How the ARDFM is changing insurance market supervision: Solvency II, IFRS 17 and client complaints

Supervision of insurance companies in Kazakhstan is being restructured in two stages. Some of the new tools are already in place under ARDFM resolutions. A deeper overhaul, including a new solvency regime, is set out in the draft law "On the Insurance Market", which was put out for public consultation on 15 September 2026.

What is already in force

Supervisory policy priorities for 2026. In early March the ARDFM published its supervisory priorities for the insurance sector. The regulator announced a transition to an integrated supervisory model based on the Insurance Core Principles of the International Association of Insurance Supervisors, the principles of the Solvency II directive and the IFRS 17 standard. Each company's risks are assessed annually by the SRES (Supervisory Risk Evaluation System), and in 2026 customer complaints became a significant factor in this assessment for the first time.

IFRS 17. The new Tax Code gave the ARDFM the right to approve requirements for the measurement and structure of insurance liabilities under IFRS 17 and the methodologies for calculating them. In 2026 the regulator will, for the first time, check whether insurers' methodologies comply with these requirements and whether companies are ready for automated measurement of liabilities.

Conduct supervision. ARDFM Board Resolution No. 3 of 27 January 2026 added to the list of factors indicating a deterioration in an insurer's financial position an excess of the complaints ratio and a combination of a low loss ratio with a high share of premiums in a class. The tariff instruction introduced limits for voluntary insurance of individuals (except savings life insurance and sickness insurance): the loading may not exceed the net rate, and the gap between the minimum and maximum base rate may not exceed 50%. Insurers are required to set up an independent customer protection unit that conducts mystery shopping of policies and checks that sales are conducted properly.

Motor third-party liability (MTPL). In 2026 amendments to the rules came into force: compulsory motor insurance became cheaper for first-time policyholders, the calculation of bonus-malus coefficients was clarified, and the insurer is now responsible for the accuracy of the data it submits to the Unified Insurance Database.

What the draft law provides for

• solvency assessment based on Solvency II principles: capital is calculated taking into account each company's financial, operational and insurance risks, and liabilities are valued on an economic basis;
• mechanisms for early detection of insolvency and a separate procedure for assessing an insurer's viability (Article 231 of the draft);
• a Central Actuary based at a subsidiary of the UAPF: calculation of tariffs for compulsory classes, stress testing and scenario analysis of the market;
• the right of the Insurance Payments Guarantee Fund to analyse financial stability risks of market participants;
• a special regulatory regime (sandbox), open also to insurance intermediaries, AI solutions, telematics and parametric insurance;
• the electronic contract as the main format for mass-market voluntary products and unique identification of all compulsory insurance contracts in the Unified Insurance Database.

Consumer protection will be strengthened by a single Financial Ombudsman Service, which will start operating on 1 January 2027. Kanat Aligulov was elected Ombudsman for the insurance sector on 30 September 2026.

What this means for agents and brokers

• Customer complaints have become a supervisory indicator for insurers. As a result, insurers will hold their sales channels, including intermediaries, to stricter account.
• Mystery shopping and checks on proper selling affect agents first and foremost: mis-selling a product or incomplete disclosure of terms is now recorded within the insurance company.
• The loading limit in voluntary products for individuals narrows the room for high commissions.
• With the move to electronic contracts and unique identification of policies, paper-based and "grey" sales schemes are becoming risky.