Subscriber service information and its cross-border transfer.
Click a question to see a short answer. The detailed analysis with legal references is in the note below.
These are subscriber data generated in communication networks — numbers, IMEI, IIN or BIN, billing, location, IP addresses and resources visited. Operators keep them in Kazakhstan and provide them to bodies conducting operational-search and counterintelligence activities; to others — only with the subscriber's consent and as provided by law.
More in the note «Subscriber service information in telecommunications»
Transferring service information outside Kazakhstan is prohibited even with the subscriber's consent — except when a Kazakhstan subscriber uses services abroad (roaming). This is stricter than the general personal data rule, under which consent allows transfer.
More in the note «Subscriber service information in telecommunications»
Note
When personal data may be sent abroad: Article 16 of the Law, how it interacts with the consent requirement in Article 7, sector-specific bans, and why the absence of a list of "safe" countries leaves much unclear.
Note
The Communications Law's special regime for subscriber data: what counts as service information (numbers, IMEI, IIN, billing, location, IP addresses), the absolute ban on transferring it abroad, access by state bodies, secrecy of communications and device registration. The 2026 amendments and a pilot project running to the end of 2027.
The core statute: definitions, scope, the in-country storage rule (Art. 12) and cross-border transfers (Art. 16). Notification of processing (Art. 10-1) and operator size categories (Art. 25-1) apply from 25 August 2026.
Open:Adilet (opens in a new tab)officialzakon.uchet.kz (opens in a new tab)alternative source, unofficial
● Checked 26 October 2026in forceAutomated processing and AIBreaches and notificationsConsentCross-border transfersTypes of personal dataData subject rightsDeletion and anonymisationDisclosure to third partiesLiabilityData localisationNotification and register of operatorsProcessing principlesProcessing without consentPurpose, scope and retentionRegulator and state supervisionResponsible person and internal policiesScope and key termsTelecommunicationsSecurity measures
Special regime for subscriber service information (numbers, device IDs, billing, location, IP addresses, Art. 23-1): it must be stored in Kazakhstan and may not be transferred abroad except to serve Kazakhstan subscribers roaming abroad (Art. 15(1)(2)).
Open:Adilet (opens in a new tab)officialzakon.uchet.kz (opens in a new tab)alternative source, unofficial
● Checked 26 October 2026in forceCross-border transfersData localisationTelecommunications