Three Different Seventy Percents
Published 2026-08-28 · EuroQuest International
Quick summary
- What it is: the share of a subsoil user's workforce that has to be Kazakhstani, measured category by category rather than across the payroll as a whole.
- Two rulebooks, not one: the Code on Subsoil and Subsoil Use makes the minimum share a term of the contract itself. Migration law sets the ratios that decide whether a work permit is issued at all.
- Four categories: heads and deputies, heads of structural subdivisions, specialists, and skilled workers. Each is tested separately.
- The thresholds: at least 70 percent citizens in categories one and two, at least 90 percent in categories three and four, and a separate 70 percent floor for specialists and skilled workers on complex hydrocarbon projects.
- The cap people miss: managers and specialists brought in under an intra-corporate transfer may not exceed 50 percent of that category.
An operator staffing a field in Kazakhstan will meet the number seventy percent three separate times, in three separate instruments, meaning three separate things. One is a condition of getting a work permit. One is a minimum written into a subsoil contract. One is not about people at all and refers to purchased works and services. Confusing them is the single most common error in this subject, and it is expensive, because the tests are applied independently and failing any one of them is enough.
This guide sets out what in-country value in personnel actually is under Kazakh law, which instrument does what, how the four worker categories work, where each threshold applies, and what the obligation looks like from inside a staffing plan. It sits alongside our guide to how the one percent training rule works in Kazakhstan, which covers the money side of the same statutory package.
On this page
- What in-country value in personnel actually means
- The four worker categories
- The three seventy percents, kept apart
- The intra-corporate transfer cap
- What this looks like inside a staffing plan
- Frequently asked questions
What In-Country Value in Personnel Actually Means
In-country value in personnel is the proportion of a workforce made up of Kazakhstani citizens, expressed as a minimum the employer has to reach. It is a staffing obligation, and it is distinct from the separate duties to spend on training and to buy locally. What makes it awkward in practice is that it is not created by a single law.
Two Rulebooks, Not One
The first is the Code on Subsoil and Subsoil Use. It obliges subsoil users conducting exploration or extraction operations to give preference to Kazakhstani personnel, and it makes the minimum share of in-country value in personnel a mandatory term of the subsoil contract itself, listed among the obligations the contract has to contain. That is a contractual commitment, owed to the state as counterparty, and it is reported on as such.
The second is migration law and the rules made under it. These do not care what the contract says. They set conditions that an employer has to satisfy before a local executive body will issue or extend a permit to employ a foreign national. Fail those, and the permit does not come, whatever commitments sit in the subsoil contract. The United States Department of State describes the effect plainly in its 2025 investment climate statement: foreign workers, except for chief executives and the deputies of fully foreign-owned companies, must obtain work permits, and the government has made it a priority to see Kazakhstani citizens well represented in foreign enterprise workforces, including in managerial and executive ranks.
Because the two operate independently, an operator can be fully compliant with its contract and still be unable to move a specialist into the country. Understanding both is squarely a legal and regulatory frameworks problem before it is a human resources one.
Measured by Category, Not Across the Payroll
The single most consequential design feature is that the tests are applied to each worker category separately. There is no netting. An operator that is comfortably above the threshold among skilled workers cannot use that surplus to cover a shortfall among specialists. Each category has to stand on its own, which is why staffing plans that look healthy in aggregate fail on inspection.
One carve-out is worth knowing. When local content in personnel is calculated, citizens of states party to the Treaty on the Eurasian Economic Union are not counted among foreign workers. That materially changes the arithmetic for operators whose regional talent pool sits inside that bloc, and it is a common source of confusion when a headcount that looks non-compliant on its face turns out not to be.
