Kazakhstan, Early Parliamentary Elections, 23 August 2026: Needs Assessment Mission Report

Office for Democratic Institutions and Human Rights REPUBLIC OF KAZAKHSTAN EARLY PARLIAMENTARY ELECTIONS 23 August 2026 ODIHR NEEDS ASSESSMENT MISSION REPORT 15-19 June 2026 Warsaw 3 July 2026

TABLE OF CONTENTS I. INTRODUCTION .......................................................................................................... 1 II. EXECUTIVE SUMMARY ............................................................................................ 1 III. FINDINGS ....................................................................................................................... 4 A. B ACKGROUND AND POLITICAL CONTEXT ....................................................................... 4 B. L EGAL FRAMEWORK AND ELECTORAL SYSTEM .............................................................. 6 C. E LECTION ADMINISTRATION ........................................................................................... 8 D. V OTER REGISTRATION .................................................................................................... 9 E. C ANDIDATE REGISTRATION ............................................................................................ 9 F. E LECTION CAMPAIGN ................................................................................................... 10 G. C AMPAIGN FINANCE ..................................................................................................... 12 H. M EDIA ENVIRONMENT .................................................................................................. 13 I. E LECTORAL DISPUTE RESOLUTION ............................................................................... 14 J. C ITIZEN AND INTERNATIONAL OBSERVATION ............................................................... 15 IV. CONCLUSIONS AND RECOMMENDATION ........................................................ 15 ANNEX: LIST OF MEETINGS ........................................................................................... 16

REPUBLIC OF KAZAKHSTAN EARLY PARLIAMENTARY ELECTIONS 23 August 2026 ODIHR Needs Assessment Mission Report I. INTRODUCTION In anticipation of the announcement of the parliamentary elections and of an invitation from the authorities of the Republic of Kazakhstan to observe the elections, and in accordance with its mandate, the OSCE Office for Democratic Institutions and Human Rights (ODIHR) undertook a Needs Assessment Mission (NAM) from 15 to 19 June. The ODIHR NAM included Mr Ulvi Akhundlu, ODIHR Deputy Head of the Election D epartment, and Dr Yelena Kovalyova, ODIHR Election Adviser. The purpose of the mission was to assess the pre-electoral environment and preparations for the elections. Based on this assessment, the NAM recommends whether to deploy an ODIHR observation activity for the upcoming elections , and if so, what type of activity best meets the identified needs. Meetings were held with officials from state institutions, representatives of the media, civil society, and the international community. A list of meetings is annexed to this report. ODIHR expresses its appreciation to the authorities of the Republic of Kazakhstan for their co- operation and for facilitating the deployment of the NAM at an early stage of the electoral process, before the formal announcement of the election date, allowing for timely preparations for an election observation activity. ODIHR would like to thank the Ministry of Foreign Affairs and its Permanent Delegation to the OSCE for their assistance and co-operation in organizing the visit. ODIHR would also like to thank all its interlocutors for taking the time to meet with the NAM and to share their views. II. EXECUTIVE SUMMARY The early parliamentary elections follow the 15 March referendum of the new Constitution that altered the state institutional structure, inter alia , by establishing a new unicameral parliament, the Kurultai. The new Constitution entered into force on 1 July 2026, triggering the dissolution of the current parliament, and far -reaching institutional changes. The pre- election environment is strongly influenced by the registration of a new political party, Adilet, and its swift merger with the ruling Amanat, rendering the new party the major contestant for the upcoming elections. The ODIHR NAM interlocutors stated that elections will be conducted in the context of general limitations on political participation, including reported constraints on the fundamental freedoms of association, peaceful assembly and expression, and removal of the possibility for independent candidates to stand for parliamentary contest. The parliamentary elections are primarily regulated by the 2026 Constitution, the 1995 Constitutional Law on Elections, last amended in June 2026 (the Election Law). A package of six constitutional laws developing and integrating the constitutional changes, including amendments to the Election Law, was adopted in June and most of them enter ed into force on 1 July. The amendments to the Election Law introduced the proportional electoral system for the parliamentary elections, extended candidate eligibility limitations, adjusted nomination and some campaign rules, increased campaign expenditure ceiling, prohibited in- kind donations, introduced new eligibility criteria for election commissioners, expanded the prohibition of foreign financing to all election- related activities,

Republic of Kazakhstan Page: 2 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report including, as interpreted by authorities, election observation activities. The amendments did not address prior ODIHR recommendations. Most ODIHR NAM interlocutors stated that the constitutional laws and amendments were developed by the respective institutions in an expedited manner, with limited or no transparency or public discussion. The 145- member unicameral Kurultai is elected for a five- year term under proportional electoral system from closed party lists from a single nationwide constituency. The constitutional review removed the majoritarian component that allowed individual candidates to run, which had been introduced in 2022 in line with international standards. The mandate of elected MPs is withdrawn in case they lose their political party membership. The elections will be administered by three-tier hierarchical system of election commissions, including the Central Election Commission (CEC), territorial and precinct commissions (TECs and PECs). No ODIHR NAM interlocutors raised concerns about the capacity of the election administration to administer the technical aspects of the electoral process. The CEC was appointed by the President and both chambers of the outgoing parliament. Under the 2026 legal amendments, the president will appoint the entire CEC composition, subject to the Kurultai ’s approval, to be implemented after the upcoming elections. The appointment mechanism of the TECs and PECs will also change. The 2026 legal amendments eliminated the eligibility to work in election management bodies for those sentenced for corruption crimes or nominated by organizations with foreign financing. The CEC informed the ODIHR NAM that all lower-level commissions are in place and ready for the process. It has developed a programme to train and test election commissions on the new election legislation, is taking measures to facilitate the participation of persons with disabilities and is implementing initiatives to engage young voters. The CEC also noted that all sessions are broadcast online, with regular press briefings with questions and answers sessions for the media. The right to vote is granted to citizens at the age of 18. Those declared legally incapable by court, including based on intellectual or psychosocial disability, and those serving a prison sentence, regardless of the gravity of the crime, are disenfranchised. Voter registration is passive and is based on the permanent residency. As of January, the voter register included 12.5 million voters; this data constitutes the basis for the voter list, and is being updated to reflect migration- induced adjustments and other voters’ requests. The CEC plans a large-scale information campaign for voter lists scrutiny. Voters can be added to a supplementary voter list on the election day without judicial or administrative oversight, provided they prove their residence within the precinct, despite previous ODIHR recommendations to discontinue this practice. The right to stand for parliamentary elections is granted to eligible voters aged 25 or older. Contrary to international standards and prior ODIHR recommendations, the 2026 Constitution maintains the 10-year residency requirement for candidacy. The Election Law stipulates disenfranchisement for any unexpunged criminal record, regardless of the crime committed, and for any corruption- related crimes and offences. In line with the 2026 Election Law amendments, independent candidates are not eligible. Candidates can be nominated only by registered political parties from among their members. The law provides for a cumulative minimum 30 per cent quota for women, youth and persons with disabilities in candidate lists , and does not provide any candidates placement requirements, which the political parties determine independently. Women remain under-represented in political and public life, with 17 out of 93 seats in the Mazhilis (18 per cent) and 3 out of 25 the government posts; none of the 20 Akims (governors of regions ) are women. The UN Committee on the Elimination of Discrimination against Women has previously expressed concern about the low representation of women in decision- making positions, as well as

