In practice, companies often operate in multiple regions of Kazakhstan. Employers may send employees from one project to another under internal business travel and within the scope of the employment contract. A common question arises: is it permitted to reassign foreign workers between regions and what are the legal requirements?
According to the current Regulations, the work permit is issued by the local executive body of the region where the foreigner will perform their work. For example, if the LLP is registered in Almaty but the work will be performed at a project site in Atyrau Region, the employer must apply for the permit from the Department of Employment Coordination and Social Programs in Atyrau. The issued permit will be valid only in Atyrau Region, and the worker can legally perform duties there.
The regulations do allow for business trips to other regions, but the total duration of such assignments must not exceed 90 calendar days per calendar year.
If the business trip is expected to exceed 90 days, we recommend obtaining an additional work permit in the region of assignment in advance. The law does not prohibit obtaining a second permit. Exceeding the 90-day limit may result in penalties:
• Small businesses: 100 MCI
• Medium businesses: 200 MCI
• Large businesses: 700 MCI
Moreover, clause 27 of the Regulations states that if a foreign worker is found to be working without a valid permit (i.e., in another region), the employer will be barred from obtaining work permits for 12 months — effectively placed on a “blacklist”.