Since 2010, the Global Law Experts annual awards have been celebrating excellence, innovation and performance across the legal communities from around the world.
posted 1 hour ago
Last updated: June 12, 2026
Any company planning to build or operate a power plant in Kazakhstan must answer one threshold question before committing capital: does the project require an electricity generation licence? Under the Law of the Republic of Kazakhstan on Electric Power Industry (the “Electric Power Industry Law”), most entities that produce electricity for sale to the grid or to third parties must hold a valid generation licence issued through the state e‑licensing portal, elicense. kz. With the Kazakhstan electricity market changes in 2026, including ongoing capacity‑market reforms flagged by the Ministry of Energy and updated KEGOC interconnection procedures, the licensing landscape has shifted enough to warrant a fresh compliance review.
This guide explains how to obtain an electricity generation license in Kazakhstan, covering when a licence is required versus when renewable projects may be exempt, the exact documents needed, statutory timelines, fees, penalties for non‑compliance, and what project‑finance lenders will expect before committing funds.
The starting point is the Electric Power Industry Law, published on the official legal information system Adilet. The law defines “electricity generation” as the production of electric and (where applicable) thermal energy at power plants, and requires any legal entity engaged in that activity on a commercial basis to hold a licence unless a specific exemption applies. The rule is binary: if you sell electricity, you almost certainly need a licence; if you generate solely for your own consumption below certain conditions, you may not.
Use the table below to identify your position quickly.
| Activity / Scenario | Licence Required? | Legal Basis / Notes |
|---|---|---|
| Selling electricity to third parties or wholesale to the grid (IPP model) | Yes | Electric Power Industry Law, generation licence required for any entity producing electricity for commercial sale; application via elicense.kz. |
| Captive generation for own consumption only (no sale to third parties), below small‑scale thresholds | No (subject to conditions) | Exemption under the law for facilities generating exclusively for the licence holder’s own needs, provided no electricity is sold or fed into the unified power system for commercial purposes. |
| Resale of purchased electricity (energy supply / trading) | Yes, separate energy supply licence | Distinct permit category; application typically through egov.kz e‑services. Not the same as a generation licence. |
| Utility‑scale renewable generation (wind / solar) selling to the grid | Yes, unless small‑scale exemption applies | Renewable facilities selling electricity under a PPA or auction mechanism require a generation licence. Certain small renewable installations may benefit from simplified treatment, see exemptions below. |
| Hybrid projects (generation + battery storage) | Likely Yes, depends on activities | Storage paired with generation that feeds the grid triggers the generation licence requirement; storage‑only activities may require separate registration or permits under evolving Ministry of Energy guidance. |
The critical dividing line is commercial sale. Once electricity crosses from the producer to a buyer, whether through a bilateral PPA, an auction allocation, or the balancing market, the generation licence requirement is triggered.
The Electric Power Industry Law, together with the Law on Supporting the Use of Renewable Energy Sources, provides a framework of incentives for renewable energy, but these incentives should not be confused with licence exemptions. Utility‑scale wind, solar, small hydro, and biogas projects that sell output to the grid under the Single Buyer mechanism (operated by the Financial Settlement Centre) are required to hold a generation licence on the same terms as conventional plants.
A genuine exemption exists only for small‑scale installations generating electricity exclusively for the owner’s own consumption and not connected to the unified power system for purposes of commercial export. Rooftop solar panels powering a single factory or farm, for example, fall outside the licensing perimeter provided no surplus is sold. Industry observers note that Kazakhstan’s regulatory framework does not yet include a formal net‑metering or feed‑in tariff scheme that would allow small prosumers to sell surplus to the grid without a licence, early indications suggest that the Ministry of Energy may address this gap in upcoming regulatory packages, but as of mid‑2026 the exemption remains narrow.
Developers should note that even exempt captive facilities may still require other power plant permits in Kazakhstan, including environmental approvals and construction authorisations, the generation licence exemption does not waive those parallel obligations.
The principal statute governing the electricity generation licence in Kazakhstan is the Law of the Republic of Kazakhstan on Electric Power Industry, available in its current consolidated form on the Adilet legal information system. Key provisions relevant to licensing include:
The energy supply licence (for electricity resale/trading) is a separate category and should not be confused with the generation licence. Applicants planning both generation and sale activities may need to apply for each licence independently.
All generation licence applications in Kazakhstan are submitted electronically through elicense.kz, the state’s unified e‑licensing portal. The platform eliminates paper applications and enables tracking of application status in real time. Below is the general application workflow.
