Prohibition on entering into civil-law contracts that have the characteristics of an employment contract.

Amendments have been introduced to the Kazakhstan Labour Code prohibiting conclusion of a civil contract with an individual if such a contract contains at least one of the distinguishing features of an employment agreement as defined by the Labour Code.

On 7 April 2026, the Kazakhstan President signed the Law on Amendments and Additions to Certain Legislative Acts of the Republic of Kazakhstan on Improving Safe Working Conditions, Protecting Employees’ Labour Rights and Social Security (Law No. 277‑VIII). Among other things, this Law introduces a prohibition on entering into a civil contract with an individual if such contract contains at least one of the distinguishing features of an employment agreement established by the Labour Code.

Thus, it is not permitted to enter into a civil contract with an individual if the contract contains at least one of the distinguishing features of an employment agreement set out in Article 27 of the Labour Code, namely:

1. performance by the individual of work (labour functions) based on a specific qualification, specialty, profession, or position;
2. personal performance of obligations subject to internal labour regulations;
3. receipt of wages by the individual for the work performed.

A contract containing one or more of the above-mentioned features should be recognized as an employment agreement regardless of its title as designated by the parties and should entail legal consequences in accordance with the Kazakhstan labour legislation.

The above-mentioned amendments come into effect on 8 June 2026.