This report presents the findings of the 2025 OECD Peer Review of Kazakhstan’s competition law and policy. It assesses progress and developments in Kazakhstan’s competition regime during the past decade since the country’s first Peer Review in 2016, and provides key recommendations to enhance the effectiveness, independence and predictability of Kazakhstan’s competition regime. The findings and recommendations were discussed by the OECD Competition Committee on 20 June 2025.
Kazakhstan has undertaken substantial reforms to modernise its competition framework in the decade since 2016. While the primary legal basis remains embedded in the Entrepreneur Code adopted in 2015, a wide range of other legal provisions continue to govern competition matters. Five successive “antimonopoly packages” have introduced numerous substantive and procedural amendments to competition legislation of Kazakhstan.
The Agency for the Protection and Development of Competition (AZRK), re-established in 2020 as an independent authority, has improved its internal structure, regional co-ordination, and stakeholder engagement mechanisms. In addition to enforcement, the Agency plays a leading role in broader policy areas such as privatisation, public procurement, and price monitoring. However, this wide-ranging mandate risks undermining the Agency’s focus on core competition enforcement functions.
The Peer Review identifies several structural and operational challenges that continue to limit the effectiveness of Kazakhstan’s competition enforcement. These include a fragmented legal framework, a reliance on preventive soft-law tools over ex-post enforcement, and limited use of essential instruments such as the leniency programme and effective market inquiries. Procedural formalism in market studies, lack of judicial specialisation, and frequent legislative changes undermine legal certainty for businesses and overburden the judiciary.
Kazakhstan’s economy continues to exhibit high levels of state involvement, with extensive participation of state-owned enterprises across sectors and increased reliance on “single operators” with special or monopoly rights. Price regulation remains widespread, highlighting structural barriers to the transition from a planned to a fully market-based economy. Although reforms such as the Yellow Pages Rule and the establishment of a Privatisation Office aim to reduce state intervention and market dominance, competitive neutrality remains elusive and poorly understood. Recent political and judicial reforms have yet to translate into more consistent enforcement of competition law.
The Agency actively engages in institutional co-operation. Internationally, it participates in regional and global fora such as the Eurasian Economic Union (EAEU), UNCTAD, and the OECD, contributing to policy dialogue and aligning its practices with international standards. Domestically, the Agency collaborates with sectoral regulators and government bodies to address competition issues across key sectors of the economy. More systematic and structured engagement with businesses, civil society, academia and the judiciary is needed to raise awareness of competition principles, foster a shared understanding of enforcement goals, and build broader support for the reform agenda. A proactive and well-resourced advocacy strategy would help cultivate a stronger competition culture.
The recommendations in this Peer Review span Kazakhstan’s legal and institutional framework, enforcement practices, merger control, state participation in the economy, market studies, advocacy and judicial oversight. Their implementation would support Kazakhstan in building a more effective, independent and economically grounded competition regime aligned with international best practices —contributing to sustainable diversification and long-term economic growth.