The Group permanently advances it’s risk management environment, to fit up-to-date challenges and risks the Group is exposed to. The Group is exposed to the following types of risks: credit risk, liquidity risk and market risk.

Credit risk

The Group is exposed to credit risk, which is the risk that a customer will be unable to pay amounts in full when due. The Group’s credit risk exposure arises primarily from our consumer finance business through the Fintech Platform. To manage credit risk during loan origination, the Group centralized all processes related to decision making, verification and accounting through it’s headquarters. The Group has developed an automated, centralized and big data-driven proprietary loan approval process that enables it to make instant credit decisions. The risk management division is responsible for maintaining credit risk assessment models and decision-making process. The quality of approved loans are monitored by risk management division on day-to-day basis with periodical validation of the models.

During the credit decision process, the Group uses proprietary risk algorithms and predictive credit risk assessment models for the evaluation of the risks of potential borrowers using statistical modelling based on (i) a wealth of proprietary internal data such as application, transactional, behavioral, shopping and payment history information, which is supplemented by (ii) external data such as data received from credit bureaus (First Credit Bureau LLP and State Credit Bureau JSC) and pension centre (the State Pension Payment Centre) with regard to each customer.

The additional proprietary data constantly accumulated around the Group’s customers’ activity that enables it to continuously deepen its credit decision process.

The risk management division, in terms of credit risk, consists of independent modelling, anti-fraud, monitoring and provisioning division.

Maximum Exposure

The Group’s maximum exposure to credit risk varies significantly and is dependent on both individual risks and general market economy risks. For financial assets recorded on statements of financial position, the maximum exposure equals to a carrying value of those assets prior to any offset or collateral. For financial guarantees and other contingent liabilities the maximum exposure to credit risk is the maximum amount the Group would have to pay if the guarantee was called on or in the case of commitments, if the loan amount was called on.

As at 31 December 2024 and 2025, the maximum exposure to credit risk after offset and collateral was equal to its carrying value of all financial assets except for loans to customers.

As at 31 December 2024 and 2025, the maximum exposure to credit risk after offset and collateral of loans to customers were KZT 5,086,464 million and KZT 6,281,705 million, respectively.

The Group holds collateral or other credit enhancements to mitigate credit risk associated with financial assets. The main types of collateral obtained are as follows:

Although, the Group uses collateral as credit enhancement to mitigate its exposure to credit risk, major part of its loan portfolio is represented by unsecured loans. Thus, as at 31 December 2024 and 2025, unsecured gross carrying amount of loans to customers were KZT 5,359,101 million and KZT 6,606,933 million, respectively.

As at 31 December 2024 and 2025, credit impaired loans with a net carrying value of KZT 29,418 million and KZT 37,469 million, respectively were either fully or partially collateralized, reflecting the extent to which collateral and other credit enhancements mitigate credit risk.

The tables below present information about the significant changes in the gross carrying amount of loans to customers during the period that contributed to changes in the allowance for impairment losses during the years ended 31 December 2024 and 2025:


	Stage 1			Stage 2			Stage 3
	12-month ECL			Lifetime ECL			Lifetime ECL			POCI			Total
Loans to customers at amortized cost

Gross carrying amount as at 1 January 2024		4,048,478			55,804			363,703			10,504			4,478,489

Changes in the gross carrying amount
- Transfer to Stage 1		65,305			(13,657	)		(51,648	)		—			—
- Transfer to Stage 2		(76,678	)		102,681			(26,003	)		—			—
- Transfer to Stage 3		(266,377	)		(24,694	)		291,071			—			—
New loans to customers originated or purchased		4,507,341			—			—			21,310			4,528,651
Loans to customers that have been repaid or derecognized		(2,830,265	)		(33,883	)		(18,736	)		(8,678	)		(2,891,562	)
Write-offs		—			—			(89,272	)		—			(89,272	)
Recovery from off-balance loans to customers		—			—			16,137			—			16,137

Gross carrying amount as at 31 December 2024		5,447,804			86,251			485,252			23,136			6,042,443


	Stage 1			Stage 2			Stage 3
	12-month ECL			Lifetime ECL			Lifetime ECL			POCI			Total
Loans to customers at amortized cost

Gross carrying amount as at 1 January 2025		5,447,804			86,251			485,252			23,136			6,042,443