The Four Worker Categories
The permit rules define four categories, and every threshold in this subject is expressed against them. The definitions are precise, and they turn on qualification requirements set out in professional standards and the relevant qualification reference books rather than on job titles chosen by the employer.
| Category | Who it covers | Minimum Kazakhstani citizens for a permit |
|---|---|---|
| First | Heads and their deputies | At least 70 percent of payroll headcount across categories one and two together |
| Second | Heads of structural subdivisions meeting the qualification requirements | |
| Third | Specialists meeting the qualification requirements | At least 90 percent of payroll headcount across categories three and four together |
| Fourth | Skilled workers meeting the tariff and qualification requirements |
Two details in the rules change how the count is done. The headcount is the payroll list, and it takes into account workers of a sending party who are working under a contract for the provision of personnel. In other words, an operator cannot move people off its own payroll into a staffing company and improve its ratio, because those people are counted anyway. Service companies supplying crews therefore sit inside their client's compliance position, which is a point worth settling in the contract rather than discovering during a permit application.
The Three Seventy Percents, Kept Apart
Here is where care pays. Three separate provisions use the figure seventy percent, and they are not versions of one another.
Seventy Percent for Permits, Categories One and Two
Under the permit rules, a permit is issued or extended only where Kazakhstani citizens make up at least seventy percent of the payroll headcount in categories one and two. This is the management layer, and it is the migration-law test. It applies to employers generally, not only to subsoil users.
Seventy Percent for Complex Projects, Specialists and Skilled Workers
The Code sets a different floor. For a contract covering exploration and production, or production, of hydrocarbons on a complex project, the minimum in-country value in personnel for specialists and skilled workers must be at least seventy percent of the total number of personnel engaged in performing the contract, for the relevant category. Note the denominator. It is personnel engaged on that contract, not company payroll, and the truncated version of this rule that circulates without the denominator is not usable for planning.
Seventy Percent That Is Not About People
The third one is a trap. The Code also requires that in-country value in works and services purchased for subsoil operations be at least seventy percent of the total volume purchased during a calendar year. That is a procurement obligation with its own methodology, and it has nothing to do with staffing ratios. Reporting the two through the same figure, which happens more often than it should, produces a compliance position nobody can defend.
The Code also states that in-country value in personnel is calculated according to an approved methodology, so the ratio is not a matter of internal interpretation. Getting the measurement right is closer to a workforce data exercise than a policy one.
The Intra-Corporate Transfer Cap
Alongside the citizen ratios sits a separate limit that catches international operators in particular. Where chief executives, managers and specialists work in Kazakhstan under an intra-corporate transfer, their number must not exceed fifty percent of the total number of chief executives, managers and specialists in each relevant category.
Three things follow. The cap is per category, so it cannot be satisfied on a company-wide average. It is additional to the permit ratios rather than an alternative to them, so both tests apply at once. And it bites hardest at exactly the moment an operator wants to move experienced people in, which is early project phase. According to Kazakh Invest, the quota for attracting foreign labor is set by the authorized body to protect the domestic labor market, with permits issued by local executive bodies within that allocation, and permits issued for an intra-corporate transfer spanning more than one administrative-territorial unit are granted free of charge.
The quota itself is set annually as a percentage of the labor force. For 2026 it was fixed at 0.3 percent for permits issued by local executive bodies to employers, and 2.85 percent for attracting labor immigrants, following an amendment that took effect in May 2026. Those two streams are distinct, and the employer-permit stream is the one that governs bringing in an expatriate specialist. Keeping current with changes of this kind is ordinary labor law compliance work.
In practice
The Code sets out what conditions on in-country value in personnel take into account: the subsoil user's need for foreign or Kazakhstani personnel given its managerial and administrative requirements, whether qualified Kazakhstani personnel in the relevant category are available on the market, and phased training including internships, with the gradual replacement of foreign personnel by Kazakhstani personnel in leadership categories. That last limb is the one operators underinvest in, because it is the only one that changes the ratio permanently rather than managing around it.