The following table summarises the core documents typically required under the qualification requirements for a generation licence. Applicants should verify the current list directly on elicense.kz, as document requirements are updated periodically by government decree.
| Document | Where to Obtain | Notes |
|---|---|---|
| Application form (electronic) | Generated on elicense.kz | Auto‑populated from BIN data; verify accuracy before submission. |
| Certificate of state registration / extract from the legal entities register | Ministry of Justice / egov.kz | Must be current; electronic extract accepted. |
| Charter (constituent documents) of the legal entity | Applicant’s corporate records | Notarised copy; must reflect energy generation as a permitted activity in the company’s objects. |
| Qualification requirements confirmation (technical competence) | Applicant / technical consultants | Evidence of qualified personnel, technical equipment, and operational readiness to generate electricity. |
| Technical passport of the generation facility | Design / engineering contractor | Includes installed capacity (MW), fuel type, schematic drawings, and equipment specifications. |
| Environmental impact assessment (EIA) approval or environmental emission permit | Ministry of Ecology and Natural Resources | Required for all generation facilities; scope depends on capacity and fuel type. |
| Grid connection agreement or KEGOC technical conditions letter | KEGOC (transmission) or regional electricity distribution company | Confirms that the plant can connect to the unified power system; critical for bankability. |
| Land title or lease agreement for the plant site | Local akimat (regional government) | Must cover the full project footprint; lease term should match or exceed the licence term. |
| Payment receipt for state duty | Generated on elicense.kz / bank transfer | Retain electronic confirmation. |
| Power of attorney (if filed by a representative) | Notary | Must specifically authorise the representative to apply for licences on behalf of the entity. |
Kazakhstan’s state language is Kazakh, and Russian has equal official use in state bodies. All documents submitted to elicense.kz must be in Kazakh or Russian. Foreign‑language documents, such as equipment certificates from overseas manufacturers, shareholder resolutions of a foreign parent, or technical reports prepared in English, require notarised translation by a certified translator in Kazakhstan. Apostille or consular legalisation may also be needed for documents originating from countries that are not parties to the Hague Apostille Convention with Kazakhstan.
Understanding the cost and timeline is essential for project scheduling and financial close planning.
For projects targeting a specific financial close date, the likely practical effect is that applicants should submit the elicense.kz application at least 45–60 days before the date by which a valid licence must be in hand, allowing buffer for any document‑correction requests.
The generation licence is only one element of the broader regulatory approval chain for power plant permits in Kazakhstan. Developers must sequence several parallel approvals, and delays in any one can hold up the entire project. The key permits and approvals include:
KEGOC, the national electricity grid operator, plays a gatekeeping role. Developers must apply to KEGOC for technical conditions before they can finalise the generation licence application, because the grid connection letter is a required document on elicense.kz. KEGOC’s published connection procedures, available on its official website, set out the application form, required technical data, and indicative timelines. Early engagement with KEGOC, ideally at the pre‑feasibility stage, is strongly recommended to avoid delays.
Operating a generation facility without a valid electricity generation licence in Kazakhstan is an administrative offence. The Code of Administrative Offences prescribes monetary fines for unlicensed activity, and repeated violations can result in court‑ordered suspension of operations. Key enforcement points include:
For IPPs and project‑finance structures, a licence revocation event typically constitutes a default under financing agreements, making ongoing compliance a commercial as well as a legal imperative.
International and domestic lenders financing power projects in Kazakhstan will scrutinise the generation licence as a condition precedent to disbursement and an ongoing covenant. The following items typically appear on a lender’s due‑diligence checklist:
Industry observers expect that as Kazakhstan’s electricity market deepens, with the planned introduction of a fully competitive balancing market, lender scrutiny of licence terms, grid access rights, and regulatory stability mechanisms will only intensify.
Even experienced developers encounter obstacles in the licensing process. The most common pitfalls, and how to mitigate them, are set out below.
To streamline the application process, use the following resources:
Securing an electricity generation licence is a foundational step for any power project in Kazakhstan, whether conventional or renewable. The process is well‑defined: determine whether your project falls within the licensing requirement, prepare the prescribed documents, submit the application through elicense.kz, and allow adequate time for the statutory review period. Developers who begin the KEGOC connection process early, prepare compliant documentation in Kazakh or Russian, and build realistic timelines into their project schedule will navigate the process most efficiently. For a concise, printable reference on how to obtain an electricity generation license in Kazakhstan, download the PDF checklist that accompanies this guide, and consult a qualified energy‑sector lawyer through the Global Law Experts directory for project‑specific advice.
This article was produced by Global Law Experts. For specialist advice on this topic, contact Madiyar Bekturganov at Zan Hub LLP, a member of the Global Law Experts network.
posted 9 minutes ago
posted 34 minutes ago
posted 58 minutes ago
posted 3 hours ago
No results available
Find the right Legal Expert for your business
Sign up for the latest advisor briefings and news within Global Advisory Experts’ community, as well as a whole host of features, editorial and conference updates direct to your email inbox.
Naturally you can unsubscribe at any time.
Global Advisory Experts is dedicated to providing exceptional advisory services to clients around the world. With a vast network of highly skilled and experienced advisors, we are committed to delivering innovative and tailored solutions to meet the diverse needs of our clients in various jurisdictions.