New Counter-Obligations in the Agro-Industrial Sector: Who Will Be Affected by the Changes

The Ministry of Agriculture of Kazakhstan has updated the subsidy regulations for farmers and processors, introducing fundamental amendments to the rules of state support for livestock farming, crop production, and the processing sector. The key innovation is the formal закрепление of clear counter-obligation criteria: access to public funds is now directly linked to companies’ production performance.

Under the new rules, farmers operating in crop and livestock production must at a minimum maintain, and ideally increase, the gross value of their output in monetary terms compared to the previous year. For the processing sector, the requirements have been specified by product category: the obligation to maintain or increase production volumes applies to butter, hard cheeses, powdered milk, and wheat gluten. In addition, processing enterprises are now required to maintain or increase the volume of tax payments and their payroll fund over the two years preceding the submission of a subsidy application.

It is important to note that counter-obligation requirements will not apply to all entities immediately. At the current stage, they take effect only for agro-industrial entities whose total amount of state support across various programs exceeds 100 million tenge per year. However, this preferential threshold is temporary — starting from early 2029, the conditions will become mandatory for all subsidy recipients without exception, regardless of the size of payments.

To ensure an objective assessment of results, the ministry has introduced a calculation system based on data from the Bureau of National Statistics, using average nationwide prices for 2024 as the baseline. If official statistics for a specific product are unavailable, the authorities plan to rely on alternative market sources or calculate an average price based on data from five comparable producers.

A safeguard mechanism is also предусмотрена for force majeure circumstances. If production volumes decline due to drought, pest infestations, or livestock epidemics, sanctions will not be applied. In such cases, farms must upload supporting documents to the information system, including certificates from Kazhydromet or phytosanitary inspection reports. However, if obligations are breached without valid justification for two consecutive years, access to state subsidies will be suspended for one year, and for repeated violations — for two years. The new rules have already entered into force and effectively regulate sectoral relations retroactively from the beginning of 2025.