Amendments to Resolution of the Government of the Republic of Kazakhstan №1041: now only one foreign national may serve as a deputy / General Director of an LLP with 100% foreign participation

In August 2025, amendments were introduced to Annex 1, Clause 16 of the Resolution of the Government of the Republic of Kazakhstan №1041. To the existing provision that no work permit is required for General Directors (first heads) and their deputies in companies with 100% foreign participation, a key phrase was added:

“No more than one unit for these positions.”

What does this mean in practice?

Now, companies with 100% foreign participation may employ only one foreign employee for each of the following positions without obtaining a work permit:

• General Director (first head), or
• Deputy General Director

Previously, the regulation did not contain quantitative restrictions, and in practice many companies appointed several deputies without a work permit.

Now, however:

• A company may employ only one foreigner in each category without a permit.
• Any additional foreign employees must go through the procedure of obtaining a work permit for the employment of foreign labor through the local executive authorities.

What if the company already employs several deputies?

At present, some companies already have several foreign nationals serving as deputies, hired earlier without obtaining a work permit – in line with the previous version of the Resolution.

In this regard, we have received an official response from the Ministry of Internal Affairs of the Republic of Kazakhstan concerning visas already issued under the exemption:

Current visas remain valid until their expiry date. However, their extension is only permitted in accordance with the new amendments to the Resolution.