Kazakhstan and the GDPR

A summary comparison of Kazakhstan's rules with the GDPR on key issues.

Questions

Click a question to see a short answer. The detailed analysis with legal references is in the note below.

  1. Where does Kazakhstan's regime match the GDPR, and where does it fundamentally differ?

    The basic concepts match — principles, people's rights, protection measures, breach notification. The foundations differ — in Kazakhstan consent is the main ground (there is no contract or legitimate interest ground), data must be stored in the country, protection measures are set by lists, response deadlines are counted in days, and fines are fixed and lower, but there is criminal liability.

    More in the note «Kazakhstan and the GDPR — a summary comparison»

  2. What must a GDPR-compliant company additionally do?

    Revisit the legal grounds — obtain consent where contract or legitimate interest sufficed under the GDPR; store data in Kazakhstan; obtain consent to transfers abroad; approve a list of data and a policy and appoint a responsible person; determine its category and protection measures; adapt processes to 1–3 working-day deadlines; and stop making paper copies of identity documents.

    More in the note «Kazakhstan and the GDPR — a summary comparison»

Key provisions

Notes

Materials

EU law

EU law2016/679EU

Regulation (EU) 2016/679 (General Data Protection Regulation) (opens in a new tab)

Used for comparison. The GDPR has no general localisation duty: data move freely within the EU (Art. 1(3)), and exports outside the EEA are governed by Chapter V, with the transfer conditions in Arts 44–49.

Key provisions
Art. 1(3), Art. 44–49

● Checked 26 October 2026in forceCross-border transfersKazakhstan and the GDPRData localisation

Regulator guidance