Changes have been made to the Rules for the Procurement of Medicines and Medical Devices

By the Order No. 172 of the Minister of Health of the Republic of Kazakhstan (“Kazakhstan”) dated December 25, 2025 (“Order No. 172”) amendments have been made to the Rules for Organizing and Executing the Procurement of Medicines, Medical Devices (“MD”) and Specialized Therapeutic Products within the Framework of the Guaranteed Volume of Free Medical Care (“GVFMC”),

Additional Volume of Medical Care for Persons Held in Pre-Trial Detention Facilities and Institutions of the Penal (Penitentiary) System, at the Expense of Budgetary Funds and/or in the Compulsory Social Health Insurance system (“OSHI”), Pharmaceutical Services (the “Procurement Rules”).

The amendments concern the introduction of a Register of Kazakhstani Manufacturers, as well as the regulation of procurement based on an investment agreement.

The changes include the following:

• Replacement of the term “Domestic Manufacturer” with “Kazakhstani Manufacturer” throughout the text of the Procurement Rules, and the introduction of a requirement to be included in the Register of Kazakhstani Manufacturers instead of providing a “CT-KZ” certificate;
• Purchasing from a single source by a Single Distributor will be carried out through a web portal (previously – “including through a web portal”);
• The introduction of a provision stating that the procurement of Medicines and/or Medical Supplies from a single source shall be carried out by directly concluding a supply agreement with a supplier that has entered into an Investment Agreement for the production of Medicines and/or Medical Supplies in accordance with Article 295-2 of the Entrepreneurial Code of Kazakhstan, in the manner prescribed in Chapter 9-1, Section 3 of the Procurement Rules;
• The introduction of additional conditions for concluding an addendum to a long-term contract for the supply of Medicines and/or MD aimed at the creation and/or modernization of production facilities, namely: the requirement that the supplier be included in the Register of Kazakhstani Manufacturers, as well as the availability of a maximum price for the trade name of the Medicine and/or MD;
• Chapter 12 “Purchase of Medical Equipment by the Lessor” of the Procurement Rules has been amended to include a provision stating that, when purchasing medical equipment included in the Single Distributor list under financial leasing arrangements, the lessor, following the notification procedure specified in paragraph 445-4 of the Procurement Rules, shall, within 20 (twenty) business days, conclude a financial leasing agreement with healthcare entities and a supplier that is a Kazakhstani manufacturer, in the form determined by the lessor;
• Amendments have been made to the Standard Supply Agreement (template) between the Single Distributor and the Supplier, approved by Appendix 17 to the Procurement Rules. In particular, Clause 82 of the Standard Agreement has been supplemented with a provision stating that, where a supply agreement for Medicines and/or MD manufactured in Kazakhstan is concluded with a potential supplier that has entered into an Investment Agreement, the agreement shall enter into force on the date of signature by the parties and shall remain valid for 10 (ten) years from the date of delivery of the first batch of goods for each item, with the possibility of extension for a further 3 (three) years;
• Chapter 9-1, “Procedure for the Procurement of Medicines and/or Medical Supplies from Suppliers Who Have Entered into an Investment Agreement for the Production of Medicines and/or Medical Supplies,” has been added. Under this chapter, the procurement of Medicines and/or Medical Supplies produced in Kazakhstan shall be carried out from a single source by directly concluding a supply agreement, in a standard form (template), with a supplier that has entered into an Investment Agreement in accordance with Article 295-2 of the Entrepreneurial Code of Kazakhstan. The supply agreement for Medicines and/or Medical Supplies produced by a Kazakhstani manufacturer shall be concluded for a period of 10 (ten) years, with the possibility of extension for a further 3 (three) years, in accordance with paragraph 2 of Chapter 6, Section 3 of the Procurement Rules. An addendum to the supply agreement shall be concluded for each financial year, except for the first year of procurement.

Order No. 172 was published on January 5, 2026 and entered into force on January 16, 2026.

Contacts:

	Zafar Vakhidov   Partner, Vakhidov & Partners Kazakhstan/Uzbekistan [email protected]
	Saltanat Zhakhina   Associate, Vakhidov & Partners Kazakhstan [email protected]