Yes, it can happen. Since 1 January 2026, Kazakh banks send the tax authority a quarterly list of people whose personal accounts received money from 100 or more different people in each of three consecutive months, where the three-month total is above 12 times the minimum monthly wage. For 2026 that total is 1,020,000 tenge. If you sell USDT on P2P to your own card, every buyer pays from their own card, so the head count is the part you hit first.
Being on that list is not a fine and not a finding that you broke the law. It tells the State Revenue Committee that your account looks like it is earning business income. What usually follows is a notice asking you to explain the money. Whether that goes smoothly depends on the records you can produce.
Order No. 698: which accounts banks report, and when
The rule sits in Ministry of Finance Order No. 698 of 12 November 2025, in force from 1 January 2026 and issued under Article 55(2)(24) of the new Tax Code. It replaced Order No. 323 of 2022. An annex to the order describes operations on an individual's account that may point to business income. All three of these must be true at once:
- Senders. In each of three consecutive calendar months, one person receives money from 100 or more different people. The Russian text reads «от 100 (ста) и более разных лиц».
- Amount. The total received over those three months is more than 12 times the minimum monthly wage in force on 1 January of that year. The 2026 minimum wage is 85,000 tenge, so the line is 1,020,000 tenge.
- Account type. The money lands on an account that is not meant for business, which in practice means an ordinary personal card or current account rather than a sole trader's business account.
Two things changed from the 2022 version. The old order had only the head count, with no amount test, and data moved once a year after the State Revenue Committee asked banks for it. Under Order No. 698 banks report every quarter, no later than the 15th of the month after the quarter ends, through a system called Smart Data Finance. The report carries the person's IIN and the total received; BES.media adds that it also includes the number of senders.
In April 2026, Deputy Finance Minister Aset Turysov told reporters that banks pass on information only in the cases the Tax Code sets out. An account that misses any one of the three conditions is not on the quarterly list.
Why P2P sellers reach the threshold before anyone else
A hundred different payers a month is roughly three or four new buyers a day. Someone who keeps a sell ad open on a P2P board most days can get there without noticing. A buyer who comes back five times in one month is, on the literal wording, still one person; we found no official guidance on how repeat payers are counted, so treat that as a reading of the text, not a ruling.
The amount test rarely holds a seller back. What hits your card is the full price of the USDT you sold, not your margin. Spread 1,020,000 tenge over three months and it comes to 340,000 a month.
And the account type fits too. Most people take P2P payments on a personal Kaspi Gold card or something like it.
The flip side is worth knowing. If you only buy USDT and pay tenge out, or you sell to the same handful of people, you will struggle to reach the head count at all. The rule counts how many different people send you money, not how many trades you make.
After the bank reports you: the notice and the 30 working days
According to BES.media in April 2026, the tax authority sends a notice to your taxpayer account (Кабинет налогоплательщика), with a list of the incoming payments attached. Another deputy finance minister said the first notices would go out in May. The article gives 30 working days to respond and makes the point plainly: a notice is not an automatic fine.
There are two ways to answer it.
If the money is not business income, send an explanation with documents attached. The State Revenue Committee has long said that an explanation with nothing to back it up can be treated as a notice not acted on.
If some of it is income, declare it. For crypto sales that brings you back to the individual return; the Form 270.00 guide shows where sale proceeds go, and crypto tax in Kazakhstan covers how it is taxed.
We could not find the provision in the new Tax Code that says what happens if you ignore the notice. Under the old code, the State Revenue Committee said accounts of people who did not respond would have operations suspended. Either way, answering inside the deadline with paperwork beats waiting.
The workaround to avoid: spreading payments across family members' cards, or asking buyers to pay from someone else's account, to stay under 100. Letting another person's card take payments for you can fall under Article 232-1 of the Criminal Code (see the Article 232-1 guide), and it leaves several accounts each with a story that is harder to explain.
What your explanation has to match up
The question behind the notice is simple: why did more than a hundred people send you money? For a P2P seller, the strongest answer lines up each bank credit with a platform order.
- Your P2P order history. Date, amount and the buyer's verified name for each order. When those match the payer name and time on your bank statement, that credit is the price of coins you sold.
- Where the USDT came from. When and how you acquired what you sold, and what you paid. This shows whether you were selling your own holdings or buying and reselling, and you will need it for the tax calculation anyway. Exporting a Binance account statement for a bank is covered in proving the source of funds; the same file works here.
- A short covering letter. Say what you sold, on which platform, over what period, roughly how many orders, and how you think the proceeds should be classified. Do not claim anything your documents cannot show.
One caution belongs here, not in a footnote. Buying low and selling high to a stream of strangers, or changing tenge into USDT for other people as a service, may look like business to the tax authority and like unlicensed exchange to the regulator. We found no official position on how frequent personal P2P selling is classified for tax. If your activity is closer to a trade than to selling your own savings, read where unlicensed P2P becomes a crime and talk to a local tax adviser. Registering as a sole trader deals with the tax side; it does not give you an exchange licence.
BES.media also reports a fine of 15 monthly calculation indices for running an unregistered business, about 64,875 tenge at the 2026 rate of 4,325 tenge per index. We did not check that figure against the Code of Administrative Offences.
Counting your own senders before a notice arrives
You can test all three conditions yourself. Download the last three months of statements for the card you use for P2P and go month by month:
- How many different people paid in each month? Did any month pass 100?
- Did all three months pass it? One month below 100 breaks the «each of three months» condition.
- Is the three-month total above 1,020,000 tenge?
If the answer is yes three times, export the matching P2P order history now and keep it. If your platform account runs into trouble later, getting those records out becomes harder.
Questions
Do transfers from friends and family count towards the 100?
The order counts money from different people and does not sort it by purpose. Gifts, a group whip-round or a loan being repaid can all add to the count. If you are reported, those payments are explained the same way as anything else: transfer comments, messages, a written loan note.
I only buy USDT on P2P and never sell. Can I be reported?
Buying means tenge leaves your account; it does not add incoming payments. Since the rule looks only at how many different people pay you, buying alone will not reach the head count.
Will being reported get my card frozen?
The report itself does not freeze anything. Card freezes usually come from a bank's anti-money-laundering review or an order from law enforcement, which is a separate track (see the first 72 hours after a freeze). Under the old Tax Code, accounts were suspended when people ignored a tax notice, so answer within the deadline.
Where the rules and figures come from
Checked in October 2026. The Adilet page for Order No. 698 loads its text by script, so the wording was checked against a full republication on an accounting law site; Adilet's current text prevails if they differ.
- Order of the Minister of Finance No. 698 of 12 November 2025 Full text republished by Uchet.kzThe three conditions, quarterly reporting by the 15th, legal basis, in force 1 January 2026.
- Order of the Minister of Finance No. 323 of 29 March 2022 Full text republished by Uchet.kzThe old head-count-only test and annual reporting; marked as repealed by Order No. 698.
- Received a tax notice over transfers: what to do BES.media, 15 April 2026 (Russian)Notices via the taxpayer account, 30 working days, the two ways to respond, the 15-index fine.
- Ministry of Finance explains which transfers reach the tax office Bizmedia.kz, 8 April 2026 (Russian)The deputy minister's statement; first-quarter data due by 15 April.
- On acting on desk-audit notices CDB, republishing the State Revenue Committee, 2023 (Russian)Old Tax Code: explanations need documents; accounts suspended for no response.
- New monthly calculation index for 2026 approved Tengrinews, 26 November 2025 (Russian)2026 index of 4,325 tenge.
This explains public rules and reporting. It is not tax advice on your own situation.