Enforcement of Foreign Court Judgments

Enforcement of a Foreign Court Judgment in Kazakhstan

Compulsory Enforcement of Judgments from the Russian Federation, CIS, EU, USA, and Arbitrations in the Republic of Kazakhstan (2026 Practice)

A sample petition for the recognition and enforcement of a Russian court judgment (or any other) can be found below in the text.

This publication has been prepared by Attorney Sagidanov S.S.

25+ years of practice, License No. 0000650 dated April 26, 2006.

Enforcement of Foreign Judicial Decisions • Exequatur • Private Bailiffs (ChSI) in Almaty • Astana • Entire Kazakhstan (including remote services).

If you have questions, please write to us on WhatsApp at +7-702-847-80-20. I will personally provide the translation and reply to you in your language via chat.

"To speak bluntly: having a final judgment from a court in the Russian Federation, Belarus, or any other country in your hands is only 50% of the success. On its own, a foreign judgment—just like a foreign writ of execution—holds no legal force within the territory of Kazakhstan.

You cannot simply take these documents to a bailiff, block the debtor’s Kaspi accounts, or seize their property in the Republic of Kazakhstan. For our system, it is merely a document that requires legalization.

To trigger the actual recovery mechanism, you must go through the procedure of 'exequatur'—the issuance of a Kazakhstan court ruling on the recognition and compulsory enforcement of the act.

And this is where the main trap lies: according to statistics, 70–80% of recognition denials are not due to the merits of the dispute, but due to fatal procedural errors made at the stage of filing the petition or drafting the documents. In this field, the law does not give a second chance: if the court issues a final denial due to improper preparation, it becomes legally impossible to recover the debt in Kazakhstan."

The fact is that, in practice, the enforcement of a foreign judicial act in Kazakhstan is not a formal transfer of documents, but a two-stage legal marathon.

The first stage is the "exequatur" procedure in a court of the Republic of Kazakhstan. At this stage, the court does not retry your dispute but acts as a "customs officer," strictly verifying: did the foreign court have jurisdiction? Was the debtor properly notified (according to the rules of international conventions, not just by regular mail)? Has the decision entered into legal force, and does it contradict the public order of the Republic of Kazakhstan?

The second stage begins only after the Kazakhstan judge issues a ruling on recognition and grants a Kazakhstan writ of execution. Only with this document do you gain access to a powerful lever of compulsion: the work of Private Bailiffs (ChSI), blocking bank accounts, seizing commercial real estate, shares in Limited Liability Partnerships (LLP/ТОО), and imposing travel bans on the debtor.

It is important to understand: until you hold a writ of execution issued specifically by a Kazakhstan court, the recovery does not legally exist, and the debtor has full freedom to withdraw their assets.

According to the norms of the Civil Procedure Code of the Republic of Kazakhstan (Articles 501–503) and the specialized Law "On Enforcement Proceedings," the judicial system of Kazakhstan is open to the enforcement of acts issued abroad.

In the Republic of Kazakhstan, the following can be compulsorily enforced:

• Decisions of foreign state courts (both general jurisdiction and economic);
• Acts of international organizations;
• Awards of foreign arbitrations (tribunals).

However, it is vital to understand a critical nuance: the presence of the decision itself does not guarantee its recognition. The "legal bridge" for entering the legal field of the Republic of Kazakhstan is the presence of a legal basis.

These include either ratified international treaties (for example, the Minsk or Kishinev Conventions for CIS countries) or the principle of reciprocity. If your situation does not fall under a treaty, the attorney must prove to the court the existence of reciprocity between the countries. Without a clearly constructed legal justification, the court of the Republic of Kazakhstan will not even proceed to consider your petition on its merits, issuing a denial at the document review stage.

3 Legal Grounds for the Enforcement of a Foreign Judgment in the Republic of Kazakhstan

For a foreign judicial act to "come to life" in Kazakhstan, it must rely on one of three legal foundations. An error in choosing the ground is a guaranteed return of documents without the right to an error.

