Kazakhstan Public Procurement and the Single Distributor SK-Pharmacy: Market Access Guide

1. Key takeaways

Procurement for the public healthcare system of Kazakhstan is executed centrally by the single distributor SK-Pharmacy, whose legal status is established by Article 247 of Code No. 360-VI. Since 2009, the company has centrally procured medicines and medical devices, providing centralized tender-based purchasing for public hospitals and clinics. The precondition for bidding is holding a valid national registration certificate of Kazakhstan: without a registration certificate, a product cannot enter the public procurement channel. For companies that have established local production or assembly in Kazakhstan, the single distributor also offers an additional channel in the form of long-term supply contracts of up to 10 years, which changes the economics of entering and holding this market. In practice, the single distributor is therefore both the gatekeeper and the counterparty: access decisions, tender participation and contract terms all run through the same institution, which makes a working relationship with it part of market strategy rather than an administrative detail.

2. Legal basis

3. Expert insights

Insight 1: the registration certificate is the ticket to public procurement, and this is determined by the market structure of Kazakhstan. The public healthcare system holds the main share of the medical market, and the only entrance to that market is centralized procurement. No registration certificate means no bidding eligibility, which makes registration in Kazakhstan not merely a compliance step but a market access step. Planning should therefore treat the certificate timeline as the first milestone of any commercial plan for this market. Delays in registration translate directly into lost tender cycles, which in this market are not evenly distributed across the year. Scheduling registration work against the tender calendar is therefore part of the access plan itself.

Insight 2: manufacturer price registration and adjustment have been folded into the 2026 integrated service. Under the joint orders No. 30 and No. 140, the one-window integrated service includes manufacturer price registration and adjustment together with the formation of the national medicines catalogue of Kazakhstan. This means registration and price access can be handled through the same digital entry point, which is a substantive convenience for companies planning to enter public procurement and reduces the number of parallel administrative tracks they must manage. The same entry point also simplifies later price adjustments, which otherwise require separate filings.

Insight 3: the core of the new procurement mechanism is more direct inquiries to manufacturers. Under the new mechanism confirmed by Order No. 110 of the Minister of Health, price formation is increasingly determined through direct inquiries to manufacturers, in order to reduce procurement costs and increase transparency. This favors manufacturers able to engage directly and requires adjustment from companies that rely on multi-layer distribution structures, whose margin model may come under pressure in tenders. Reviewing the distribution architecture before the next tender cycle is therefore a practical necessity rather than an optional exercise.

Insight 4: long-term contracts are the policy reward for localized production. For companies that establish local production or assembly in Kazakhstan, the single distributor offers long-term supply contracts. This policy makes localized packaging or assembly a viable strategy for long-term market positioning, and the contract length of up to 10 years gives the investment in local capacity a predictable payback horizon that pure import models cannot offer.

Insight 5: public procurement also involves international organization channels. Beyond centralized tenders, some products are procured through channels of international organizations such as the United Nations Development Programme and the United Nations Children’s Fund. The rules of these channels differ from centralized tenders and require separate handling, including separate registration of interest, separate documentation sets and separate price negotiation logic. For some product classes these channels are a meaningful share of volume, so ignoring them leaves part of the market uncovered.

4. Practical recommendations

1. Treat the registration certificate as the first precondition of public procurement access and protect it in project scheduling.
2. Within 2026, evaluate handling registration and manufacturer price registration together through the integrated service.
3. Manufacturers able to engage directly should evaluate the direct inquiry channel under the new procurement mechanism.
4. Companies with long-term market plans should evaluate localized packaging or assembly to qualify for long-term supply contracts.
5. Study international organization procurement channels separately and do not mix their rules with centralized tenders.

5. Verification checklist

• □ A valid national registration certificate of Kazakhstan is held
• □ Manufacturer price registration and adjustment have been evaluated for handling through the integrated service
• □ The inquiry channel under the new procurement mechanism (Order No. 110 of the Minister of Health) has been evaluated
• □ The feasibility of localized production or assembly to obtain a long-term contract has been evaluated
• □ The rules of international organization procurement channels have been studied separately
• □ The registration certificate information in bid documents matches the register record

Regulatory information verified as of October 29, 2026.

GRZAN provides registration and post-market compliance support for medical device manufacturers, importers and authorized representatives in Kazakhstan, including procurement access planning and price registration support. For inquiries, contact info@grzanglobal.com.