Republic of Kazakhstan Page: 3 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report about discriminatory gender stereotypes hindering the participation of women in political and public life. Election campaign starts upon candidate registration and ends one day before the elections. The right is guaranteed to citizens and public associations at meetings, rallies, citizens’ gatherings and in the media, including online. Political programmes and campaign messages with false information, discriminating against different groups, calls for a violent change of the constitutional and public order, and war are prohibited. The law also prohibits misuse of office and administrative resources, and vote buying. The 2026 legal amendments prohibit any participation or input of foreigners and foreign funding in any electoral activities. The political parties ODIHR NAM met with stated complete readiness for the forthcoming campaign. Most plan campaign activities aiming to ensure large-scale grassroots outreach, with door-to-door canvassing and cultural events in the regions, and plan to rely on social networks to promote their programmes. All of them declared support to the President’s political programme. The Election Law amendments increased the campaign fund amounts and contribution limits. Parliamentary election campaigns can be financed from electoral funds created by the political parties nominating candidate lists; the Election Law prohibits individual electoral funds. Electoral funds can be constituted from political party and candidate’s personal contributions, and donations from Kazakh individuals and legal entities. There is a list of prohibited donors. The 2023 Election Law amendments eliminated political parties’ obligation to report on campaign financing. The CEC is entitled to control the use of campaign funds, and will receive the financial data from banks; the Law does not regulate the scope of oversight and control. The CEC will publish the total expenditure for election campaigns within ten working days after election results publication. The media environment is strongly influenced by the state dominance in the media market, through ownership and budgetary subsidies. Denials of journalistic accreditations, deregistration of media and content removals are frequent. Television remains the primary source of political information, particularly in rural areas. The internet hosts a larger share of the critical public debate, but, according to ODIHR NAM interlocutors, it is also affected by state control and sanctions, including blocking of critical websites and requests to remove content. The Election Law requires objective coverage of election campaigns and equal access and conditions for contestants in the media, and lists topics that cannot be subject of public campaign discourse. Broadcasting campaign materials in news and analytical programmes is prohibited. The Election Law prescribes registration with the CEC for media outlets to cover the election campaign and publish or broadcast political advertising. Decisions, actions and inactions of election commissions are subject to hierarchical review by superior election commissions or courts. The legal standing to challenge decisions and actions of the election administration is granted to citizens and registered public associations, while electoral violations can be contested by citizens, other participants and election commissions. The law provides for expedited deadlines for electoral-related disputes. The Constitutional Court examines the correctness and constitutionality of the electoral process, if requested by the president, the prime minister or one fifth of all members of the Kurultai within ten days after the determination of the election results. The Election Law provides for observation by representatives of registered public associations and international observers, and together with CEC resolutions regulates accreditation procedures, as well as the status and conduct of observers. Only associations registered to conduct election observation as a statutory activity are allowed. Several citizen observer groups informed the ODIHR NAM that they struggled to plan observation activities for the upcoming elections due to lack of financing, pressure from authorities and uncertainty related to eligibility to observe for organisations with

Republic of Kazakhstan Page: 4 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report foreign funding. The authorities commented to ODIHR NAM that the changes to the Election Law effectively exclude all CSOs with foreign funding from election observation activities in Kazakhstan. ODIHR NAM interlocutors expressed uniform appreciation of the potential added value and necessity of an ODIHR observation activity for the anticipated elections. Most interlocutors highlighted the benefit of an independent assessment, including in the context of recent election-related changes and the legislative revision. Interlocutors underlined that the legal framework for elections, the campaign and its coverage in the media, respect for fundamental freedoms, and election day procedures, would merit particular attention in the context of a potential ODIHR observation activity. Based on the findings of this report, the ODIHR NAM recommends the deployment of an Election Observation Mission (EOM) for the upcoming early parliamentary elections. In addition to a core team of analysts, ODIHR will request the secondment by OSCE participating States of 30 long- term observers to follow the electoral process countrywide, as well as 300 short-term observers to follow election day procedures. In line with ODIHR’s standard methodology, the EOM will include a media monitoring component. III. FINDINGS A. B ACKGROUND AND POLITICAL CONTEXT The early parliamentary elections follow the 15 March referendum on the new Constitution that altered the state institutional structure, inter alia , by establishing a new unicameral parliament, the Kurultai. The constitutional revision subject to a referendum was initiated by President Kassym - Jomart Tokayev in 2025, as the continuation of the 2022 reform, which also entailed a referendum and early presidential and parliamentary elections. The stated aim of the new constitutional revision was modernization and optimization of governance to support the country’s development in the digital age. 1 The new Constitution entered into force on 1 July 2026, 2 triggering the dissolution of the current parliament, the announcement by the President of parliamentary elections on 1 July to be conducted on 23 August 2026, and far -reaching institutional changes. 3 In the absence of parliamentary continuity, from 1 July to the first Kurultai ’s session there will be no legislative 1 See the 2025 presidential address presenting the initial concept for the parliamentary reform, which explained that the second parliamentary chamber, the Senate, needed to be abolished as it “accomplished its historical role”. Consequently, the president, several politicians and members of the Working Group explained the need for a new Constitution by “a broad grassroots demand for a fundamental review ”. Other institutional changes under the new Constitution include abolition of the parliamentary majoritarian component, reintroduction of vice-presidency, and a new consultative body with legislative initiative. The presidency gains wider entitlements for institutional appointments and parliamentary dissolution in case of repeated dissent, and temporary, effectively unlimited unilateral legislative powers between the dissolution of parliament and election of a new one. The Constitution does not recognise the priority of international law, and prescribes that decisions of international organisations shall not be implemented if the Constitutional Court considers them unconstitutional. 2 According to the official results, the 15 March referendum was supported by over 87 per cent of some 73 per cent of voters who participated in the referendum. See the Central Referendum Commission’s Resolution No. 12/24 of 17 March 2026 ‘On Voting Results at the Republican Referendum of 15 March 2026’. 3 The 2026 Constitution prescribes, inter alia, the vice-president, the Constitutional Court, the Central Election Commission shall be appointed within two months after the new parliament’s first session, and the chairpersons of the Supreme Court, of the Supreme Judicial Council, of the National Security Committee and of the National Bank, the Prosecutor General and the Ombudsman by the end of August. See the President’s Decree No. 1338 of 1 July 2026 announcing the elections to be held on 23 August.

