Trading Infrastructure Report 2026: Kazakhstan, Uzbekistan, Armenia, Georgia

1. Introduction and how to use this report

This report is written for founders, CTOs, heads of platform, and heads of engineering at trading businesses across Kazakhstan, Uzbekistan, Armenia, and Georgia. These are the four jurisdictions where the most meaningful trading infrastructure work is happening in the region in 2026.

How to read this report

The report is structured so that each section is useful on its own. If you already know which jurisdiction you are building in, skip the jurisdiction comparison and go straight to the technology section. If you are early in your thinking and comparing regions, read sections 2 and 3 first.

The technology section (Section 4) is the longest and the most technical. It is written for CTOs and senior engineers. The rest of the report is accessible to non-technical founders.

What this report does not cover

The report does not cover the following topics, because they are either outside our expertise or covered better by other publications:

• Tax planning and structuring, which depends on facts specific to each company
• Token economics and exchange listing strategy, which is a separate discipline
• Marketing, user acquisition, and community building, also separate disciplines
• Specific vendor contract negotiation and procurement
• Russian, Belarusian, and Central Asian jurisdictions outside the four covered, which have different operational realities that we have less direct experience with

2. The regional trading landscape in 2026

The region's trading infrastructure has changed significantly across the last four years. The factors driving the change include the geopolitical reshaping of the post-2022 period, the regulatory maturation in Kazakhstan and Uzbekistan, the emergence of Armenia and Georgia as neutral technology hubs, and the substantial capital flows from Russia, the UAE, Turkey, and China that have landed in the region looking for trading and investment infrastructure to operate on.

This section gives a market-map view of what exists today and where activity is concentrated.

Kazakhstan

Kazakhstan is the most mature trading infrastructure market in the region. The Kazakhstan Stock Exchange (KASE) is a functioning equities and fixed-income venue with meaningful daily volume. The Astana International Exchange (AIX), which operates under the AIFC framework, has positioned itself as a regional and international venue, with listings that include Kazakhstani sovereign debt and international equity products.

Freedom Holding Corp, with its Kazakhstani origins and US listing, has become one of the largest retail brokerage operations in the region, operating across equities, fixed income, and increasingly derivatives. Halyk Finance, Jusan Invest, and BCC Invest are the main domestic investment and brokerage operations. A number of digital asset exchanges operate under AFSA licenses, with Binance, CaspianEx, Biteeu, and others having registered locally.

For technology infrastructure, Kazakhstan combines the regulatory sophistication of AIFC with a developing but real engineering talent base. Almaty and Astana both have growing populations of trading-tech engineers. Colocation at KASE is limited but possible for firms with the right relationships. AIX infrastructure is newer and has better modern connectivity options.

Uzbekistan

Uzbekistan has moved fastest in the region over the last three years. The National Agency of Perspective Projects (NAPP), which took over capital market regulation from the Ministry of Economy and Finance in September 2023, has issued new frameworks for brokerage, asset management, and increasingly digital assets. The Republican Stock Exchange (Toshkent) and the Uzbek Republican Currency Exchange (UZEX) are the primary venues. Volumes on UZEX in particular are substantial, especially in currency operations.

The broker ecosystem is smaller than Kazakhstan but growing quickly. Local names include Alpari Uzbekistan, Avesta Invest, and a number of smaller operations. Foreign brokers are entering, often through partnership structures with local operators. The digital asset licensing regime has been tightened multiple times since 2022 and continues to evolve.

The technology ecosystem in Uzbekistan is earlier stage. Engineering talent exists, concentrated in Tashkent, but the depth of trading-tech-specific talent is lower than in Kazakhstan. Infrastructure choices for firms operating in Uzbekistan often involve hosting in the UAE, Turkey, or Singapore, with the operational entity in Tashkent.

Armenia

Armenia has emerged as a neutral technology hub, particularly for firms that want a Western-facing operational base with access to Russian-speaking engineering talent. The Central Bank of Armenia regulates capital markets and has been working on modernising the framework, although it remains less developed than AIFC. The Armenia Securities Exchange (AMX) operates but with modest volume compared to regional peers.

The Armenian trading-business activity is predominantly on the technology and operational side rather than in domestic venue operation. A significant population of trading engineering and infrastructure teams now operates from Yerevan, supporting trading businesses that are legally based elsewhere. Ameriabank, IDBank, and ACBA Bank are the main banks with trading-infrastructure-adjacent services.

For a firm looking at Armenia specifically, the commercial case is almost always about the engineering talent, the cost base, the English-language operational environment, and the ability to service clients across Central Asia, the Caucasus, MENA, and Europe from a neutral location. It is less about domestic licensing or domestic venue connectivity.

Georgia

Georgia, through the Georgian Stock Exchange (GSE) and the broader National Bank of Georgia framework, has been slowly modernising its capital markets infrastructure. The 2025 capital markets legislation introduced clearer frameworks for digital assets and expanded the scope of permissible brokerage activity. The volumes on GSE remain modest, but the regulatory direction is positive.

Like Armenia, the strongest commercial case for Georgia in 2026 is often the operational base rather than the domestic market. Georgia's tax regime, its EU association status, and its position as a bridge between Europe and Central Asia have attracted a significant number of trading-adjacent businesses to base operations in Tbilisi. Bank of Georgia and TBC Bank are the main banking partners, and both have meaningful capital-markets arms.

Engineering talent in Georgia is smaller than in Kazakhstan or Armenia but growing. The cost base is attractive. The regulatory environment is less developed but also less restrictive than more mature jurisdictions.

What this map implies for a new entrant

For most new trading businesses looking at the region in 2026, the practical structure that works best is a combination:

• Primary licensing in Kazakhstan (AIFC or AFSA), because the regulatory framework is the most developed and the cost and timeline are manageable
• Secondary entity in Armenia or Georgia for engineering, operations, and technology hosting, because the cost base and talent environment are favourable
• Banking relationships across multiple countries to manage fiat flows and avoid single points of failure
• Targeted expansion into Uzbekistan for specific market opportunities, particularly currency and regional equity flow

This multi-entity structure is more complex to operate than a single-jurisdiction approach, but it addresses the reality that no single country in the region provides the full stack of what a serious trading business needs. The firms we see operating most successfully in the region all have some version of this structure.

3. Jurisdiction comparison: licensing, capital, timelines

This section compares the four jurisdictions across the factors that most shape the decision of where to license and operate. The information is accurate as of early 2026. Regulatory frameworks in the region move, so always confirm specifics with a local legal advisor before committing to a path.

Kazakhstan: AIFC and AFSA

The Astana International Financial Centre operates under an English-common-law-based regulatory regime, independent of the broader Kazakhstani legal system. The AFSA (Astana Financial Services Authority) is the regulator. For trading businesses, AIFC is the most practical licensing path in the region.

Capital requirements vary by license type. A standard brokerage license typically requires paid-up capital in the range of several hundred thousand US dollars equivalent. A digital asset exchange license requires substantially more, typically seven figures. A market-making license sits between these.

The timeline from initial application to live operations is typically nine to fifteen months for a straightforward brokerage license and twelve to eighteen months for a digital asset exchange license. Firms that submit well-prepared applications with experienced legal counsel tend to be at the lower end of the range.

Banking access for AFSA-licensed firms is workable but requires effort. Local banks that have the operational maturity to serve AFSA-licensed firms include Halyk, Kaspi, and Bank CenterCredit. International correspondent banking adds complexity. The AIFC Banking Commission has been working on improving this, and conditions in 2026 are noticeably better than in 2023.