If the employee and their spouse had no taxable income during the reporting period, there is no need to publish any information.

Information regarding both the individual and their spouse is required to be published as a single consolidated list. There is no need to create separate publications.

Yes, the amendments were introduced by us based on several grounds, including legislative ones.

According to the normative rulings of the Constitutional Court, any prohibitions and restrictions on human rights and freedoms must correspond to legally justified objectives and meet the standards of fairness, proportionality, and appropriateness. Thus, restrictions that lack an objective and reasonable justification cannot be taken into account. Based on the provisions and objectives of the anti-corruption legislation, it appears sufficient and appropriate to publish information on income subject to individual taxation.   

Pursuant to paragraph 1 of Article 14‑1 of the Law “On Combating Corruption,” individuals holding responsible public positions, persons authorized to exercise state functions (excluding members of maslikhats), and officials are forbidden to open or maintain accounts (deposits) in foreign banks outside the Republic of Kazakhstan, or to store cash and valuables in such foreign banks.

In light of the above, disclosing information on funds in foreign bank accounts for the specified categories of officials carries no independent legal or anti-corruption relevance, as existing legislation already imposes a direct prohibition on the opening and possession of foreign accounts.

Furthermore, the existing level of digitalization and interagency integration of governmental information systems allows the competent authorities to automatically track the financial and property activities of individuals, including the acquisition and disposition of property, the flow of funds in bank accounts, the ownership of assets, and other relevant indicators.

Consequently, financial oversight is conducted in a structured and continuous format, without requiring further public disclosure of information, thereby demonstrating that the current digital tools are sufficient for effective monitoring and prevention of violations.

It should also be noted that foreign assets were already reported in the declaration of assets and liabilities (Form 250.00) upon entry into the declaration system.

Thus, the initial information on foreign assets is already at the disposal of the state revenue authorities and is taken into account under the financial control.

In the following tax period, the focus of control is on the income generated from the disposal of assets, rather than the assets themselves. Pursuant to tax legislation, property-related income encompasses both income from the sale of property within the Republic of Kazakhstan and income from the sale of property originating from sources outside the Republic of Kazakhstan. Such income is subject to mandatory declaration, which ensures the maintenance of comprehensive financial control by the authorized bodies.

No, publication is not required. The publication is always linked to the reporting year. In this case, the reporting year is 2024. In 2024, this person was a Category “B” employee.

Employees of Category “B” are obliged to submit declarations (Form 270.00); however, they are not included among the individuals whose information must be published for public awareness (in accordance with paragraph 9 of Article 11 of the Law): those holding political state positions, occupying administrative state positions in Category “A,” members of the Parliament of the Republic of Kazakhstan; the Commissioner for Human Rights in the Republic of Kazakhstan; judges of the Republic of Kazakhstan; and individuals exercising managerial functions in quasi-state sector entities.

Thus, the declaration he submitted for 2024 is not subject to publication. His new status as a political official will be relevant only in the following year. The obligation to publish information will arise for him based on the results of 2025. This information will be published in 2026.

When making a decision on publication, it is necessary to take into account two key factors simultaneously:

The first is the status of the individual at the time of submitting the declaration (by September 15).

The second is the status of the individual on December 31 of the year following the reporting calendar year.

No, the declaration is not required to be published. The status of the person, which served as the basis for submitting the declaration, must be taken into consideration.

Despite the fact that, on December 31, 2025, the person occupies a political position, the 2024 declaration was submitted by him/her in another capacity.

Accordingly, the requirement to publish information from this declaration does not apply to them. The obligation to publish information for this official will arise based on the results of 2025. This information will be published in 2026.

No, the declaration is not required to be published. If a political public official was appointed to service after September 15, 2025, they did not submit a declaration of income and assets for the 2024 reporting year.

The duty to submit a declaration for the 2024 reporting year applies solely to individuals who held a position in public service during that period, i.e., in 2024.