Republic of Kazakhstan Page: 5 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report body. 4 On 17 March, the president launched legislative process to regulate the constitutional novelties and harmonise the legal framework. 5 Some ODIHR NAM interlocutors stated that elections will be conducted in the context of general limitations on political participation, enabled through constraints on the fundamental freedoms of association, peaceful assembly and expression. 6 They also expressed concerns about what they described as a growing intolerance of criticism by the authorities, resulting in increasing pressure and sanctions. According to these interlocutors, this has contributed to a greater caution among civil society actors, including self-censorship and reduced civic participation. They further referred to a sense of uncertainty following recent legal changes and official narrative that some perceived as intimidating and signaling of potential further restrictions. 7 ODIHR NAM interlocutors noted that no genuine opposition parties are registered, independent civil society organisations and media workers face pressure, administrative hurdles and stigmatization . 8 The pre-election environment is strongly influenced by the registration of a new political party, Adilet , and its swift merger with the ruling Amanat, rendering the new party the major contestant for the upcoming elections. 9 Some ODIHR NAM interlocutors questioned the potential implications of the Amanat’s reorganization and its eventual deregistration for the composition and stability of local assemblies, many of whose members are affiliated with Amanat , and considered that these developments could increase the likelihood of early local elections . Another significant political 4 The 2026 Constitution entitles the president to adopt decrees with the force of constitutional laws in the absence of the parliament, but this is specifically prescribed for cases of early termination of powers of the Kurultai , and thus should not be applicable for the period before the first elections of the Kurultai , although no official interpretation of the norm has been provided. 5 The decree tasked various authorities, including the government, central and local state institutions, with harmonizing the relevant legislation, and distributed the drafting of the new constitutional laws to regulate the new institutional design among the presidential administration for the laws ‘ On the President of the Republic of Kazakhstan’, ‘On Kurultai and the Status of its Members’ and ‘On the People’s Council of Kazakhstan (Khalyq Kenesi)’ and the government for the laws ‘On the Status of the Capital of the Republic of Kazakhstan’ and ‘On the Administrative-Territorial Structure of the Republic of Kazakhstan’. 6 The 2025 UNHRC Universal Periodic Review for Kazakhstan raised concerns, inter alia, about the right to freedom of association, peaceful assembly, expression and freedom of media. See also the 2025 joint communication by UN Special Rapporteurs and experts with regard to concern over the criminal prosecution and sentencing of activists, a the broader pattern of criminalization and punishments for exercising freedom of expression, peaceful assembly, and association. In January 2026, Amnesty International stated about pressure on media and degrading situation with the freedom of expression. The F statement by the Kazakhstan International Bureau for Human Rights and Rule of Law and International Partnership for Human Rights (IPHR) highlighted serious concerns r restrictions of peaceful assemblies, and persecution of activists, journalists and bloggers. 7 Several ODIHR NAM interlocutors expressed disillusionment with the legislative and political process, citing lack of opportunity for meaningful impact. Some interlocutors considered election-related activities as potentially dangerous, and cited the case of Mr Yerzhanov, the initiator of ‘Smart Referendum Boycott’, who was sentenced to a four-year imprisonment, with electoral offences explicitly exempt from the scope of the recent Amnesty Law. ODIHR NAM interlocutors expressed concerns about public statements by authorities regarding possible enactment of a ‘foreign agent law’ and its potential consequences for the civic space, as well the expansion of strategic litigation against journalists. 8 Paragraph 4 of the 1990 OSCE Copenhagen Document states that the participating States “will ensure that their laws, regulations, practices and policies conform with their obligations under international law and are brought into harmony with the provisions of the Declaration on Principles and other CSCE commitments”. 9 Six of seven registered parties entered the Mazhilis after the last early parliamentary elections held on 19 March 2023. The Amanat party received 62 seats (40 from the proportional and 22 from the majoritarian contests), the National Democratic Patriotic Party - Auyl – 8 seats, the Democratic Party Ak Zhol and the Respublika party - 6 seats each, the People’s Party of Kazakhstan - 5 seats, and the National Social-Democratic Party – 4 seats, 7 seats were won by independent candidates in majoritarian context.

Republic of Kazakhstan Page: 6 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report development that some ODIHR NAM interlocutors described as unexpected was the leadership change within three political parties in June 2026. 10 Women remain under-represented in political and public life, with 17 out of 93 seats in the Mazhilis (18 per cent) and 3 out of 25 the government posts; none of the 20 Akims (governor of region) are women. The UN Committee on the Elimination of Discrimination against Women has previously expressed concern about the low representation of women in decision- making positions as well as about discriminatory gender stereotypes hindering the participation of women in political and public life. 11 ODIHR has observed 15 elections and two referenda in Kazakhstan. The final report, issued in July 2023, contains 35 recommendations, including 8 priority ones, for the authorities to improve electoral process and bring it closer in line with OSCE commitments. 12 B. L EGAL FRAMEWORK AND ELECTORAL SYSTEM The parliamentary elections are primarily regulated by the 2026 Constitution, the 1995 Constitutional Law on Elections last amended in June 2026 (the Election Law). 13 The Central Election Commission (CEC) issues normative and procedural regulations. 14 Kazakhstan is a party to major international and regional instruments related to the holding of democratic elections. 15 A package of six constitutional laws developing and integrating the new constitutional provisions, including amendments to the Election Law, was adopted on 5 June, 16 a package of legal amendments harmonising other laws, including election- related, followed on 11 June and entered into force on 1 July. 17 10 Ak Zhol, Auyl and the People’s Party of Kazakhstan and announced the changes of their leaderships on 13, 23, 26 June, respectively. 11 See UN Committee on the Elimination of Discrimination against Women 2019 Concluding observations on the fifth periodic report of Kazakhstan, paragraphs 24, 29 and 30. 12 In paragraph 25 of the 1999 OSCE Istanbul Document, OSCE participating States committed themselves “to follow up promptly the ODIHR’s election assessment and recommendations”. See ODIHR Electoral Recommendations Database at Paragraph25.odihr.pl, see also all previous ODIHR election-related reports on Kazakhstan. 13 Election-related legislation includes, inter alia , the Law on Kurultai , the Law on Political Parties, the Law on Peaceful Assemblies, the Law on Mass Media, the Code on Administrative Procedures, the Code on Administrative Offences, and the Criminal Code. 14 To date, the CEC has not adopted regulations specific to the upcoming parliamentary elections, as the election date has not been announced. 15 Including the 1966 International Covenant on Civil and Political Rights (ICCPR), 1979 Convention for the Elimination of All Forms of Discrimination against Women (CEDAW), 1965 International Convention on the Elimination of All Forms of Racial Discrimination (CERD), 2003 Convention against Corruption, 2006 Convention on the Rights of Persons with Disabilities (CRPD), and the 2002 Commonwealth of Independent States (CIS) Convention on Standards of Democratic Elections, Electoral Rights and Freedoms. Kazakhstan is a member of the Council of Europe’s Commission for Democracy through Law (Venice Commission) and the Group of States against Corruption (GRECO). 16 The package of six constitutional laws, including the Laws ‘On the President of the Republic of Kazakhstan’, ‘On Kurultai and the Status of its Members’, ‘On the People’s Council of Kazakhstan (Khalyq Kenesi)’, ‘On the Status of the Capital of the Republic of Kazakhstan’ and ‘On the Administrative -Territorial Structure of the Republic of Kazakhstan’ and amendments to the Law on Elections (Law No 305- VIII) was adopted at a joint session of both parliamentary chambers on 20 May and promulgated on 5 June . The constitutional law ‘On the President’ incorporated basic regulation on the new institute of vice-presidency, leaving detail for the president’s discretion. The National Council of Kazakhstan is designed as a consultative body with legislative initiative, its 126 members are appointed by the president, 42 each from ethno-cultural associations, from public associations, and maslikhats and public councils, with strong presidential influence on the determination of the Council’s activities. 17 The (Law No 305-VIII), Law No 306- VIII, and Law No 307 -VIII entered into force on 1 July, some provisions, including on election commissions and voter lists, entered into force on 23 June.