Changes in the gross carrying amount
- Transfer to Stage 1		78,937			(17,388	)		(61,549	)		—			—
- Transfer to Stage 2		(118,983	)		153,117			(34,134	)		—			—
- Transfer to Stage 3		(378,113	)		(55,316	)		433,429			—			—
New loans to customers originated or purchased		5,348,309			—			—			(1,934	)		5,346,375
Loans to customers that have been repaid or derecognized		(3,719,369	)		(41,284	)		(24,301	)		(1,321	)		(3,786,275	)
Write-offs		—			—			(118,895	)		—			(118,895	)
On acquisition of subsidiary		32,578			4,420			4,944			—			41,942
Recovery from off-balance loans to customers		—			—			18,336			—			18,336

Gross carrying amount as at 31 December 2025		6,691,163			129,800			703,082			19,881			7,543,926

The Group uses an internal rating model to classify individually significant loans to customers in different risk categories:


	Stage 1			Stage 2			Stage 3
	12-month ECL			Lifetime ECL			Lifetime ECL			POCI			Total
Loans to customers that are individually assessed for impairment
Grades: Low to fair risk		5,120			—			—			—			5,120
Grade: Impaired		—			—			5,260			—			5,260
Loans to customers that are collectively assessed for impairment		5,442,684			86,251			479,992			23,136			6,032,063

Total gross carrying amount		5,447,804			86,251			485,252			23,136			6,042,443
Allowance for impairment losses		(77,521	)		(22,378	)		(193,759	)		(2,185	)		(295,843	)
Carrying amount as at 31 December 2024		5,370,283			63,873			291,493			20,951			5,746,600


	Stage 1			Stage 2			Stage 3
	12-month ECL			Lifetime ECL			Lifetime ECL			POCI			Total
Loans to customers that are individually assessed for impairment
Grades: Low to fair risk		4,172			—			—			—			4,172
Grade: Impaired		—			—			4,428			—			4,428
Loans to customers that are collectively assessed for impairment		6,686,991			129,800			698,654			19,881			7,535,326

Total gross carrying amount		6,691,163			129,800			703,082			19,881			7,543,926
Allowance for impairment losses		(74,162	)		(26,061	)		(270,058	)		(1,483	)		(371,764	)
Carrying amount as at 31 December 2025		6,617,001			103,739			433,024			18,398			7,172,162


	Stage 1			Stage 2		Stage 3
	12-month ECL			Lifetime ECL		Lifetime ECL		Total
Due from banks
High grade (A- and higher)		36,464			—		—		36,464
Investment grade (BBB+ - BBB-)		1,328			—		—		1,328
Investment grade (BB+ - B-)		123			—		—		123

Total gross carrying amount		37,915			—		—		37,915
Allowance for impairment losses		(7	)		—		—		(7	)
Carrying amount as at 31 December 2024		37,908			—		—		37,908


	Stage 1			Stage 2		Stage 3
	12-month ECL			Lifetime ECL		Lifetime ECL		Total
Due from banks
High grade (A- and higher)		49,946			—		—		49,946
Investment grade (BBB+ - BBB-)		962			—		—		962
Not rated		1,051			—		—		1,051

Total gross carrying amount		51,959			—		—		51,959
Allowance for impairment losses		(8	)		—		—		(8	)
Carrying amount as at 31 December 2025		51,951			—		—		51,951


	Stage 1		Stage 2		Stage 3
	12-month ECL		Lifetime ECL		Lifetime ECL		Total
Investment debt securities
High grade (A- and higher)		36,415		—		—		36,415
Investment grade (BBB+ - BBB-)		1,373,391		—		—		1,373,391
Non-Investment grade (BB+ - B-)		4,957		—		—		4,957
Not rated		70,614		567		3,261		74,442
Сarrying amount as at 31 December 2024		1,485,377		567		3,261		1,489,205


	Stage 1		Stage 2		Stage 3
	12-month ECL		Lifetime ECL		Lifetime ECL		Total
Investment debt securities
High grade (A- and higher)		243,391		—		—		243,391
Investment grade (BBB+ - BBB-)		867,166		—		—		867,166
Non-Investment grade (BB+ - B-)		2,395		—		—		2,395
Not rated		37,624		3,663		561		41,848
Сarrying amount as at 31 December 2025		1,150,576		3,663		561		1,154,800

Financial assets, other than loans to customers and other financial assets, are graded according to their external credit ratings issued by an international rating agencies, such as Standard and Poor’s, Fitch and Moody’s Investors Services. The highest possible rating is AAA.


