; new definitions (anonymisation, masking, hashing, breach) and public-source data rules plus state breach register from 2026-08-25; small/medium/large controller classes, with only large ones notifying start/end of processing.
    Text
    Authority
    Ministry of Artificial Intelligence and Digital Development (Committee for Information Security)
    Verification

    Medium confidence.

    Partly verifiedMedium confidence. In-force date (2013-11-25) from general knowledge; adilet page needed JS. Regulator renamed with ministry restructuring in 2025.

    Record
    Full record for PD Law
    Partly verifiedMedium confidence. In-force date (2013-11-25) from general knowledge; adilet page needed JS. Regulator renamed with ministry restructuring in 2025.

AI / automated decisions1

  • AI LawLaw of the Republic of Kazakhstan No. 230-VIII 'On Artificial Intelligence'Risk-based AI framework requiring owners to classify systems as minimum, medium or high risk, manage risk over the lifecycle and keep documentation. It bans manipulative techniques, social scoring, non-consensual emotion recognition and discriminatory biometric categorisation, and requires labelling of synthetic content and disclosure of AI interactions.
    Synopsis

    Risk-based AI framework requiring owners to classify systems as minimum, medium or high risk, manage risk over the lifecycle and keep documentation. It bans manipulative techniques, social scoring, non-consensual emotion recognition and discriminatory biometric categorisation, and requires labelling of synthetic content and disclosure of AI interactions.

    Key themes
    • risk classification
    • prohibited practices
    • transparency
    • deepfake labelling
    • user rights over AI decisions
    • copyright and TDM opt-out
    Unique features

    One of the first comprehensive AI statutes in Central Asia; machine-readable opt-out for training on copyrighted works.

    SaaS relevance

    SaaS offering AI features to Kazakh users must label synthetic outputs, disclose AI interaction and honour users' rights to explanations and correction.

    Breach notification
    None
    DPO
    No
    Cross-border transfers
    None specific
    Maximum penalty
    Administrative fines in MCI units (amounts not confirmed)
    Key dates
    • Adopted
    • In force
    • Signed 2025-11-17; in force 2026-01-18 with accompanying Administrative Offences Code amendments.
    Text
    Authority
    Ministry of Artificial Intelligence and Digital Development
    Verification

    Medium confidence.

    Partly verifiedMedium confidence. Official adilet text URL not captured.

    Record
    Full record for AI Law
    Partly verifiedMedium confidence. Official adilet text URL not captured.
Part II

Regional & international frameworks

Membership-based — check ratification status in the instrument record. 5 instruments from 1 bodies.

United Nations

  • UN Cybercrime ConventionUnited Nations Convention against Cybercrime; Strengthening International Cooperation for Combating Certain Crimes Committed by Means of Information and Communications Technology Systems and for the Sharing of Evidence in Electronic Form of Serious CrimesThe first global UN treaty on cybercrime. It requires states to criminalise a set of computer-related offences and to provide procedural powers, such as preserving and producing stored data and collecting traffic and content data, and it sets up channels for cross-border e-evidence cooperation on serious crimes. It includes a general human rights clause and conditions and safeguards on these powers.
    Synopsis

    The first global UN treaty on cybercrime. It requires states to criminalise a set of computer-related offences and to provide procedural powers, such as preserving and producing stored data and collecting traffic and content data, and it sets up channels for cross-border e-evidence cooperation on serious crimes. It includes a general human rights clause and conditions and safeguards on these powers.

    Key themes
    • cybercrime offences
    • e-evidence
    • production orders
    • data preservation
    • mutual legal assistance
    • human rights safeguards
    Unique features

    It is broader than the Budapest Convention in that evidence sharing covers any 'serious crime'. Rights groups and industry have criticised its safeguards as weak.

    SaaS relevance

    Once in force and implemented, it could widen the range of states able to issue preservation and production orders to cloud and SaaS providers.

    Extraterritorial
    Limited
    Breach notification
    None
    DPO
    No
    Cross-border transfers
    Cooperation channels for electronic evidence
    Maximum penalty
    Set by national law
    Key dates
    • Adopted
    • Adopted by the UN General Assembly in December 2024; opened for signature in Hanoi on 2025-10-25; enters into force 90 days after the 40th ratification. About 3 ratifications (Qatar, Azerbaijan, Viet Nam) as of mid-2026.
    Text
    Authority
    UNODC (secretariat); Conference of the States Parties once in force
    Sources consulted
    Verification

    Medium confidence.

    Partly verifiedMedium confidence. The ratification count comes from secondary sources as of mid-2026. The convention is not in force (it needs 40 ratifications). The exact GA adoption date (24 Dec 2024, A/RES/79/243) comes from established references and I did not re-verify it.

    Record
    Full record for UN Cybercrime Convention
    Partly verifiedMedium confidence. The ratification count comes from secondary sources as of mid-2026. The convention is not in force (it needs 40 ratifications). The exact GA adoption date (24 Dec 2024, A/RES/79/243) comes from established references and I did not re-verify it.
  • Right to privacy in the digital ageUN General Assembly resolutions on the right to privacy in the digital age (series)This is a recurring series of non-binding General Assembly resolutions. They confirm that people have the same privacy rights online as offline, and they ask states to review surveillance, interception and bulk data collection against international human rights law. Later resolutions also cover AI, biometrics, encryption and data brokers.
    Synopsis

    This is a recurring series of non-binding General Assembly resolutions. They confirm that people have the same privacy rights online as offline, and they ask states to review surveillance, interception and bulk data collection against international human rights law. Later resolutions also cover AI, biometrics, encryption and data brokers.