🔹 1. International Treaty or Convention (The Most Reliable Path)

This mechanism applies if a valid agreement exists between Kazakhstan and the country that issued the judgment. Most often, we work with judicial acts from Russia, Belarus, Uzbekistan, Kyrgyzstan, Armenia, Azerbaijan, and Tajikistan. In these cases, recovery relies on the "heavy artillery" of international law: the Minsk and Kishinev Conventions, as well as the 1992 Kyiv Agreement. This is why Russian court decisions are considered the most "enforceable" in Kazakhstan. But there is a nuance: even a minor deviation from the protocol (wrong stamp, lack of a certificate of finality according to the convention's form) turns the process into an endless cycle of correspondence with the courts.

🔹 2. National Legislation of the Republic of Kazakhstan (High-Risk Zone)

If there is no direct international treaty, the Civil Procedure Code of the Republic of Kazakhstan applies. Here, the procedure becomes significantly tougher. The Kazakhstan court scrutinizes under a microscope not only the judgment but the entire process of its issuance. Requirements for documents become critical: any inaccuracy in translation or the wording of the petition leads to an immediate denial. Here, the risk of losing increases by 60%, as the national law of the Republic of Kazakhstan protects its residents very carefully.

🔹 3. Principle of Reciprocity (The "High-Altitude" of Jurisprudence)

This is the only way to enforce judgments from the courts of the USA, Great Britain, Germany, France, Italy, the Netherlands, China, or India in Kazakhstan. Direct treaties with these countries are often non-existent, so the attorney must use the "principle of reciprocity."

⚠️ Reciprocity is not just a word. In practice, it is complex legal labor: we must prove to the Kazakhstan court that the foreign state would recognize our [Kazakhstan] decision in a similar situation. There is no automation or established practice here. The outcome of the case depends 90% on the depth of the legal argumentation provided by your attorney and the evidence presented. To enter such processes independently without specialized experience is to doom the case to failure in advance.

Enforcement of Russian Court Judgments in Kazakhstan: Analysis of Core Practice

Despite close economic ties and membership in the EAEU, a strict legal border exists between our countries. If you won a court case in Moscow, Novosibirsk, or any other Russian city, you have only completed half the task.

⚠️ IMPORTANT TO KNOW (Dispelling Illusions):

• ❌ A Russian Court Writ of Execution IS NOT valid in Kazakhstan. You cannot mail it directly to a Kazakhstan bailiff or bank—it will be returned without consideration.
• ❌ There is NO automatic enforcement. There is no "unified database" of writs. Every decision must cross the state border in a legal sense.

The Real Compulsory Recovery Algorithm (2026):

To turn a Russian judgment into real money in your account, you must follow a strictly defined path:

1.      Preparation of the Petition: This is the foundation. You must not simply ask to "recognize" but justify the legality of recovery through the prism of the Minsk or Kishinev Conventions.

2.      Filing in the Republic of Kazakhstan Court: It is vital not to err in jurisdiction (district or economic court at the debtor’s place of residence/registration or the location of their property).

3.      Review of the Case: The court verifies the integrity of the process: was the debtor notified according to the rules (via requests for legal assistance), and were the deadlines met?

4.      Obtaining the Ruling: The final act of the Republic of Kazakhstan court, which gives the "green light" to enforcement.

5.      Issuance of the Republic of Kazakhstan Writ of Execution: Only at this stage do you hold a document with power within Kazakhstan.

6.      Transfer to the Private Bailiff (ChSI): Search for accounts, seizure of property, and real recovery through a private bailiff.

📌 Remember: Any error in the first three steps—improperly certified copy of the judgment, absence of a certificate of finality, or an incorrectly drafted petition—leads to a final denial. You lose not only time and the state fee but the opportunity to recover the debt, as re-filing on the same grounds in the Republic of Kazakhstan is extremely difficult.

Which Court to File With in Kazakhstan: Subtleties of Jurisdiction

Determining the correct court is the first "filter" where foreign and out-of-town creditors stumble. In Kazakhstan, you cannot file a petition in any court convenient to you; the law strictly regulates where the case is heard.

