Obtaining a work permit after three extensions for a German citizen

A German citizen approached us who had been working in the Republic of Kazakhstan for four years on the basis of a work permit. The initial permit and all subsequent extensions had been handled by our team. The permit was extended annually, and at the time of inquiry the employee had already received three extensions.

It is important to note that the procedure for issuing and extending work permits for foreign nationals in Kazakhstan is governed by the Rules and Conditions for Issuing Permits to Employers for the Engagement of Foreign Labor, approved by an Order of the Minister of Labor and Social Protection of the Population of the Republic of Kazakhstan. Under the applicable regulations, certain categories of foreign employees are subject to a limit on the number of permit extensions. After three extensions, no further renewal is allowed, and the employer must initiate the process of obtaining a new work permit. This is exactly the situation we encountered. Upon the expiration of the most recent permit, it was decided not to extend it, but instead to apply for a new work permit for the foreign employee as a separate procedure.

An additional complication arose from the fact that work permit applications for foreign nationals in Kazakhstan must now strictly correspond to the National Classifier of Occupations of the Republic of Kazakhstan. An application may only be submitted for a position that is officially listed in the classifier. The position previously held by the employee — “Regional Commercial Manager” — is not included in the current version of the CS.

Accordingly, it was not possible to apply using the same job title. In such cases, a purely formal approach is not acceptable. It is not sufficient to simply “rename” the position; the selected role must genuinely correspond to the employee’s education, qualifications, and actual job responsibilities. We analyzed his diploma and professional experience and aligned them with the applicable occupational reference frameworks of the Republic of Kazakhstan, including the Qualification Handbook, the Occupation Classifier, and the UTQH.

In accordance with the legal requirements, specifically the provisions of the Law “On Employment of the Population,” before submitting a work permit application, the employer must demonstrate efforts to recruit candidates from the domestic labor market. The vacancy must be posted on the Electronic Labor Exchange enbek.kz for the exact position specified in the Occupation Classifier. This is a mandatory step; without it, the application will not be accepted. We selected a position listed in the Qualification Handbook that best matched the employee’s qualifications, posted the vacancy on the portal, conducted the required search for candidates among citizens of the Republic of Kazakhstan, and only after completing this stage prepared the application package.

After completing all preparatory steps, we proceeded with the submission of the work permit application through the e-License portal, which is used for filing such applications electronically. Within two business days, we received confirmation that the company had been authorized to employ a foreign specialist in the specified position. This indicates that the competent authority verified the correctness of the selected role, the employee’s qualifications, and compliance with all procedural requirements, including the vacancy posting. At the next stage, we paid the state fee. Upon confirmation of payment, the process was finalized promptly, and the work permit was officially issued within one business day.

Right after obtaining the permit, we proceeded to the next step — submitting documents for the extension of the employee’s C3 work visa. It is important to note that visa extensions are directly dependent on the validity of the work permit; therefore, strict adherence to timelines at each stage is essential. As a result, all procedures were completed in a timely and consistent manner, ensuring uninterrupted employment of the foreign specialist in the Republic of Kazakhstan.

This case demonstrates that obtaining a work permit for a German citizen in Kazakhstan (as well as for citizens of other countries) in similar circumstances requires not only meeting deadlines, but also careful alignment of the job position with the official classifier. Currently, the work permit process in Kazakhstan is highly structured: the authorities assess not only the fact of employment, but also the appropriateness of the selected position, the employee’s qualifications, and compliance with local labor market search requirements.