    Key themes
    • surveillance
    • interception
    • AI and privacy
    • encryption
    • business responsibility
    • remedies
    Unique features

    The series grew out of the 2013 Snowden revelations. It led to OHCHR reports and, through the Human Rights Council, to the Special Rapporteur on privacy.

    SaaS relevance

    These are soft-law expectations on business respect for privacy (UN Guiding Principles), which are relevant to transparency reporting and to how a provider handles government data requests.

    Breach notification
    None
    DPO
    No
    Cross-border transfers
    None
    Maximum penalty
    None
    Key dates
    • Adopted
    • In force
    • First resolution A/RES/68/167 (2013-12-18); renewed roughly every two years; latest verified A/RES/79/175 adopted 2024-12-17
    Text
    Authority
    Office of the UN High Commissioner for Human Rights (OHCHR) reports; UN Special Rapporteur on the right to privacy
    Sources consulted
    Verification

    Medium confidence.

    Partly verifiedMedium confidence. Treated as one row for the whole series. I did not check whether a newer resolution was adopted at the 80th session in late 2025.

    Record
    Full record for Right to privacy in the digital age
    Partly verifiedMedium confidence. Treated as one row for the whole series. I did not check whether a newer resolution was adopted at the 80th session in late 2025.
  • ICCPR Art 17International Covenant on Civil and Political Rights, Article 17This is a binding treaty. Article 17 bans arbitrary or unlawful interference with privacy, family, home or correspondence, and requires states parties to protect people from such interference by law. The Human Rights Committee monitors compliance through state reports and, for states that accept it, individual complaints.
    Synopsis

    This is a binding treaty. Article 17 bans arbitrary or unlawful interference with privacy, family, home or correspondence, and requires states parties to protect people from such interference by law. The Human Rights Committee monitors compliance through state reports and, for states that accept it, individual complaints.

    Key themes
    • right to privacy
    • state obligations
    • legality
    • arbitrariness
    • individual communications
    Unique features

    It is the main binding global privacy guarantee and has about 170+ parties. General Comment 16 reads it as covering the gathering and holding of personal information, including by private bodies.

    SaaS relevance

    It binds states, not companies, but it shapes national privacy laws and the rules on government access to the data SaaS providers hold.

    Breach notification
    None
    DPO
    No
    Cross-border transfers
    None
    Maximum penalty
    None (treaty-body views; no fines)
    Key dates
    • Adopted
    • In force
    • Adopted by GA resolution 2200A (XXI) on 1966-12-16; in force 1976-03-23. Human Rights Committee General Comment No. 16 on Article 17 was issued in 1988.
    Text
    Authority
    UN Human Rights Committee (treaty body)
    Sources consulted
    Verification

    High confidence.

    The party count is approximate and was not re-checked against the UN Treaty Collection.

    Record
    Full record for ICCPR Art 17
  • UDHR Art 12Universal Declaration of Human Rights, Article 12Article 12 says no one may be subjected to arbitrary interference with their privacy, family, home or correspondence, and that everyone is entitled to legal protection against such interference. It is a declaration rather than a treaty, but it is the starting point for privacy as an international human right.
    Synopsis

    Article 12 says no one may be subjected to arbitrary interference with their privacy, family, home or correspondence, and that everyone is entitled to legal protection against such interference. It is a declaration rather than a treaty, but it is the starting point for privacy as an international human right.

    Key themes
    • right to privacy
    • correspondence
    • reputation
    • protection of the law
    Unique features

    Not legally binding in itself, though many of its provisions are treated as customary international law. Every later privacy instrument, from the ECHR to the ICCPR, builds on this text.

    SaaS relevance

    Gives no direct obligations to a SaaS business; it is useful as the human rights background for policies and DPIAs.

    Breach notification
    None
    DPO
    No
    Cross-border transfers
    None
    Maximum penalty
    None
    Key dates
    • Adopted
    • In force
    • Proclaimed by the UN General Assembly in Paris on 10 December 1948
    Text
    Authority
    None designated
    Sources consulted
    Verification

    High confidence.

    The CIPP/E project holds a copy (1948UDHR.pdf).

    Record
    Full record for UDHR Art 12
  • UN Guidelines 1990Guidelines for the Regulation of Computerized Personal Data FilesNon-binding guidelines from the General Assembly that set minimum guarantees for national laws on computerised personal data files, covering both public and private files. They list principles such as lawfulness and fairness, accuracy, purpose specification, interested-person access, non-discrimination, security and independent supervision.
    Synopsis

    Non-binding guidelines from the General Assembly that set minimum guarantees for national laws on computerised personal data files, covering both public and private files. They list principles such as lawfulness and fairness, accuracy, purpose specification, interested-person access, non-discrimination, security and independent supervision.

    Key themes
    • fair information principles
    • sensitive data
    • access
    • security
    • supervisory authority
    • transborder flows
    Unique features

    Separate provisions extend the principles to files held by international governmental organisations. They also have an early non-discrimination rule on sensitive data and allow transfers to countries with comparable safeguards.

    SaaS relevance

    Gives no direct obligations; it is historical background to UN-system data protection policies.

    Breach notification
    None
    DPO
    No
    Cross-border transfers
    Free flow to states with comparable safeguards
    Maximum penalty
    None
    Key dates
    • Adopted
    • In force
    Text
    Authority
    None designated
    Sources consulted
    Verification

    Medium confidence.

    Partly verifiedMedium confidence. I did not open the resolution text in this session. The resolution number and date come from established references. Refworld is a UNHCR mirror; the official text is in the UN Digital Library under A/RES/45/95.

    Record
    Full record for UN Guidelines 1990
    Partly verifiedMedium confidence. I did not open the resolution text in this session. The resolution number and date come from established references. Refworld is a UNHCR mirror; the official text is in the UN Digital Library under A/RES/45/95.