How jurisdiction is determined (Art. 502 CPC RK):

The choice of court depends on a combination of three factors:

1.      Location (Registration) of the Debtor: For individuals, this is the address of permanent registration; for legal entities (LLP/ТОО, JSC/АО), it is the legal address specified in the certificate of state registration.

2.      Location of Property: If the exact address of the debtor is unknown, the petition may be filed at the location of their primary assets (real estate, warehouses, specialized machinery).

3.      Status of the Subject:

o    If the debtor is an individual, the case is heard in a District Court (general jurisdiction).

o    If the debtor is an individual entrepreneur or a company (LLP/ТОО, JSC/АО), the process takes place in the Specialized Inter-district Economic Court (SMES).

Geography of Recovery:

Most often, cases concentrate in the republic's business centers, where major businesses and assets are registered:

• Almaty and Astana—where up to 70% of all petitions regarding foreign judgments are heard.
• Shymkent, Karaganda, Atyrau—key industrial and logistics hubs.

❗ Critical Error: Filing a petition in violation of jurisdictional rules (for example, filing in a regular district court instead of an economic court) leads to the immediate return of the application. At best, you lose a month on re-sending documents; at worst, the debtor will learn of your intentions and use that time to transfer property or withdraw funds from accounts.

Documents for the Recognition and Enforcement of a Foreign Judgment

Standard Checklist (may vary by convention):

• Decision of the foreign court;
• Confirmation of entry into legal force;
• Evidence of proper notification of the parties;
• Translation into Russian or Kazakh;
• Apostille or legalization (if required);
• Petition;
• Power of attorney.

📌 Attention: In 9 out of 10 denials, the problem is not the court decision, but the documents.

Why Independent Filing is the Most Expensive Path

Many creditors try to save on an attorney, viewing the recognition procedure as a simple formality. In practice, such "savings" result in the total loss of the opportunity to return money. As an attorney, I regularly encounter the consequences of self-activity when clients come to me to fix a situation that has already reached a dead end.

Typical errors that "kill" your case:

• Using "Universal Samples": Internet templates do not account for the specifics of your case, the current practice of the Supreme Court of the Republic of Kazakhstan for 2026, and the requirements of specific international conventions.
• Wrong Choice of Legal Basis: Filing via the CPC where the Kishinev Convention should have been used is a guaranteed return of documents.
• Jurisdictional Errors: Wasting months on the transfer of cases between courts of different cities and levels.
• Formal Translation: A translation of a judicial act made without considering the legal terminology of the Republic of Kazakhstan is often rejected by the court as improper.
• Premature Appeal to the ChSI: Attempting to start recovery without a Republic of Kazakhstan writ of execution is a waste of time that only signals the debtor to take action.

What happens after the first denial?

The main danger is not just the loss of the state fee. As soon as you file an incorrect petition:

1.      The debtor learns of your intentions. Upon receiving a court notice, they understand you have started the legalization process.

2.      Assets are withdrawn. While you fix errors and re-submit documents, LLP accounts are emptied, and property is transferred to affiliated persons.

3.      Blocking of Rights. Re-filing a petition on the same grounds after a refusal ruling enters into force in the Republic of Kazakhstan is legally impossible.

⚠️ IMPORTANT: Stop and verify your documents

If you are planning to file a petition independently right now, using downloaded templates, or have not conducted a deep audit of the statute of limitations, jurisdiction, and legal basis—you are in a critical risk zone.

Remember: in matters of recognizing foreign judgments, you essentially have only one attempt. Correcting procedural errors and restoring deadlines after a denial is often impossible, even for the most experienced attorney.

Do not risk your recovery. A single professional analysis of documents before filing in court costs dozens of times less than losing the entire debt amount due to a formal error.

How I Work: From Legal Analysis to Real Money

My task as an attorney is not simply to "hand papers to the office," but to ensure your decision passes through all the legal filters of Kazakhstan's judicial system.

