Dual citizenship in Kazakhstan: is there such a concept in 2026

What the law says: Article 3 and its consequences

Article 3 of the Law of the Republic of Kazakhstan “On Citizenship” of 1991, as amended, is unambiguous: a citizen of Kazakhstan cannot simultaneously be a citizen of another state. This is not a vague formulation - it is a strict norm.

What happens if a Kazakhstani citizen receives a foreign passport? By law, he automatically loses KZ citizenship from the moment he voluntarily acquires citizenship of a foreign state. No special court decision, no warnings - the loss occurs after the fact.

Over the years of practice, I have seen how this ruined the life plans of people who did not bother to understand the issue before submitting documents. A person invested in a citizenship program, received a passport - and suddenly found himself without a Kazakh one. This is a painful story that can be easily avoided with proper preparation.

De facto dual citizenship: how it works in practice

If the law is so strict, why do many Kazakhstanis still have two passports? The answer is simple: Kazakhstan does not have an automatic mechanism for tracking the fact of obtaining foreign citizenship.

A person receives, say, a passport from Malta or Montenegro. This information does not enter the Kazakh database - countries do not exchange such data in real time. At the same time, the Kazakh passport physically remains in your hands and continues to work.

De jure this is a violation of the law. In fact, millions of people live this way. I don't recommend this route for several reasons:

• When crossing the Kazakh border with a foreign passport, you may be checked
• When registering an inheritance or real estate transactions in KZ, the situation may come to light
• Changing the political situation or tightening control is a risk that is difficult to calculate

Legal vulnerability is a poor foundation for international mobility.

Why Kazakhstan does not introduce dual citizenship

The issue is periodically raised at the state level - especially in the context of attracting the Kazakh diaspora back. But every time the decision is postponed.

The position of the authorities is clear: dual citizenship creates difficulties with military duty, tax obligations and loyalty to the state. Kazakhstan is a country where these issues are felt especially acutely given its geopolitical situation.

Compare with its neighbors: Russia de jure also does not recognize dual citizenship (but de facto tolerates it for most countries), Kyrgyzstan recently introduced limited exceptions, Uzbekistan has the same tough position as Kazakhstan. The general trend in the region is a gradual softening, but Kazakhstan is not moving in this direction yet.

Oralman Program: Repatriation of Ethnic Kazakhs

This is the only special mechanism associated with KZ citizenship that is worth knowing about separately. Oralman (from Kazakh “returned”) - ethnic Kazakhs living abroad and wishing to return to their historical homeland.

A simplified procedure for obtaining Kazakh citizenship is provided for them: a shortened processing period, exemption from a number of requirements, and resettlement quotas. The program worked actively in the 1990-2000s, when hundreds of thousands of Kazakhs from Mongolia, China, Russia, and Uzbekistan moved to KZ.

Important: this is a mechanism for obtaining Kazakh citizenship, and not for maintaining two passports. When receiving KZ citizenship, Oralman is also obliged to renounce his previous one. There is no exception to the general rule here.

Main strategy: choose countries without requiring a waiver

This is where the real planning begins. If you want to have a second passport and keep the Kazakh one, you need to choose programs from countries that do not themselves require renunciation of previous citizenship upon naturalization.

There are many such countries. Fundamental point: Kazakh law speaks of “automatic loss” in case of “voluntary acquisition”. If the country where you are investing does not notify the Kazakh authorities and you yourself do not go to hand over your passport, legally the situation remains in a gray zone.

But there is also a purely legal way: first, officially renounce Kazakh citizenship, obtain a second passport, and then - if necessary - return through a repatriation program or standard naturalization. It's long, but legally flawless.

In my practice, there was a case when a client from Almaty did exactly this: he renounced KZ citizenship, received a Grenada passport (CBI program), then five years later, when the business situation changed, he again received Kazakh citizenship in the standard manner. Difficult - but clean.

Second passport programs that are suitable for KZ citizens

All major citizenship by investment (CBI) programs are open to Kazakh citizens who are ready to invest. Here are the current data for 2026:

None of these countries notify the state of previous citizenship or require the applicant to formally renounce. This does not exempt you from the requirements of Kazakhstan law - but the issue of notification remains on your side.

Residence permit and permanent residence as an alternative to a second passport

Not everyone needs a passport. Sometimes a residence permit or permanent residence is enough - this provides most of the practical advantages without the legal risks of KZ citizenship.

Greece residence permit (Golden Visa) from €400,000 for real estate - gives the right to live, work, travel throughout the EU. The passport remains Kazakh.

Permanent residence in Cyprus from €300,000 - lifelong, without residence requirement, includes the whole family. There is no conflict with the Kazakh citizenship law, because permanent residence is a resident status, not citizenship.

UAE Golden Visa for 10 years - from AED 2 million for real estate. A popular choice among Kazakh entrepreneurs precisely because it does not create issues with the KZ law.

I recommend this path to those who are not ready for the legal uncertainty surrounding a second passport.