Since this employee was not in service at that time, they had no obligation to submit a declaration. Due to the absence of a submitted declaration, the information is not subject to publication.

No, the declaration is not required to be published. The requirement to publish information applies to individuals who, as of the date of publication, hold a political public position. 

In the situation described in the question, the appointment procedure has not been legally completed. The person is serving in an acting capacity and is subject to the required special background check.

If, as of December 31, the individual has not yet assumed the position and does not hold full status as a political official, there are no grounds for publishing information from their declaration.

No, the declaration is not required to be published. It should be noted that a person appointed to a political position in 2025 will provide a declaration for the 2025 reporting year in 2026, and consequently, the information will be published in 2026.

Yes, the declaration is required to be published. If, during the reporting period (2024), the individual held a political position and submitted a declaration in the status of a political official, and also holds a political position at the time of publication, then their information is subject to publication.

No, the declaration is not required to be published. The duty to submit a declaration of income and assets, and consequently to disclose the information, is linked to the relevant reporting tax period. In 2025, the reporting period is the year 2024.

Thus, the date of marriage in 2025 is irrelevant for the publication of information for 2024.

There are no grounds for publication. The obligation to submit a declaration as a spouse will arise for this individual based on the results of 2025.

No, the declaration is not required to be published. In the event of divorce, the obligation to publish information about the former spouse terminates.

A distinction must be made between the duty to submit a declaration, which must be completed by September 15, and the duty to publish it, which is to be fulfilled by December 31.

In this case, at the time of submitting the declaration (by September 15), the individual was still married and was required to submit a declaration. As the marriage has been dissolved by the time of publication, the person ceases to hold the legal status of a spouse.

According to the law, the disclosure of information applies solely to individuals who are currently married. Since the individual no longer belongs to this category, information about them is not subject to publication.

Pursuant to paragraph 9 of Article 11 of the Law, the information disclosed in declarations is to be published by no later than December 31 of the year following the reporting year.

Setting this deadline entails a yearly cycle for updating the information subject to publication.

Thus, previously published information remains on the website until it is replaced by new, up-to-date information.

The removal of published information may occur simultaneously with the posting of updated information for the next reporting period.

Following dismissal, the person no longer possesses the status (of an individual specified in paragraph 9 of Article 11 of the Law) which served as the basis for the publication. However, this does not entail the immediate removal of the information.

Pursuant to paragraph 9 of Article 11 of the Law, the information disclosed in declarations is to be published by no later than December 31 of the year following the reporting year.

Thus, the entire set of data published for a specific year remains relevant until the next publication period begins.

In this regard, information about a dismissed individual, being part of the data for the reporting year, remains on the government agency’s online resource.

Such information stays publicly available until the planned replacement with updated data, namely, until the publication of information for the subsequent reporting year.

Yes, duplication of the publication is required. Pursuant to paragraph 9 of Article 11 of the Law, the duty to disclose information on the official websites is assigned to the human resources (personnel) departments of the relevant government agencies and organizations.

Thus, the responsibility for publishing the information lies with the human resources department at the employee’s current place of work.

As the disclosure is conducted at the official’s place of public service, upon transfer of a political official to a different government agency, the information shall be republished on the website of the new employer following the prescribed procedure.

Yes, duplication of the publication is required. In accordance with paragraph 9 of Article 11 of the Law, information must be published about individuals who have submitted declarations, as well as their spouses. This duty rests with the human resources department at the employee’s place of work.

Thus, if both spouses are political officials in different organizations, each human resources department is required to fully comply with the provisions of the Law:

The organization where the husband works publishes information about both him and his spouse.

The organization where the wife works publishes information about both her and her spouse.

This ensures the completeness and transparency of the published information in accordance with the requirements of the law.

If an official does not provide the information required for publication, the human resources (personnel) department notifies the head of the relevant government agency of this fact. At the same time, in accordance with the procedure established by law, the human resources (personnel) department initiates the issue of holding the individual disciplinarily liable for violating anti-corruption legislation.