What This Looks Like Inside a Staffing Plan
The obligation is not unusually onerous. It is unusually specific, and it fails on administration rather than on principle. The labor market it draws on is substantial: the Bureau of National Statistics recorded 9.4 million people employed across the economy in the second quarter of 2026, of whom 7.3 million worked for hire, or 77.2 percent of total employment. Those are whole-economy sample survey figures rather than sector ones, but they describe a formal labor market deep enough that a shortfall in a given category is usually a sourcing and development problem rather than an absolute scarcity.
The replacement limb is where the real movement happens, and it is the reason the training obligation and the personnel obligation are best planned together. A funded pipeline that moves Kazakhstani specialists into leadership categories over a contract's life is what turns compliance from an annual scramble into a position that holds. Structured succession planning does more for a ratio than any amount of reporting.
Checklist for a compliant staffing position
- Map every role to one of the four categories using the qualification requirements, not internal job titles.
- Count seconded and staffing-contract personnel inside the headcount, because the rules do.
- Run the permit ratios and the contractual minimum as two separate tests, and report them separately.
- Exclude Eurasian Economic Union nationals from the foreign worker count when calculating local content in personnel.
- Track the intra-corporate transfer cap per category, not across the company.
- Hold a dated replacement plan for leadership categories, since the Code expects phased training and gradual substitution.
Teams working through this material tend to do it alongside people facing the same rules in other jurisdictions, which is why the discussion travels well. EuroQuest runs energy and oil and gas management programs in Istanbul, which is the most practical hub for Caspian delegates, as well as Dubai, Kuala Lumpur, Amman, and Vienna. The technical roles most affected by these ratios are the ones covered in our guide to drilling manager training.
Frequently Asked Questions
What is in-country value in personnel in Kazakhstan?
It is the share of a subsoil user's workforce that must be Kazakhstani, measured by worker category rather than across the payroll as a whole. Two separate instruments govern it. The Code on Subsoil and Subsoil Use makes the minimum share a mandatory term of the subsoil contract itself and obliges subsoil users to give preference to Kazakhstani personnel. Migration law then sets the citizen ratios an employer has to satisfy before a local executive body will issue or extend a permit to bring in a foreign worker.
What are the four worker categories?
The permit rules define them as follows. The first category is heads and their deputies. The second is heads of structural subdivisions. The third is specialists who meet the qualification requirements set by professional standards. The fourth is skilled workers who meet the requirements of the unified tariff and qualification reference book. The categories matter because the thresholds are applied to each one separately, so an operator cannot offset a shortfall among specialists with a surplus among skilled workers.
How is the seventy percent figure applied?
Carefully, because three different seventy percent figures sit in this area of law and they are not interchangeable. Migration rules require at least seventy percent Kazakhstani citizens on the payroll headcount for categories one and two. The Subsoil Code sets a minimum in-country value in personnel of at least seventy percent for specialists and skilled workers on a complex-project hydrocarbon contract, measured against the total personnel engaged on that contract for the relevant category. A third seventy percent in the Code applies to works and services purchased, which is a procurement figure and has nothing to do with staffing.
Is there a limit on transferring managers in from the parent company?
Yes. Where managers and specialists work in Kazakhstan under an intra-corporate transfer, the Code caps them at no more than fifty percent of the total number of chief executives, managers and specialists in each relevant category. The cap is applied per category, which is the part most often missed. It sits alongside the citizen ratios rather than replacing them, so an operator has to satisfy both tests at once.
Who should attend training on this?
Human resources and mobility teams who prepare permit applications, local content and compliance managers who report contractual commitments, contract and procurement staff who negotiate subsoil contract terms, workforce planners who build replacement schedules, and the country and asset managers accountable for the whole obligation. Service companies supplying personnel under a staffing contract need it too, since their people are counted in the employer's headcount.
Get the Staffing Position Right Before the Permit Application
EuroQuest International delivers energy, oil and gas management programs covering local content obligations, workforce planning and replacement pipelines, contract terms and compliance reporting, in Istanbul, Dubai, Kuala Lumpur, Amman, and Vienna.
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