Liability for Violations in Submitting Data to the Unified System of Employment Contracts

Dear Readers,

On 12 March 2026, amendments¹ to the Code of Administrative Offences came into force, introducing liability for employers that violated the rules for submitting data to the Unified Employment Contracts System (the UECS). The state introduced the requirement to submit such data in 2020; however, the administrative liability for non-compliance was introduced only now.

Article 98 of the Administrative Offences Code introduced a new provision establishing administrative liability for:

• failure to submit data to the UECS or late submission;
• submission of incomplete information;
• submission of inaccurate or incorrect information.

Based on the Monthly Index Factor for 2026 (KZT 4 325), the fines are as follows:

• KZT 129 750 (30 times the MIF) for officials;
• KZT 259 500 (60 times the MIF) for small businesses or non-profit organizations;
• KZT 346 000 (80 times the MIF) for medium-sized businesses;
• KZT 648 750 (150 times the MIF) for large businesses.

For repeat violations within one year (Article 98(2-1) of the Administrative Offences Code), the fines increase to:

• KZT 259 500 (60 times the MIF) for officials;
• KZT 346 000 (80 times the MIF) for small businesses or NPOs;
• KZT 432 500 (100 times the MIF) for medium-sized businesses;
• KZT 865 000 (200 times the MIF) for large businesses.

According² to the Ministry of Labor and Social Protection, the law does not provide for automatic penalties for late submission of data to the UECS. The state authorities will impose administrative liability only following inspections.

Under³ the Labor Code, employers are required to submit to the UECS information on the conclusion and termination of employment contracts, any amendments or supplements to them, and certain types of leave. The Rules⁴ for Submission and Retrieval of Employment Contract Data in the UECS establishes the procedure and timelines for submission.

Employers are required to submit the following information:

1. identification details of the parties:
2. the employee's job function (specialization, position);
3. work location;
4. the term of the employment contract;
5. work commencement date;
6. contract date and reference number.

The rules establish the following submission deadlines:

• employment contract execution – within 5 business days;
• amendments and supplements – within 15 calendar days;
• termination – within 3 business days;
• correction of errors – within 30 business days;
• reinstatement – within 10 business days;
• contract extension – within 15 business days.

To enter information into the UECS, employers may integrate their HR information systems with the UECS to automatically transfer the data. Alternatively, employers may enter the employment contracts data into the UECS via the state Internet portal Electronic Labor Exchange. Employers must authenticate the entered data with an electronic digital signature.

¹ Law No. 257-VIII of the Republic of Kazakhstan On Amendments and Additions to the Code of Administrative Offences, dated, 9 January 2026

² https://www.gov.kz/memleket/entities/enbek/press/news/details/1179545?lang=ru

³ Point 2 (27) of Article 23 of the Labor Code

⁴ Order No. 353 of the Minister of Labor and Social Protection of the Republic of Kazakhstan On Approval of the Rules on Submission and Retrieval of Employment Contract Data in the Unified System of Employment Contracts, dated 3 September 2020