Republic of Kazakhstan Page: 7 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report The amendments to the Election Law, inter alia, introduced a proportional electoral system for parliamentary elections, ex panded candidate eligibility limitations, adjusted nomination and certain campaign rules, increased campaign expenditure ceiling, prohibited in- kind donations, introduced new eligibility criteria for election commissioners, expanded the prohibition of foreign financing to cover all election-related activities, including, as interpreted by authorities, election observation activities. Amendments to the Code of Administrative Offences expand ed sanctions for campaign and campaign financing violations. The amendments did not address prior ODIHR recommendations. 18 The constitutional laws and amendments were developed by the respective institutions in an expedited manner, with limited or no transparency or public discussions. 19 The parliament processed the vast package of key constitutional laws and amendments within two weeks. The work was conducted within special joint parliamentary committees, which reviewed, inter alia, several proposals from citizens and MPs. 20 ODIHR NAM interlocutors informed that the draft laws were not uniformly published, there was no visible information campaign or public discussion on the drafts, and the legislative process was not inclusive. 21 The amendments, including on electoral system and candidacy requirements, were adopted three months prior to the upcoming elections. 22 The 145- member unicameral Kurultai is elected for a five- year term under a proportional electoral system based on closed party lists in a single nationwide constituency. The constitutional review removed the majoritarian component that allowed individual candidates to run, which had been introduced in 2022, in line with international standards. 23 In line with the 2026 Constitution, the mandate of elected MPs is withdrawn in case they lose their political party membership. Some 18 The recommendations inter alia concerned a comprehensive review of the electoral legal framework through an inclusive consultative process to bring it in line with international standards and OSCE commitments, on ensuring fundamental freedoms of peaceful assembly, expression and association, independence of election administration, candidacy requirements, the media, and publication of election results. 19 The Ministry of Justice (MoJ) informed the ODIHR NAM that the drafts developed by the government are published online on a specialised platform allowing comments from citizens, but there were few for the respective drafts, whereas the law does not prescribe public consultations for the bills drafted within the presidential legislative initiative, hence those were not conducted. The CEC informed the ODIHR NAM that the amendments to the Election Law were planned in Resolution of the Government of the Republic of Kazakhstan of 27 December 2024 No. 1132 ‘Plan of Legislative Work of the Government of the Republic of Kazakhstan for 2025’, were drafted by the Ministry of National Economy, and published for discussion “Open Legal Acts” portal for public discussion from 15 January 2025 to 5 February 2025. 20 The concept of the draft constitutional bills was approved at a joint session of the parliament on 8 May and joint parliamentary commissions were created to prepare the bills for adoption on second reading, held on 20 May. The information on preparation of all six constitutional laws is not uniformly available. Members of the parliament’s Mazhilis Committee on Legislation and Judicial reform informed ODIHR NAM that the rules to prohibit photo- and video-footage at polling station was incorporated based on a citizen’s proposal, no other examples were given. Other ODIHR NAM interlocutors stated that their proposals were not considered. 21 ODIHR NAM interlocutors informed that while the parliamentary webpage did contain a dedicated section for the draft constitutional laws, the links to the draft bills were leading to outdated documents. The parliamentary system does not allow to submit comments on published bills . The parliamentary working groups did not include members of the expert community or independent civil society, although allowed by the Rules of Procedure. 22 Paragraph II.2.(b). of the 2002 Venice Commission Code of Good Practice in Electoral Matters ( Code of Good Practice) states that s tates that “The fundamental elements of electoral law, in particular the electoral system proper, membership of electoral commissions and the drawing of constituency boundaries, should not be open to amendment less than one year before an election”. See also the 2024 Venice Commission Revised Interpretative Declaration o 23 Paragraph 7.5 of the 1990 OSCE Copenhagen Document states that the participating States should “respect the right of citizens to seek political or public office, individually or as representatives of political parties or organizations, without discrimination.” See Article 25 of the 1966 ICCPR and paragraph 15 of the UN HRC General Comment No. 25: “persons who are otherwise eligible to stand for election should not be excluded by unreasonable or discriminatory requirements such as education, residence or descent, or by reason of political affiliation.”

Republic of Kazakhstan Page: 8 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report ODIHR NAM interlocutors questioned the designation of the new parliament as the Kurultai, citing what they viewed as incompatibility of the historically and culturally determined concept of a kurultai as a consultative assembly of the elites and elders with its use to denote a directly elected parliament in a modern representative democracy. C. E LECTION ADMINISTRATION The elections will be administered by a three- tier hierarchical system of election commissions , including the Central Election Commission (CEC), territorial commissions (TECs) - as of April 2026, 17 oblast commissions, 3 commissions in cities with special status, and 227 district and district city commissions - and some 10,400 precinct commissions (PECs). 24 Commissions at all levels are appointed for a five-year term and, except for the PECs, consist of seven members. 25 In light of the elimination of the majoritarian component, district election commissions will not be involved in conducting these elections. The 2026 legal amendments eliminated the eligibility to work in election management bodies for those sentenced for corruption crimes or nominated by organizations with foreign financing. The CEC regulates, administers and oversees the overall conduct of the elections , maintains the unified voter register, establishes the election results, and may invalidate election results per administrative unit or a PEC. Of the current composition of the CEC, the President appointed the CEC chairperson and two members, while the Senate and the Ma zhilis appointed two members each. 26 Two of the current seven CEC members are women. Under the 2026 legal amendments, t he president will appointment the entire CEC composition, subject to the Kurultai’s approval, except for the candidacy of the Chairman, to be piloted after the upcoming elections. The 2026 Law on the President also empowers the president to approve the resolution on the CEC . The current compositions of the TECs and PECs were appointed by the local assemblies from the nominees of political parties and CSOs. With the new Law, the CEC will appoint the TECs, elected by the respective maslikhats upon the nomination of political parties. The CEC informed the ODIHR NAM that commissions membership required adjustments due to withdrawals. The TECs are responsible for the preparations for the elections in their territory, consider complaints against relevant PECs and tabulate voting results. The PECs inform voters about voting locations, manage voter lists scrutiny, conduct election day procedures, including vote counting, and decide on election day complaints at first instance. The CEC informed the ODIHR NAM that all lower -level commission members and their organizational and logistical resources are available and ready for the process. The CEC developed a combined online and offline training programme, including for the TECs and PECs, and already conducted them; additional trainings and testing on the knowledge of the new legal framework are planned. 27 The CEC informed the ODIHR NAM that all sessions are broadcast online, with regular press briefings with questions and answers sessions for the media. 24 Out-of-country voting will be administered in 80 PECs at 62 countries abroad; 552 polling stations are established in hospitals, military units and other places of temporary stay of voters, 9,779 PECs are regular. 25 By law, the PE Cs should have between 5 and 9 members depending on the size of the precinct. 26 After the CEC appointment in 2022, most members were changed during 2023- 2024. 27 According to the CEC, cascade trainings for the T ECs and PECs have been conducted in the regions and locally in three stages divided by the scope of functions and responsibilities. The CEC plans to conduct a seminar for the media and civil society observers closer to the election campaign start. The CEC also shared its positive experience in conducting regional youth fora on electoral matters, and planned to repeat those in the future.