	A- and higher		BBB+ to BBB-		BB+ to B-		CCC+ and lower		Not rated		Total
Gross carrying value
31 December 2024
Cash and cash equivalents, excluding cash on hand		203,364		210,591		1,077		273		7,247		422,552
Mandatory cash balances with NBRK		—		57,307		—		—		—		57,307
Due from banks		36,457		1,328		—		—		130		37,915
Investment securities and derivatives		48,687		1,378,268		4,957		—		75,620		1,507,532

31 December 2025
Cash and cash equivalents, excluding cash on hand		137,756		445,137		133,683		—		5,203		721,779
Mandatory cash balances with NBRK		—		305,126		—		—		—		305,126
Due from banks		41,946		962		2,420		—		6,631		51,959
Investment securities and derivatives		243,712		867,317		24,039		—		43,012		1,178,080

As at 31 December 2024 and 2025, all loan commitments and financial guarantee contracts of the Group are classified in Stage 1 (12-month ECL) and have “low to fair” risk grade.

As a result of the Group’s forbearance activities, loans to customers might be modified. Modification doesn't lead to a material change in the net present value (“NPV”), therefore the Group doesn't recognise a modification gain/loss. The following tables refer to modified loans to customers where modification does not result in derecognition.

The net carrying amount of loans to customers at time of modification that are modified during the years ended 31 December 2024 and 2025 were KZT 117,763 million and KZT 160,156 million, respectively. The gross carrying amount of modified loans to customers for which the allowance for impairment losses changed from lifetime to 12-month ECL in the years ended 31 December 2024 and 2025 were KZT 38,744 million and KZT 101,774 million, respectively.

The Group has performed a sensitivity analysis on its loan portfolio. For the purpose of ECL estimation the Group assumes a scenario of a 1 percentage point shift of the nominal Exchange rate of USD and base rate KZT.

A shift in the baseline nominal Exchange rate of USD by +/- 1 percentage point with respective correction of upside and downside scenarios lead to change in loss allowance amount by KZT -1,447/+1,407 million respectively.

A shift in baseline Short-term interest rate by +/- 1 percentage point with respective correction of upside and downside scenarios lead to change in loss allowance amount by KZT -1,386/ +1,381 million respectively.

Liquidity risk

The liquidity management framework of the Group mainly consists of following instruments:

The liquidity risk is managed considering specific aspects of Kazakhstan economy, in particular limited funding instruments and possible dollarization due to currency devaluation expectations.

The Group devotes great significance to social media marketing, to support the brand of the Group and mitigate various risks such as liquidity and reputational risks. The division of social media marketing covers mass media, social networks, blogs and other sources of information, available to current or potential customers.

A major part of the Group’s obligations consists of customer accounts of individuals, with nominal maturity under 2 years. However, 92% of deposits in 2025 were rolled over, which absent a liquidity event such as a run on the bank, allows the Group to maintain a long-term stable funding base. The average amount of individuals’ customer accounts balance is KZT 1,296 thousand as at 31 December 2025, which is another indicator of diversification and stability of the funding base.

The Group retains a significant amount of high quality liquid assets, which consists mainly of cash, deposits within NBRK, short-term and mid-term notes of NBRK and bonds issued by the Ministry of Finance of the Republic of Kazakhstan.

Market risk

The Group's market risk arises from fluctuations in the value of financial instruments because of changes in market prices whether those changes are caused by factors specific to the individual instrument or factors affecting all instruments traded in the market. The Group has established various limits on operations with securities, including instrument specific limits, in order to balance profit and risk in the securities portfolio. The Group's portfolio is predominantly comprised of Kazakhstan government debt securities.

The contractual maturities of assets and liabilities of the Group has modest gaps, which provides possibilities of instant reactions on changes of market interest rates. The Group has significant amounts of high quality liquid assets with a short maturity which helps to minimize the sensitivity to a sharp increase of interest rates in case of a liquidity shortfall on the market.

An analysis of the financial assets and liabilities liquidity and interest rate risks is presented in the following table on discounted basis:


	Up to 1 month			1 month to 3 months			3 months to 1 year			1 year to 5 years		Over 5 years		2024 Total
Cash and cash equivalents		388,707			6			—			—		—		388,713
Due from banks		2,267			2,315			33,016			310		—		37,908
Investment securities		153,419			81,250			358,229			627,589		268,718		1,489,205
Loans to customers		485,611			728,514			2,242,972			2,039,044		250,459		5,746,600
Total interest bearing financial assets		1,030,004			812,085			2,634,217			2,666,943		519,177		7,662,426

