Kazakhstan mandates disclosure of uranium asset control changes

September 25, 2026 at 09:00 AM2 min

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Kazakhstan's atomic energy agency approved a notification form requiring uranium subsoil users to disclose changes of control over themselves. The order was signed on September 17, 2026, and took effect retroactively from September 7, 2026. The move follows several ownership changes in Kazakh uranium mining involving Russian state corporation Rosatom.

Key Facts

The order No. 88-n/қ was signed by agency chairman Almasadam Satkaliyev on September 17, 2026, and registered with the Ministry of Justice on September 22, 2026.
The disclosure threshold is 25% of participation interest, votes in the management body, or right to distributable net income, including indirect control through chains of third-party organizations.
In December 2024, Rosatom subsidiary Uranium One sold 49.99% in the Zarechnoye joint venture to China's State Nuclear Uranium Resources Development.
The order was brought into effect from September 7, 2026, 16 days before official publication and 10 days before signing.
The order was agreed with the ministries of finance and national economy, indicating its fiscal and strategic weight.

Regulatory Framework

The Agency of the Republic of Kazakhstan for Atomic Energy approved a notification form that uranium subsoil users must submit upon a change of control over themselves. The formal basis for the document is a provision of the Code on Subsoil and Subsoil Use, not a specific company or country. The procedure is notification-based, not authorization-based: the subsoil user informs the state after the fact rather than seeking permission. The disclosure threshold is 25% of participation interest, votes in the management body, or right to distributable net income, including indirect control through chains of third-party organizations. This is intended to close a loophole for opaque offshore and holding structures in uranium asset ownership.

Retroactive Application

Order No. 88-n/қ was signed by agency chairman Almasadam Satkaliyev on September 17, 2026, registered with the Ministry of Justice on September 22 (No. 39943), and officially published on September 23. However, it was brought into effect from September 7, 2026, 16 days before official publication and 10 days before signing. For a normative act establishing a new obligation for legal entities, taking effect before official publication is rare: such norms generally should not have retroactive force if they worsen the position of addressees. Formally, subsoil users were required to notify the regulator of transactions concluded between September 7 and 23 using a form that had not yet been officially published at that time.

Rosatom Context

The order appears against the backdrop of several ownership changes in Kazakh uranium mining involving Russian state corporation Rosatom over the past two years. In December 2024, Rosatom subsidiary Uranium One sold 49.99% in the Zarechnoye joint venture to China's State Nuclear Uranium Resources Development. This type of transaction—transfer of a large stake to another owner, including a foreign one—now falls under mandatory declaration. The order was agreed not only with the specialized agency but also with the ministries of finance and national economy, indicating its fiscal and strategic weight.