1. Does the number of contractors matter
No. Neither the Tax Code nor the Labour Code links risk to the number of contractors. Since 8 June 2026, under paragraph 1-1 of Article 26 of the Labour Code, a civil-law contract with an individual is treated as an employment contract if it contains at least one sign of employment. This is assessed for each contract separately, whether you have one contractor, five or five hundred.
2. What the self-employed regime is for
In February 2026 the State Revenue Committee explained that the special tax regime for the self-employed was introduced to legalise the activity of people with small incomes who work occasionally. In March 2026 the Committee said it sees cases where employees are moved off staff and registered as self-employed, and that it analyses them.
The self-employed regime does not replace an employment contract. If a person in substance works for you as an employee, they need an employment contract, however many such people there are.
3. Checklist for each contractor
Go through these questions for each contractor:
- Activity. Is their work on the list under Resolution No. 994? You can check it in the services directory.
- Status. Are they a citizen of Kazakhstan or a kandas, not registered as an individual entrepreneur, not hiring employees, and within the income limit (Article 718 of the Tax Code)?
- Position. Do they work in a position or profession within your structure? That is a sign of employment.
- Internal rules. Do they follow your schedule and internal rules? That is a sign of employment.
- Pay. Do they in substance receive wages for work — regular pay for time worked rather than for an accepted result? That is a sign of employment.
- One customer. Do they work permanently only for you? The State Revenue Committee has warned that permanently serving one party will raise questions about employment.
- Former employee. Do they do the same work they did on your staff? The Committee has said directly that such cases raise questions.
4. When an employment contract is needed
If the answer to at least one of questions 3–5 is “yes”, this is employment. Sign an employment contract and register it in the unified system for recording employment contracts. If the answer to question 6 or 7 is “yes”, assess the relationship especially carefully: an employment contract is likely needed.
The self-employed regime fits when a person provides specific services from the list, decides whether to take the work, is paid for the result and can work with different customers.
5. Which documents you need
- a contract whose subject is a specific result, not a position;
- a task with volume, deadline and price;
- an act for each completed task;
- the self-employed person’s receipt from e-Salyq Business;
- payment after the result is accepted.
6. What mistakes lead to
If the relationship is recognised as employment, the company faces an administrative fine, additional taxes and social payments for past periods within the limitation period, and obligations to the worker: paid leave or compensation for it and other employment guarantees. More in the articles “GPH ban from 8 June 2026” and “What incorrect work with the self-employed can cost you”.
Official sources: Labour Code of Kazakhstan, Articles 26 and 27 (adilet.zan.kz), Tax Code, Article 718 (adilet.zan.kz), Government Resolution No. 994 (adilet.zan.kz). The State Revenue Committee’s position is based on publications by Kazinform (09.02.2026) and Forbes Kazakhstan (05.03.2026). This material is for reference and is not legal advice.