Cash and cash equivalents		230,757			—			—			—		—		230,757
Mandatory cash balances with National Bank of the Republic of Kazakhstan		57,307			—			—			—		—		57,307
Derivative financial assets		1,011			2,340			7,126			6,672		—		17,149
Investment securities		417			—			—			—		60		477
Other financial assets		29,793			—			—			—		—		29,793
Total non-interest bearing financial assets		319,285			2,340			7,126			6,672		60		335,483
Total financial assets		1,349,289			814,425			2,641,343			2,673,615		519,237		7,997,909

Due to banks		24,474			—			—			—		—		24,474
Customer accounts		672,334			970,692			3,738,339			46,994		5,776		5,434,135
Debt securities issued		51,050			—			—			—		—		51,050
Subordinated debt		3,300			—			59,116			—		—		62,416
Total interest bearing financial liabilities		751,158			970,692			3,797,455			46,994		5,776		5,572,075

Customer accounts		1,127,815			—			—			—		—		1,127,815
Trade liabilities		—			22,454			—			—		—		22,454
Derivative financial liabilities		133			129			—			—		—		262
Other financial liabilities		18,992			—			—			—		—		18,992
Total non-interest bearing financial liabilities		1,146,940			22,583			—			—		—		1,169,523
Total financial liabilities		1,898,098			993,275			3,797,455			46,994		5,776		6,741,598
Guarantees issued and similar commitments		250			32			423			5,251		—		5,956
Total financial liabilities and commitments		1,898,348			993,307			3,797,878			52,245		5,776		6,747,554
Liquidity surplus/(gap)		(549,059	)		(178,882	)		(1,156,535	)		2,621,370		513,461
Cumulative liquidity surplus/(gap)		(549,059	)		(727,941	)		(1,884,476	)		736,894		1,250,355

Interest sensitivity surplus/(gap)		278,846			(158,607	)		(1,163,238	)		2,619,949		513,401
Cumulative interest sensitivity surplus/(gap)		278,846			120,239			(1,042,999	)		1,576,950		2,090,351


	Up to 1 month			1 month to 3 months			3 months to 1 year			1 year to 5 years		Over 5 years		2025 Total
Cash and cash equivalents		706,448			—			—			—		—		706,448
Due from banks		2,135			1,930			47,886			—		—		51,951
Investment securities		54,601			270,644			177,690			500,541		151,325		1,154,801
Loans to customers		882,217			919,753			2,705,255			2,662,182		2,755		7,172,162
Total interest bearing financial assets		1,645,401			1,192,327			2,930,831			3,162,723		154,080		9,085,362

Cash and cash equivalents		196,695			—			—			—		—		196,695
Mandatory cash balances with National Bank of the Republic of Kazakhstan		305,126			—			—			—		—		305,126
Derivative financial assets		22,378			2,073			6			—		80		24,537
Investment securities		418			—			—			—		63		481
Other financial assets		57,019			40,406			—			—		—		97,425
Total non-interest bearing financial assets		581,636			42,479			6			—		143		624,264
Total financial assets		2,227,037			1,234,806			2,930,837			3,162,723		154,223		9,709,626

Due to banks		15,712			471			—			—		—		16,183
Customer accounts		1,496,544			1,414,973			3,379,009			37,009		5,776		6,333,311
Debt securities issued		—			—			5,420			326,572		—		331,992
Total interest bearing financial liabilities		1,512,256			1,415,444			3,384,429			363,581		5,776		6,681,486

Customer accounts		1,197,975			—			—			—		—		1,197,975
Trade liabilities		255,758			84,530			6,113			—		—		346,401
Derivative financial liabilities		1,010			1,747			4,302			—		—		7,059
Other financial liabilities		39,485			373			4,773			9,224		—		53,855
Total non-interest bearing financial liabilities		1,494,228			86,650			15,188			9,224		—		1,605,290
Total financial liabilities		3,006,484			1,502,094			3,399,617			372,805		5,776		8,286,776
Guarantees issued and similar commitments		—			218			—			5,055		—		5,273
Total financial liabilities and commitments		3,006,484			1,502,312			3,399,617			377,860		5,776		8,292,049
Liquidity surplus/(gap)		(779,447	)		(267,506	)		(468,780	)		2,784,863		148,447
Cumulative liquidity surplus/(gap)		(779,447	)		(1,046,953	)		(1,515,733	)		1,269,130		1,417,577

Interest sensitivity surplus/(gap)		133,145			(223,117	)		(453,598	)		2,799,142		148,304
Cumulative interest sensitivity surplus/(gap)		133,145			(89,972	)		(543,570	)		2,255,572		2,403,876

As at 31 December 2024 and 2025, guarantee deposits in favour of international payments systems included in due from banks were KZT 37,782 million and KZT 43,940 million, respectively.