Republic of Kazakhstan Page: 9 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report The CEC informed the ODIHR NAM that it takes into account the divers e needs of persons with disabilities in the electoral process. 28 While no ODIHR NAM interlocutors raised concerns about the capacity of the election administration to administer the technical aspects of the electoral process, many expressed reservations about the integrity of the process. They referred to concerns regarding the appointment of election commissioners, past electoral irregularities , including on election days, and a perception among some stakeholders that the election outcome may already be largely predetermined. D. V OTER REGISTRATION The right to vote is granted to citizens at the age of 18. Those with judicially withdrawn legal capa city, including based on intellectual or psychosocial disability, and those serving a prison sentence, regardless of the gravity of the crime , are disenfranchised, contrary to the OSCE commitments, other international standards, and prior ODIHR recommendations. 29 The CEC announced that, as of 1 January, the unified voter register included 12,416,759 voters. V oter registration is passive and is based on the permanent residency, which constitutes the basis for the voter list. T he local executive bodies comply voter lists based o n the state population register, to be transmitted to TECs and PECs twenty days before voting, which PECs further verify and update. Voters may apply for inclusion into the voter register from the day of the elections announcement, and can apply to change voting address a month before voting. Voter lists will be available for public scrutiny 15 days before voting at the precinct level and online, with requests for corrections examined the same day, subject to judicial review. Voters may also apply for an Absentee Voting Certificate, enabling them to vote at any polling station outside their permanent registration locality. Voters can be added to a supplementary voter list on election day without judicial or administrative oversight, provided they prove their residence within the precinct , despite previous ODIHR recommendations. 30 ODIHR NAM interlocutors did not express concerns regarding the accuracy of the voter register. The CEC plans a large- scale information campaign for voter lists scrutiny and election participation, including via lower-level election commissions for voter outreach, call-centres, mobile notifications and online platforms . E. C ANDIDATE REGISTRATION The right to stand for parliamentary elections is granted to eligible voters aged 25 or older. Contrary to international standards and prior ODIHR recommendations, the 2026 Constitution maintains the 10-year residency requirement for candidacy. 31 The amended Election Law stipulates disenfranchisement for any unexpunged criminal record, regardless of the crime committed, and for any corruption-related crimes and offences. T he 2026 Election Law amendments excluded 28 The CEC informed about provision of hearing and visual aids to all polling stations, and that special requirements to the premises and voting equipment were applied to the polling stations, where persons with motor disabilities are registered; while the CEC sessions are interpreted into sign language. Some ODIHR NAM interlocutors informed that Braille templates are deformed during transportation, affecting their readability. 29 Paragraph 7.3 of the 1990 OSCE Copenhagen Document states that the participating States will “guarantee universal and equal suffrage to adult citizens”. Deprivation of the right to vote based on mental disability is inconsistent with Articles 12 and 29 of the UN CRPD. Paragraph 14 of UN HRC General Comment No. 25 to Article 25 of the ICCPR state that grounds for deprivation of voting rights based on criminal conviction “should be objective and reasonable”. See also Paragraphs 50-51 of the 2016 UN HRC Concluding Observations. 30 According to paragraph I.1.2.iv of the 2002 Venice Commission Code of Good Practice in Electoral Matters , “polling stations should not be permitted to register voters on election day itself”. 31 Article 54 of the 2026 Constitution . See Article 25 in conjunction with Article 2 of the 1966 ICCPR, paragraph 15 of the 1996 UN HRC General Comment No. 25.

Republic of Kazakhstan Page: 10 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report independent candidates, and allowed an individual to stand simultaneously for elections to the parliament and local assemblies but on one candidate list per contest. Candidates can be nominated only by registered political parties from among their members. 32 The number of candidates cannot exceed the number of distributed seats by more than 30 per cent. The law provides for a cumulative minimal 30 per cent quota for women, youth and persons with disabilities in candidate list, and does not provide any candidates placement requirements, which the political parties determine independently. 33 Political parties are obliged to transfer electoral deposit, amounting to KZT 1,275,000 per candidate to the CEC; the deposit is refunded to the parties that win over 5 per cent of votes. 34 To be registered, candidates are required to provide property declarations. The CEC conducts candidate registration, which starts and finishes 60 and 30 days prior to the elections, respectively, unless determined otherwise. Candidate lists or individual candidates can be deregistered up to two days prior to elections; denial of registration and de-registration can be appealed to the Supreme Court. The CEC shall publish the candidates lists within ten days. ODIHR NAM interlocutors from political parties stated that their parties are a waiting the official announcement of elections to begin the process of determining candidate lists, while their local branches have already started identifying potential candidates. The ODIHR and other international organizations noted long-standing challenges related to political party registration, despite the formal simplification of registration procedures, citing unsubstantiated and formalistic decisions to deny registration, and considered the new system will limit participation to established political elites . 35 F. E LECTION CAMPAIGN Under the amended Election Law, election campaign starts upon candidate registration and ends one day before elections. 36 The right is guaranteed to citizens and public associations at meetings, rallies, citizens’ gatherings and in the media, including online. The 2026 legal amendments extended campaign regulation on social networks. The law provides for the CEC-organized debates for contestants. Political programmes and campaign messages with false information, discriminating against different groups, calls for a violent change of the constitutional and public order and war are prohibited. 37 The Election Law prohibits participation in election campaigns to officials of state and local institutions 32 Decisions on candidate list are made by the majority vote of the political party’s supreme body at its general assembly. 33 See paragraphs 24, 29 and 30 of the 2019 UN CEDAW Committee Concluding observations on the fifth periodic report of Kazakhstan. The 2024 CEDAW General Recommendation No. 40 prescribes Parties to “amend the Constitution and legislative frameworks to institutionalize 50:50 parity between women and men in all spheres of decision-making”. See also paragraph 22 of the CEDAW Committee General Recommendation No. 25, on Article 4, paragraph 1 of the CEDAW on temporary special measures to promote women’s political participation. 34 The Election Law stipulates the electoral deposit amount of 15 minimal salary amounts. In 2025 State Budget Law for 2026 - 2028, minimal salary was determined to amount to KZT 85,000. The electoral deposit constitutes some EUR 2,344 per candidate; EUR 1 is equal to KZT 544. The law stipulates decreased deposits, depending on previous elections results, and exemption for political parties that won over 5 per cent of the vote. 35 See, inter alia, the 2025 UPR Review of Kazakhstan that resulted on several repeated recommendations to guarantee the rights to freedom of expression, assembly and association for all, in accordance with international human rights standards. 36 The Election Law entitles the CEC to determine all deadlines for conducting early parliamentary elections. 37 Amendments to Article 29 of the Election Law prohibit election programme to “proclaim the ideas of forcible change of the foundations of the constitutional system, encroachment on the territorial integrity, Sovereignty and Independence of the Republic of Kazakhstan, violation of public order, undermining national security, war, armed conflicts, social, racial, national, ethnic, religious superiority or discord, the cult of cruelty and violence, as well as calls to commit such actions”.

