OECD Integrity Review of Kazakhstan

Kazakhstan has made significant strides in anti-corruption efforts since the introduction of the Law on Combating Corruption and the Law on Civil Service and has developed a more integrated approach to integrity, spearheaded by the Anti-Corruption Service. Nonetheless, core anti-corruption institutions remain vulnerable to undue interference. Some integrity bodies and functions are still recent and could benefit from more co-ordination and co-operation to become fully operational. The role of the Civic Councils has been strengthened, paving the way for more broad-based engagement of civil society and the private sector.

• Kazakhstan could strengthen transparency and accountability around the selection, appointment and dismissal of the leadership of state bodies with responsibilities in the area of anticorruption and integrity.

• Kazakhstan could foster co-ordination of anti-corruption policy across the public sector and strengthen co-operation with non-state actors.

• Kazakhstan could strengthen corruption prevention at subnational level through targeted capacity-building and information-sharing.

Kazakhstan’s strategic approach to anti-corruption – the 2022-2026 Anti-Corruption Policy Concept – stands out for its evidence-based problem analysis and effective implementation, supported by the Anti‑Corruption Service’s digitally enabled project management approach. Notwithstanding these notable strengths, there is room to promote a more risk-based and participatory approach to public integrity, ensuring that current and future strategies deliver the desired impact. Project offices, Authorised Ethics Officers and Compliance Officers are key to implement the Policy Concept in organisations, but their capacities could be strengthened.

• Kazakhstan could improve the monitoring and evaluation framework of the 2022-2026 Anti‑Corruption Policy Concept.

• In the design of future strategies, the Anti-Corruption Service could apply a risk-based, participatory approach and encourage local governments to develop their own integrity plans.

• The Anti-Corruption Service could invest in capacity-building and methodological guidance to strengthen the mainstreaming of integrity policies in the public and quasi-public sectors.

In Kazakhstan, the Law on Combating Corruption and the Law on Civil Service set out standards for managing conflicts of interest. To strengthen existing standards and ensure their effective application, the legal framework could benefit from clearer definitions and broadened financial and interest disclosure requirements, supported by robust sanctions. Like other countries, Kazakhstan grapples with the practical application of its whistleblowing framework and the Code of Ethics for Civil Servants, which lay the foundation for promoting ethical behaviour and a culture of openness in the public sector.

• The scope of asset and interest declarations could be broadened and institutional responsibilities for in-depth verification clarified. While basic sanctions are in place, they could be more proportionate to ensure the credibility of relevant integrity standards.

• Kazakhstan could improve whistleblower protection by strengthening internal reporting and expanding protections against retaliation.

• To strengthen integrity standards and build a culture of integrity in the public sector, Kazakhstan could provide clear, practical guidance on the application of ethical principles for civil servants, making use of behavioural insights and tailored training.

In Kazakhstan, the importance of promoting a whole-of-society approach to anti-corruption has been recognised in key strategic policy documents. Notwithstanding progress made, legal and structural barriers related to access to information, media pluralism and civic participation continue to limit individuals, civil society organisations, and the media in scrutinising government and fully participating in policymaking.

• To cultivate a whole-of-society approach to integrity, Kazakhstan could undertake fundamental legal reforms to expand access to information, promote media pluralism and independence, and foster civic participation.

• Kazakhstan could increase public sector transparency and improve the enabling environment for civil society organisations and other relevant stakeholders to effectively engage in policymaking, underpinned by a dedicated strategic approach.

• The Anti-Corruption Service could develop a communications strategy to promote civic education and raise awareness for anti-corruption and integrity across society. This also includes strengthening guidance and support for the private sector.

Internal control and risk management are critical components of Kazakhstan’s fight against corruption, as acknowledged in the 2022-2026 Anti-Corruption Policy Concept. Recognising the importance of these systems, Kazakhstan could benefit from improving the effectiveness and objectivity of internal control, risk management, internal audit, and external oversight.

• To make internal control and risk management more effective, Kazakhstan could establish clear guidelines for internal control systems, detailing the responsibilities of managers and auditors.

• Risk management frameworks could be broadened to address various types of risks and involve line managers in day-to-day operations.

• Kazakhstan could improve internal audit capabilities, particularly at the central government level, and make better use of the Supreme Audit Chamber’s work for effective budget allocation and internal control in line with international standards. This includes investing in IT-based audit capabilities to increase efficiency, transparency and impact of audits.

In recent years, Kazakhstan has taken steps to enhance transparency and integrity in public decision making, including by introducing public consultations, Public Councils and Expert Councils. Notwithstanding these positive developments, Kazakhstan could benefit from strengthening the autonomy of public authorities in the face of private interests.

• Kazakhstan could strengthen transparency of lobbying activities and bodies providing advice to the government.

• Kazakhstan could establish a public integrity framework for public officials that is adapted to the risks of lobbying and influence activities.

• To reinforce competition, transparency and integrity in election processes, Kazakhstan could tighten rules around political party income and expenditures and strengthen audit capacities to better enforce political financing regulations.