Based on prior experience, the Group considers it highly unlikely that all customer accounts seek repayment on maturity. Historically the majority of such deposits are rolled over.

The Group manages fair value interest rate risk through periodic estimation of potential losses that could arise from adverse changes in market conditions. The Risk Management Department conducts monitoring of the Group’s current financial performance, estimates the Group’s sensitivity to changes in interest rates and its influence on the Group’s profitability.

The sensitivity analysis includes interest rate risk, which has been determined based on “reasonably possible changes in the risk variable”. The level of these changes is determined by management and is contained within the risk reports provided to key management personnel.

As at 31 December 2025, the impact on profit before income tax due to a +/-3 p.p. change in interest rate amounted -/+ KZT Nil (2024: -+/- KZT Nil).

As at 31 December 2025, the impact on equity due to a +/-3 p.p. change in interest rate amounted KZT -49,348 million /KZT+55,739 million (2024: KZT -74,854 million /KZT+85,862 million).

Currency risk

The Group manages its currency risk by keeping modest open currency position. The Group only issues loans to customers in tenge, which protects the Group from hidden currency risk in case of a currency devaluation.

The Group’s exposure to foreign currency exchange rate risk is presented in the table below:


	Tenge			USD USD 1 = KZT 525.11			EUR EUR 1 = KZT 546.74			Other currency			2024 Total
Non-derivative financial assets
Total non-derivative financial assets		7,552,496			388,027			25,336			14,899			7,980,758

Non-derivative financial liabilities
Total non-derivative financial liabilities		6,153,015			579,664			6,247			2,673			6,741,599

NET POSITION ON NON- DERIVATIVE FINANCIAL INSTRUMENTS		1,399,481			(191,637	)		19,089			12,226

Derivative financial instruments
Accounts payable on spot and derivative contracts		(251,281	)		(95,760	)		(59,595	)		(2,709	)		(409,345	)
Accounts receivable on spot and derivative contracts		69,674			316,929			43,192			1,340			431,135
NET POSITION ON DERIVATIVE FINANCIAL INSTRUMENTS		(181,607	)		221,169			(16,403	)		(1,369	)		21,790

NET POSITION		1,217,874			29,532			2,686			10,857


	Tenge			USD USD 1 = KZT 505.53			EUR EUR 1 = KZT 593.44			TRY TRY 1= KZT 11.80			Other currency			2025 Total
Non-derivative financial assets
Total non-derivative financial assets		8,883,016			563,151			20,214			199,829			18,883			9,685,093

Non-derivative financial liabilities
Total non-derivative financial liabilities		7,060,636			903,121			9,884			310,435			2,861			8,286,937

NET POSITION ON NON- DERIVATIVE FINANCIAL INSTRUMENTS		1,822,380			(339,970	)		10,330			(110,606	)		16,022

Derivative financial instruments
Accounts payable on spot and derivative contracts		(299,866	)		(21,304	)		(70,085	)		—			(63,232	)		(454,487	)
Accounts receivable on spot and derivative contracts		17,418			316,357			62,938			537			61,127			458,377
NET POSITION ON DERIVATIVE FINANCIAL INSTRUMENTS		(282,448	)		295,053			(7,147	)		537			(2,105	)		3,890

NET POSITION		1,539,932			(44,917	)		3,183			(110,069	)		13,917

Currency risk sensitivity analysis

The Group analyzed sensitivity to an increase and decrease in the USD, EUR and TRY against the KZT. +/-25% is the sensitivity rate for USD, EUR and +25%/-50% is the sensitivity rate for TRY used when reporting foreign currency risk internally to key management personnel and represents management’s assessment of the possible change in foreign currency exchange rates. The sensitivity analysis includes only outstanding foreign currency denominated monetary items and adjusts their translation as at 31 December 2024 and 2025.

As at 31 December 2025, the impact on profit or loss and on equity due to +/-25% change in USD rate were KZT +/-11,229 million (2024: KZT +/-7,383 million).

As at 31 December 2025, the impact on profit or loss and on equity due to +/-25% change in EUR rate were KZT +/- 796 million (2024: KZT +/- 672 million).

As at 31 December 2025, the impact on profit or loss and on equity due to +25% and -50% change in TRY rate were KZT -27,517 million and KZT +55,035 million, respectively (2024: KZT Nil).