Republic of Kazakhstan Page: 11 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report while performing their professional duties, and misuse of office and administrative resources , and vote buying. The 2026 legal amendments prohibit any participation or input of foreigners and foreign funding in any electoral activities, which is subject to wide interpret ation. 38 The Election Laws define conditions for the conduct and publication of opinion polls, which some ODIHR NAM interlocutors assessed as in need of review for stifling political debate and limiting participation. While the law provides for the notification of the CEC about the intent to conduct polling, the CEC may adopt rejections, constituting a de facto authorization process. 39 According to many ODIHR NAM interlocutors, the interpretation of some norms of the law is restrictive, including on the definition of polling, with instances when journalistic activities during the referendum campaign, such as street interviews and posts on social networks, were treated as sociological polling, and content removals were ordered in connection with discussions on the referendum. 40 ODIHR NAM interlocutors considered the new political party, Adilet, to be come the most influential contestant. The announcement of the new political initiative to register Adilet followed shortly after the referendum, with declaration to pursue consolidation of society in support of the President’s ‘Just Kazakhstan’ programme and the constitutional reform. Following a smooth and expeditious process, Adilet was registered on 1 June. 41 On 12 June, after the President’s address, advocating for the union between pro-presidential forces, Amanat announced merger with Adilet, which the latter supported on 14 June. Amanat is currently undergoing reorganization procedure, which, according to the Ministry of Justice (MoJ) will be finalized within several months, after the elections. 42 ODIHR NAM interlocutors described the merger as unanticipated for Amanat members, and a lack of certainty as to the political future of its numerous members, including for the upcoming parliamentary elections within the Adilet’s campaign. 43 38 The CEC, MoJ and other ODIHR NAM interlocutors informed that the provision extends to any type of foreign funding, including to national CSOs, including those not earmarked for any election- unrelated activities, which inter alia excludes national CSOs with any foreign funding for any activities from election observation. 39 The publication of opinion polls is prohibited five days before and on the day of voting; exit polls inside polling stations on the day of voting are prohibited. Only registered organisations with at least 5 years of experience are allowed to conduct electoral opinion polls. The media must publish the opinion polls with the reference of the commissioner, the methodology, the time, and other information related to the questionnaire. ODIHR interlocutors informed that the CEC issues decisions rejecting to consider the notification on conducting opinion polls, if it is established that the applicants or their methodology does not comply with the law, e.g. in 2026 Demoscope was prohibited from conducting opinion polls on referendum. 40 An Azattyq journalist was fined for a question “will you participate in the referendum?” on a social network where 6 people responded; in 2024, a newspaper was fined for an interviews about the 2024 nuclear power plant referendum; the same outlet was fined again in 2026 for interviews related to the 2026 constitutional referendum. The CEC informed ODIHR NAM that “obtaining the opinion of several citizens in the form of interviews or comments does not in itself constitute an opinion poll. Such materials represent a form of free communication with a limited number of participants and do not fall under the requirements applicable to opinion polls, provided they do not contain aggregated quantitative results”. 41 Adilet is the first political party registered since 2023. The party initiative group included former members of the Constitutional Commission and a president’s relation, the party is led by the Aibek Dadebai, who, until 5 May, was the Head of the Presidential Administration. Adilet is the first party that could recruit its membership via the government’s online portal. On the day of party registration its membership constituted over 126,000 people, indicating a 119,000 increase in less than a month. The party membership includes influential businessmen and former government ministers and other officials. 42 The MoJ explained that the reorganization includes termination of membership, financial claims resolution, and liquidation of its field divisions. While, according to the party members and the MoJ, the legal title to Amanat’s extensive property will be transferred to Adilet once reorganization is finalized and Amanat is deregistered, Adilet already uses Amanat’s property, including the offices, for which no legal explanation was afforded. ODIHR NAM interlocutors mentioned Amanat’s offices were transferred to Adilet next day after the merger announcement. 43 The reorganization does not entail an automatic transfer of party membership, and Amanat members will have to apply to join Adilet. Some ODIHR NAM interlocutors stated the reorganization was intended as an effort to reshape the political landscape, and consolidate political control.

Republic of Kazakhstan Page: 12 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report The political parties ODIHR NAM met with stated complete readiness for the forthcoming campaign. Most stated that their campaign activities will aim to ensure large-scale grassroots outreach, with door-to-door canvassing and cultural events in the regions. Most parties plan to rely on social networks to promote their programmes. All of them declared support to the President’s political programme. A week prior to the announcement of the elections, several MPs stated uncertainty as to electoral plans. 44 Most political parties informed ODIHR NAM about active women’s wings and that no special measures are required to promote their participation. The Ministry of Culture and Information (MCI) informed that as the law regulating social networks and online space has been adjusted to the networks policies and user agreements, and the appointment of social networks’ country representatives, the implementation, including with respect to election campaign violations, is streamlined. The MC I informed that its Centre of Monitoring and Analysis conducted a monitoring of the online space, including major social networking platforms, and during election campaign the scope of its activities will be extended to potential electoral violations. ODIHR NAM interlocutors in state institutions assessed the risk of foreign interference for the elections in Kazakhstan as only a potential threat; however, they stated that necessary preventive mechanisms have been elaborated, and state security services monitor to respond to potential attacks. G. C AMPAIGN FINANCE Campaign financing is regulated by the Election Law and the Law on Political Parties, while the CEC regulates expenditures and operations on campaign bank accounts. The Election Law amendments in force since 2023 eliminated political parties’ obligation to report on campaign financing; the Law does not regulate the scope of oversight and control. 45 The 11 June Election Law amendments increased the campaign fund and contribution limits, while those to the Code of Administrative Offences inter alia introduced sanctions for campaign financing outside electoral funds. The recent legal amendments did not address prior ODIHR recommendations related to campaign financing. Parliamentary election campaigns can be financed from electoral funds created by the political parties nominating candidate lists; the Election Law prohibits individual electoral funds for candidates. Only contributions deposited on a designated campaign account can be used. T he CEC will determine the banks servicing campaign accounts. Electoral funds can be constituted from political party and candidate’s personal contributions, and donations from Kazakh individuals and legal entities . Political parties may contribute up to KZT 1.275 billion; the total amount of donations and legal entities should not exceed KZT 2.55 billion. An individual donation is limited to KZT 25.5 million, a legal entity may donate up to KZT 127.5 million. 46 ODIHR recommendation to regulate the limits for candidates’ contributions remains unaddressed. The Election Law prohibits donations from charitable, religious, and state-funded organizations, state and local self-governance institutions, any foreign funding is prohibited, anonymous donations are transferred to state budget. Following the amendments to the Election Law in June 2026, only monetary donations to electoral funds are allowed. 44 See interview with seven MPs about their plans for the forthcoming elections. 45 The amendments to para. 9 of Article 34 of the Election Law under the Law No. 156-VII of 5 November 2022. 46 The limits are denominated in minimal salaries, amounting to 15,000 (increased from 5,000), 30,000 (increased from 10,000) minimal salaries, and 300 and 1,500 minimal salaries, or EUR 2.35 million and EUR 4.7 million, EUR 46,875 and EUR 234,375, respectively. The amount of expenditures per candidate list may amount to EUR 7 million.