Real risks with an undeclared second passport

Let's return to the de facto situation. Many people think: “No one will know.” I want you to understand when this might come to light:

• Crossing the KZ border - if you enter with a foreign passport, this is recorded. Then you present the Kazakh one - and questions arise.
• Notarial transactions in KZ - when checking documents, a notary or government agency may request confirmation of citizenship.
• Inheritance and will - upon assuming the rights of an heir, the citizenship status is checked.
• Sanctions checks - if you come to the attention of international compliance structures, the presence of several passports becomes visible.
• Divorce and division of property - during legal proceedings, documents are studied in detail.

I'm not exaggerating. Most people with two passports live for decades without problems. But there is a risk - and it is unpredictable.

How to officially renounce Kazakhstan citizenship

If you decide to go the pure route and get a second passport after officially renouncing KZ citizenship, here's what awaits you:

Release order: an application is submitted to the Ministry of Internal Affairs (through the Public Service Center or a consulate abroad), documents are attached (passport, certificate of no criminal record, certificate of no tax arrears), state duty is paid. The review period is up to 1 year.

Restrictions: You cannot renounce citizenship if you have open obligations to the KZ state - debts, criminal cases, uncompleted military service for men of military age.

After exit: you become a foreigner in Kazakhstan. The right to real estate is retained (with some restrictions on agricultural land), business activity is through a foreign person.

This decision requires careful planning - especially if you have assets and family in Kazakhstan.

The situation of the Kazakh diaspora abroad

A separate story is for Kazakhstanis who left a long time ago and have already naturalized in another country. Formally, they lost their KZ citizenship at the moment they received a foreign passport. But they have the Kazakh passport in their hands - and it is valid until it expires.

Using an expired or "lost" Kazakh passport to enter KZ is a separate legal issue. In fact, most border guards look at a valid passport, not citizenship history. But this is not legal protection.

For those who are already naturalized abroad and want to re-establish contact with KZ, there is a path through standard naturalization (5 years of permanent residence) or through the Oralman program (if there are Kazakh roots and meets the criteria).

Tax consequences of a second passport for KZ citizens

This is a question that has been heard more and more often lately - especially after the tightening of international tax controls.

Kazakhstan taxes the worldwide income of residents. Tax residency is determined primarily by residence (183 days per year), and not by citizenship. That is, even after receiving a second passport, if you continue to live in Kazakhstan, you remain a Kazakh tax resident.

On the other hand, if you move, it is important to correctly terminate your tax residency in KZ. This doesn't happen automatically. You need to deregister, close the individual entrepreneur/LLP, and notify the tax authority.

A number of Caribbean CBI programs are offered by countries with zero taxation of global income - Grenada, St. Kitts, Antigua. But this is only relevant if you actually change your tax residence, and not just keep your passport in a drawer.

I always advise clients to work out the tax part of the issue separately with a local tax consultant in KZ - before deciding on a second passport.

Comparison with CIS countries: who allows dual citizenship

It's helpful to understand the context. Here is a brief picture of the nearest neighbors:

Armenia and Georgia are countries where Kazakh citizens can obtain citizenship through naturalization without a formal conflict with the local laws of these countries. But the KZ law will still consider them to have lost their citizenship.

Common misconceptions about dual citizenship in KZ

Over 12 years of practice, I heard the same myths. I'll go over the main ones:

“As long as you don’t tell the authorities, everything is fine.” Legally, no. Loss of citizenship occurs automatically and not after notification. Ignorance or silence does not invalidate the rule of law.

“Kazakhstan will sign an agreement on dual citizenship with Russia.” This rumor has been circulating since the 1990s. There were negotiations, but no agreement was signed. There are no changes in 2026.

“Children born abroad automatically have both citizenships.” Partially true - by birth a child can receive both citizenships by right of blood. But upon reaching the age of majority (18 years old), a number of countries require a choice. There is no direct rule on forced choice in the Code, but legal uncertainty remains.

“A residence permit is the same as citizenship.” No. Residence permit and permanent residence - the status of a resident, not a citizen. They do not create a conflict with the KZ citizenship law.

How to choose the right path: a step-by-step approach

When a client from Kazakhstan comes to me with a request for a second passport, I start with four questions:

1. Are you ready to officially lose your KZ citizenship? If yes, complete freedom of choice of program opens up. If not, we work within the framework of a residence permit/permanent residence permit or a gray zone (with a full understanding of the risks).
2. Why do you need a second passport? For mobility (a residence permit is enough), for business (you need a passport with the necessary contracts), for tax planning (you need a real change of residence).
3. What's the budget? From $90,000 (Nauru) to $300,000+ (Caribbean premium programs).
4. Is there a family in the program? Most CBI programs include a spouse and children, and some include parents. This greatly affects the final amount.

Once these questions are answered, the best path usually becomes clear. There is no universal solution - it is always individual.

Bottom line: what should a citizen of Kazakhstan do in 2026?

Let me summarize practically:

• Dual citizenship in KZ is legally impossible - the law does not provide exceptions
• The de facto situation is common, but carries legal risks
• The legal path to a second passport is through an official exit from KZ citizenship, or through programs of countries that do not require renunciation of the previous one (with the acceptance of legal uncertainty on the KZ side)
• Residence permit and permanent residence are a clean alternative that solves most practical problems without conflict with the law
• Always consider the tax side separately

If you are at the decision-making stage, I recommend starting with a consultation, where we will analyze exactly your situation: citizenship, assets, goals and budget. Only then will the picture become complete.