Comprehensive approach of Attorney Sagidanov S.S.:

• Preliminary Audit: I evaluate the prospects of recognition before the state fee is paid and the petition is filed. If there are "landmines" in the case (errors in notification or deadlines), you will know immediately.
• Strategy Selection: I choose the correct legal basis (Minsk/Kishinev Conventions, CPC, or the principle of reciprocity) depending on the country of origin and the category of the dispute.
• Local Adaptation: I form a legal position considering the practice of the specific regional court (Almaty, Astana, etc.).
• Control of Execution: I do not abandon the case after receiving the paperwork. Мое accompaniment lasts until the moment of real recovery through verified Private Bailiffs (ChSI).

📍 Geography: Working throughout Kazakhstan (Almaty, Astana, Shymkent, Karaganda, etc.).

📞 Format: Consultations and case management are possible remotely. You do not need to fly to Kazakhstan—I will represent your interests via Power of Attorney.

🕒 Urgency: If the debtor has begun withdrawing assets—such cases are accepted with priority.

Conclusion: Price of an Error vs. Result

The enforcement of a foreign judgment in Kazakhstan in 2026 is a complex procedure with a high price for a formal error. One wrong step turns a court case won in another country into a useless folder of documents.

If your goal is the actual receipt of funds rather than a formal refusal on "procedural grounds," then independent experiments with the CPC of the Republic of Kazakhstan are the riskiest and most expensive path.

🚀 The First Step to Recovery

Don’t guess whether the court will accept your decision. Get a brief expert analysis of your documents before filing. Often, a 15-minute conversation decides the outcome of a case on which you have spent years abroad.

👉 To check a foreign court decision before filing, write to WhatsApp +7-702-847-80-20

FAQ Section: Frequently Asked Questions on the Enforcement of Foreign Judicial Decisions in Kazakhstan (2026)

1. How long does it take to enforce a Russian court decision in Kazakhstan and are there statutes of limitations?

The recognition process (judicial stage) takes from 15 to 45 days. Subsequent recovery through a Private Bailiff (ChSI) takes from 1 month to full execution. The statute of limitations is 3 years from the moment the foreign decision enters into force (Art. 5 of the Law "On Enforcement Proceedings" of the RK). If the deadline is missed, it is extremely difficult to restore it. In my practice, we launch the seizure process as quickly as possible so that the debtor does not have time to "clear out" their accounts.

👉 Write on WhatsApp +7-702-847-80-20 — I will check your deadlines; for foreign legal entities, the initial consultation is free.

2. Can a foreign decision be enforced remotely, without coming to Kazakhstan?

Yes. In 2026, the courts of the RK are fully digitized. Filing a petition through the "Judicial Cabinet," participating in hearings via video link, and interacting with bailiffs all happen online. But an important point: you must send original documents as attachments to the Court in Kazakhstan; furthermore, if you send them to the wrong Court, you will have to reclaim them and resubmit them to the court with proper jurisdiction.

I represent your interests by power of attorney in any city (Almaty, Astana, Shymkent, etc.). You do not need to spend money on flights. However, remember: any error in the electronic document package will lead to an automatic system rejection.

👉 Save on tickets and entrust the matter to a pro: +7-702-847-80-20.

3. What to do if the RK court refused to recognize the decision: can it be appealed?

A private complaint is filed against a refusal ruling within 10 working days. The main reasons for refusals are: lack of evidence of the debtor's notification or violation of the exclusive competence of the RK courts (for example, disputes over real estate in Kazakhstan). Re-filing on the same grounds is prohibited, so an appeal is your last chance.

👉 If you have already received a refusal — urgently send it to me for analysis on WhatsApp +7-702-847-80-20.

4. How much do an attorney's services cost and what is the amount of the state fee in 2026?

The state fee for filing a petition is 5 MRP. My fee is fixed in the contract and depends on the complexity of the case (country of origin, availability of the debtor's property). Independent filing seems cheaper, but an error in one document leads to the loss of the entire debt amount. I offer a "Turnkey" package: from document translation to receiving money in your account. An important point: if the recovery amount is significant, it is possible to pay the attorney's fees in tranches—part for the work and part for the result. This will significantly reduce your costs.

👉 Find out the exact calculation for your case: +7-702-847-80-20.