Republic of Kazakhstan Page: 13 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report The CEC is entitled to control the use of campaign funds, and to receive information about the electoral funds of political parties from the banks, weekly or upon request. The Election Law provides for candidates’ deregistration and invalidation of election results if campaign finance violations are revealed after the vote. The CEC will publish the total expenditure for election campaigns within ten working days after election results publication. H. M EDIA ENVIRONMENT The media environment is strongly influenced by state dominance in the media market, through ownership and budgetary subsidies, which affects its pluralism, along with denials of journalistic accreditations, deregistration of media and content removals. 47 Television remains the primary source of political information, particularly in rural areas. Internet hosts larger share of the critical public debate, but, according to ODIHR NAM interlocutors, it is also affected by state control and sanctions, including blocking of critical websites, requests to remove content. Internet shutdowns are occasional. Situation with media freedoms, including access to information, and safety of media workers is deteriorating. 48 As 2025, there are 5,029 registered media outlets in the country, including 686 information agencies, 623 online media, 248 television (TV) channels, 99 radio channels, and 3,067 print media. 49 The law prescribes the majority of content to be in Kazakh language. 50 Despite previous ODIHR recommendations, there is no genuine public service broadcasting, with the independent appointment of management, multi-sourced funding and a clearly defined public service mandate. The MCI regulates and implements state policy with respect to all media, including online, bloggers and influences, and manages broadcasting licences. The Ministry conducts media monitoring, including online and on social networks, for compliance with the legal requirements and may limit dissemination of content unilaterally or by a judicial decision. 51 The Constitution guarantees the freedom of expression, media freedoms and the right of access to information. Previous ODIHR recommendations on effective exercise of freedom of expression, including decriminalization of libel, insult, false information, and ensuring access to information, 47 According to Ministry of Culture and Information (MCI) data from November 2025, of some 30 TV stations registered in Kazakhstan on the national and regional levels, 10 are owned by three large state TV holdings. Qazaqstan Radio and TV corporation owns four channels (including Qazaqstan), Agency Khabar operates two (Khabar and 24kz) and TV and Radio Complex of the President of the Republic of Kazakhstan four (including Jibek Joly and news agency Kazinform ). Astana TV belongs to a media holding related to Amanat. State funding to private media is distributed under the Law on Mass Media without public disclosure, as the information is classified for restricted use. The MCI stated that its decisions to grant or deny journalistic accreditations are based on the MCI’s Standard Rules for Journalist Accreditatio n, developed in order to ensure a more organized and effective access to informationin consideration of the proposals from the media. 48 The 2026 Regular Report by the OSCE Representative on Freedom of the Media underlines that, inter alia , in Kazakhstan “journalists and other media actors are facing prosecution, ongoing criminal proceedings, pre- trial detention, and other forms of legal pressure” (p. 6) and that “criminal proceedings under broadly framed provisions have affected journalists reporting on matters of public interest” (p.10). Recent cases concern KazTAG editor-in- chief Amir Kasenov, journalists Botagoz Omarova, Oleg Gusev, Mirbolat Bishuinov and others. 49 According to the MCI , of these, 4,723 were national media, and 306 were foreign. 50 Article 50 of the 2024 Law on Mass Media with the 2025 amendments. 51 From 1 to 31 November 2025, the Ministry limited circulation of 6,707 online resources and links due to violations of prohibited content; no content-related limitations were prescribed by courts in that period. From 1 January to 31 December 2024, the Ministry limited dissemination of 26,500 online resources and links; no content related limitations were imposed by the court in that period. The MCI stated that the decisions on content removals are made under Article 41-1 of the Law on Communications.

Republic of Kazakhstan Page: 14 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report ceasing content removals, remain unaddressed. 52 Some ODIHR NAM interlocutors reported that the protective mechanisms for media freedoms under the media -specific legal framework 53 are mostly disregarded in the consideration of cases against journalists in favour of restrictive criminal and administrative laws, manifesting in a growing number of SLAPP (strategic lawsuits against public participation) cases against journalists, which affect freedom of expression and of the media . 54 The Election Law requires objective coverage of election campaigns and equal access and conditions for contestants in the media, and lists topics that cannot be subject of public campaign discourse, reinforced with liability for dissemination of prohibited information. B roadcasting campaign materials in news and analytical programmes is prohibited. The Election Law prescribes registration with the CEC for media outlets to cover the election campaign and publish or broadcast political advertising. 55 The 2026 amendments to the Code of Administrative Offences introduced sanctions for the failure of the media to timely inform the CEC about campaign-related contracts and for violations of equal campaign opportunities for contestants, including on bloggers. The state broadcasting corporation Qazaqstan informed the ODIHR NAM that it will develop its electoral programme once the elections are officially announced. Its representative stated that the corporation will conduct news coverage of the election campaign, which will be interpreted into sign language, and will broadcast materials provided by the political parties, ensuring equal coverage. The ODIHR NAM was informed that the state broadcasting corporation cooperates with the CEC who shares information materials on election campaign coverage rules and conducts trainings for journalists. I. E LECTORAL DISPUTE RESOLUTION Decisions, actions and inactions of election commissions are subject to hierarchical review by superior election commission or courts. A dministrative courts are the first instance for complaints against lower-level election commissions, with the possibility of further appeal to the Supreme Court, which also acts on first instance in cases against the CEC. In cases of parallel complaint submission to election administration and courts, the election commissions shall suspend the procedure. Complaints about electoral violations can be submitted to courts or to the prosecution. Legal standing to challenge decisions and actions of election administration is granted to citizens and registered public associations, while electoral violations can be also contested by other participants 52 Libel and insult remain criminalized when public office holders are targeted, see Articles 375, 376 and 378 of the Criminal Code. 53 Article 68 of the Law on Mass Media exempts a journalist, editorial office and mass media from liability for the dissemination of information that does not correspond to reality, in certain cases, inter alia for quoted information (a verbatim reproduction of the statements, or was obtained from official sources). The MCI informed the ODIHR NAM that, as the authorized body in the field of mass media, it considers the position any form of obstruction of journalists’ professional activities to be unacceptable. It noted that Article 158 of the Criminal Code establishes criminal liability for obstructing lawful professional activities of journalists, and stated that it monitors the progress of investigations in cases involving journalists. 54 Besides the Criminal Code, sanctions for dissemination of false information are stipulated in the Code of Administrative Offences, the Law on the Online Platforms and Online Advertising, and the Law on Mass Media. In March, journalists petitioned the President to decriminalize Article 274 of the Criminal Code on dissemination of false information due to its increased misuse to pressurize journalists. In line with the 2025 amendments to the Code of Administrative Offence, a new Article 456-3 provides sanctions for unaccredited foreign media, journalists and national journalists working for foreign media without accreditation. See the April 2026 Legal Media Center’s ‘Freedom of Speech Barometer’ that lists restrictive legislation and cases against media and media workers, including SLAPP and criminal prosecutions in Kazakhstan. 55 The CEC informed the ODIHR NAM that the requirement is aimed at ensuring the openness and transparency of the conditions for placing election campaign materials, as well as at precluding the granting of advantages to particular political parties.