5. How to enforce a decision of a court of the USA, China, or EU countries if there is no international treaty?

This is the most difficult category of cases, where the attorney must prove to the court that the courts of the USA or Germany recognize our decisions. Without a deep evidentiary base, RK courts refuse in 90% of cases. I have successful experience in recognizing decisions not only from CIS countries but also from the far abroad.

👉 Check the prospects of your case under the principle of reciprocity: write on WhatsApp +7-702-847-80-20.

If you have questions, write on WhatsApp +7-702-847-80-20; I will provide the translation myself and answer you in your language in the correspondence.

Below is a sample petition for recognition and enforcement of a Russian Federation court decision in Kazakhstan (Current for 2026)

To the [Name of the Inter-district Economic Court / District Court]

(specify city: Almaty, Astana, Shymkent, etc.)

Petitioner: [Full Name / Organization Name]

IIN/BIN: [Fill in]

Address: [Legal/actual address]

WhatsApp/Tel: [For communication with the court]

Debtor: [Full Name / Organization Name]

IIN/BIN: [Fill in — critically important for the bailiff]

Address: [Place of registration or location of property in the RK]

PETITION

for recognition and authorization of compulsory enforcement of a foreign court decision

By the decision of [Exact name of the Russian court] dated “” ________ 20__ in case No. [Case number], the claims of [Name of Petitioner] against [Name of Debtor] regarding [Subject of dispute: debt recovery/alimony/damages] were satisfied in full (partially).

According to the specified decision, a sum in the amount of [Amount in the currency of the decision] and state fee expenses were recovered from the Debtor in favor of the Petitioner.

The decision entered into legal force on “” ________ 20__.

To date, the court decision has not been voluntarily executed by the Debtor. On the territory of the Republic of Kazakhstan, there is property (funds) of the Debtor against which execution can be levied.

In accordance with Art. 501 of the CPC RK and the provisions of [specify: Minsk Convention of 1993 / Kishinev Convention of 2002 / Kyiv Agreement of 1992], decisions issued by the courts of member states are recognized and enforced on the territory of the Republic of Kazakhstan.

On the basis of the foregoing, guided by Art. 501–503 of the CPC RK,

I ASK THE COURT:

1.      To recognize and authorize compulsory enforcement on the territory of the Republic of Kazakhstan of the decision of [Name of the RF court] dated “_” ________ 20 in case No. [Case number].

2.      To issue a writ of execution for the compulsory enforcement of the specified decision.

Appendices (Critically important):

1.      A duly certified copy of the foreign court decision.

2.      An official document stating that the decision has entered into legal force (if this is not indicated in the text of the decision itself).

3.      A document confirming that the Debtor was timely and properly notified of the time and place of the case hearing in the RF court.

4.      A document on partial execution (if performed).

5.      Copies of the petition for the parties.

6.      Receipt for payment of the state fee.

Date: “___” ________ 2026

Signature: ___________ / [Full Name]

Why can't this sample be submitted "as is"?

I, Attorney Sagidanov S.S., intentionally leave the list of appendices open. There are more than 15 nuances under which the RK court will return this petition to you without consideration:

• Notification issue: A simple printout from the "Russian Post" website is not enough. The court will require proof of notification through justice authorities if provided for by an international treaty.
• Currency control: How to correctly convert the amount into tenge on the date of filing or execution? An error in calculations will lead to a refusal by the bailiff.
• Legalization: Do you need to put an apostille on a court decision from the RF? (Spoiler: it depends on which convention you fall under).

My advice: Use this template to evaluate the structure, but contact a specialized attorney to fill in and check the document package. It is practically impossible to fix a "crooked" petition after registration in court.

If the matter is serious, trust a professional. I, Attorney Sagidanov Samat, with license No. 0000650 dated 04/26/2006, will help draw up a response that wins.

👉 Check your document: Write on WhatsApp 8-702-847-80-20 with a description of the case — get an analysis within a day. Don't wait until the court makes a decision without you!

I hope the article was useful. Share your experience in the comments — let's help each other.

© Attorney Sagidanov S.S. All rights reserved.