Republic of Kazakhstan Page: 15 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report and election commissions. The MCI forwards cases of election -related violations identified during monitoring to the prosecution or the court and may order content removal. The law provides for expedited deadlines for electoral -related disputes: applicants have ten days to contest; the courts decide within five days, or immediately, if submitted within four days prior to or on the election day, while the election commissions decide on election-related violations within five days and review the decisions, actions, inactions of lower-level election commissions within three days. The CEC may invalidate the election results for violations; the 2026 amendments clarified that such violations must affect at least one fourth of all PECs or administrative units. The Constitutional Court examines the correctness and constitutionality of elections, if requested by the president, the prime minister or one fifth of all members of Kurultai within ten days after the determination of the results. Some ODIHR NAM interlocutors voiced concerns about the effectiveness of the dispute resolution process and the conduct of law enforcement, and expressed varying degrees of confidence in the election administration and judiciary to deal with election-related cases impartially. J. C ITIZEN AND INTERNATIONAL OBSERVATION The Election Law provides for observation by representatives of registered public associations and international observers, and together with CEC resolutions regulates accreditation procedures, the status and conduct of observers. 56 Only associations registered to conduct election observation as a statutory activity are allowed. Several citizen observer groups informed the ODIHR NAM that they struggled to plan observation activities for the upcoming elections due to lack of financing, pressure from authorities and uncertainty related to eligibility to observe for organisations with foreign funding. The authorities commented to ODIHR NAM that the recent amendments to the Election Law effectively exclude all CSOs with foreign funding from election observation activities in Kazakhstan. CSO s noted that those engaging in activities considered politically sensitive, including election observation, may face administrative pressure, while the legal framework governing the registration and activities of such non-governmental organizations imposes extensive reporting and financial requirements, with sanctions, including fines, for broadly defined violations. IV. CONCLUSIONS AND RECOMMENDATION ODIHR NAM interlocutors expressed uniform appreciation of the potential added value and necessity of an ODIHR observation activity for the anticipated elections . Most interlocutors highlighted the benefit of an independent assessment, including in the context of the election-related changes and the legislative revision. Interlocutors underlined that the legal framework for elections, the campaign and its coverage in the media, respect for fundamental freedoms, and election day procedures, would merit particular attention in the context of a potential ODIHR observation activity. Based on the findings of this report, the ODIHR NAM recommends the deployment of an Election Observation Mission (EOM) for the upcoming early parliamentary elections. In addition to a core team of analysts, ODIHR will request the secondment by OSCE participating States of 30 long- term observers to follow the electoral process countrywide, as well as 300 short-term observers to follow election day procedures. In line with ODIHR’s standard methodology, the EOM will include a media monitoring element. 56 One observer per public association is allowed in a polling station at the same time.

Republic of Kazakhstan Page: 16 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report ANNEX: LIST OF MEETINGS Ministry of Foreign Affairs Zhangeldi Syrymbet, Deputy Director, Department of Europe Aibek Yessey, Third Secretary, Department of Europe Gulnar Akhmetova, Third Secretary, Department of Europe Central Election Commission Mukhtar Yerman, Deputy Chairperson Damegul Kabiyeva, Head, International Department Supreme Court Aslan Turkiev, Chairman of the Judicial Division for Administrative Cases, Supreme Court Gulzhanar Gusman, Secretariat for the Administrative Cases, Supreme Court Yelena Popova, Deputy Head, Division of International Cooperation and Protocol Ministry of Justice Gulnara Mukusheva, Director, Department of Constitutional L egislation and Public Administration Dias Sharipbai, Deputy Director, Department of Constitutional Legislation and Public Administration Venera Kalimova, Head, Committee on Registration Services and Organization of Legal Services Ministry of Culture and Information Alisher Mukazhan, Chairman, Committee for Information Anar Mukatayeva, Director, Department of State Media Policy Mikhail Komissarov, Head, Centre of Monitoring and Analysis Members of Mazhilis of the Parliament 57 Snezhana Imasheva, MP, Chairperson, Committee on Legislation and Judicial and Legal Reform, member of the Constitutional Commission Magerram Magerramov, MP, Secretary, Committee on Legislation and Judicial and Legal Reform, member of the Constitutional Commission Political Parties Aidarbek Khodzhanarov, Leader of the political party ‘Respublica’, MP Zhanat Iskakov, Head, Central Administration, political party ‘Respublica’ Rauan Kenzhekhanuly, Political Party ‘Adilet’ Gulzira Abayeva, Political Council member, Political Party ‘Adilet’ National Center on Human Rights Dinara Tazhenova, Head Anvar Sabirov, Deputy Head Media Aizada Zhamankulova, Deputy Chair of the Board, National TV Channel Qazaqstan Olga Didenko, Internews Diana Okremova, Director, Legal Media Centre Gulmira Birzhanova, Co -Founder, Lawyer, Media Expert, Legal Media Center Representatives of other media outlets 57 Meetings were requested with all parliamentary factions.

Republic of Kazakhstan Page: 17 Early parliamentary elections, 23 August 2026 ODIHR Needs Assessment Mission Report Civil Society Dimash Alzhanov, Political Expert Zauresh Battalova, Foundation for Parliamentarism Development Tatiana Chernobil, Expert in Human Rights, Human Rights Defender Meiram Kazhyken, Institute of Modern Society Studies Pavel Lobachev, Director, Public Foundation “Echo” Yelena Shvetsova, Chairperson, Public Foundation Yerkindik Qanaty Roman Reimer, Head, Legal Unit, Public Foundation Yerkindik Qanaty Yevgeniy Zhovtis, Director, Kazakhstan International Bureau for Human Rights and Rule of Law Representatives of other civil society organizations Dinara Yegeubayeva, blogger, journalist International Community 58 Representatives of OSCE participating States in Astana: Embass ies of the Czech Republic, the Kingdom of the Netherlands, the Russian Federation, Sweden, Switzerland, and the United States of America. 58 The ODIHR NAM extended an invitation to representations of all OSCE participating States resident in the Republic of Kazakhstan.