November 2026

An analysis of the Register of Well-Known Trademarks of the Republic of Kazakhstan: all 85 registrations from 10 May 2006 to 23 June 2026, in the context of the new Recognition Rules of 10 February 2026

In Brief

Recognition of well-known trademarks (“WKTMs”) in Kazakhstan has been under way since 2006 — the first entry in the Register is dated 10 May 2006. Over twenty years, 85 trademarks have been recognized as well-known, whereas registrations of “ordinary” trademarks number in the tens of thousands.

Because the Register has been maintained since the institution of recognition of well-known trademarks was introduced, the 85 entries are not a sample or a snapshot of some period but the complete list of all WKTMs ever recognized as such in Kazakhstan.

Such rarity makes WKTM status the hardest to achieve and, at the same time, the strongest and most prestigious tool of brand protection. But the Register has another side: throughout the history of recognitions, WKTMs have never appeared evenly. During the first three years not a single WKTM appeared, while in one year seventeen were recognized.

One more circumstance makes an analysis of the Register timely: on 10 February 2026, the new Rules for Recognition of a Trademark as Well-Known entered into force¹. They double the requirements for the sociological survey, formalize for the first time a list of evidence (including digital evidence), and introduce a new ground for refusal.

Methodology

This analysis is based on the official Register of Well-Known Trademarks of the Republic of Kazakhstan as of August 2026. All 85 entries were processed; registration numbers run consecutively from 1 to 85 without gaps.

Because the Register has been maintained since 2006, these 85 entries cover the entire history of the institution without remainder. This is a rare case in legal statistics where the object of analysis is not a sample but the whole population: no conclusions about structure or dynamics require caveats about representativeness.

For each entry, the registration date, status, right holder, name of the trademark, and bulletin number and date were recorded. Right-holder names were normalized: in the Register they appear duplicated in Kazakh and English and with different legal forms.

The Register as a Whole

Indicator	Value
Total registrations	85
Valid	77
Lost status	8
Right holders	53
Period	2006–2026 (entire history of the Register)

What WKTM Status Provides

Before analyzing the numbers, it is worth explaining why this status is sought at all. An ordinary trademark is protected only for the goods and services declared at registration. A well-known trademark is protected for any goods and services — regardless of those for which it was recognized as well-known. Several practical advantages follow:

• Protection beyond the Nice classes. A trademark can be registered in all 45 classes, but this is expensive and still does not cover goods that will appear tomorrow. Well-known status solves the problem differently — it removes the link to a list of goods;

• Blocking third-party applications. Designations identical or confusingly similar to a well-known trademark are refused registration regardless of the type of goods and services;

• Cancellation of earlier registrations — within five years from the date of registration of the similar trademark, and after that period provided that such a trademark is capable of misleading consumers as to the goods or their manufacturer;

• Immunity from cancellation for non-use. An ordinary registration may be cancelled by an interested person in respect of unused goods and services. This does not apply to a well-known trademark;

• Suppression of infringements of WKTM rights on any products, including infringements on the Internet and in domain names;

• No prior registration required. A trademark may be recognized as well-known regardless of whether it is registered in Kazakhstan as an ordinary trademark;

• Valuation effect. The status is taken into account when valuing intangible assets and, accordingly, when recognizing them on the balance sheet and in amortization charges.

There is also a less obvious advantage, which in Kazakh practice has proved almost decisive for certain brands: recognition as well-known makes it possible to overcome the lack of distinctiveness. For an ordinary registration, the law sets a strict list of grounds for non-registrability — descriptiveness, indication of the kind of goods, shape dictated by functionality. For recognition of a trademark as well-known, such grounds historically did not exist, and refusal could follow on two grounds — insufficient evidence of renown or the existence of a valid trademark with an earlier priority for the same goods. The logic is clear: if consumers unambiguously associate a designation with a specific product, distinctiveness is proved by the very fact of renown.

In Kazakh practice, protection on this basis was obtained by three-dimensional trademarks that had been refused ordinary registration as shapes dictated by functionality; by combination trademarks, all of whose word elements had been excluded from protection by a disclaimer at registration; and by designations caught by the ban on using prefixes such as “BIO” and “ECO” without the permission of the competent authorities, although the legislator never specified those authorities.

Important for foreign right holders: recognition of a trademark as well-known in another country does not automatically give rise to such status in Kazakhstan, just as registration of an “ordinary” tradetrademark outside Kazakhstan has no legal force in Kazakhstan. The procedure must be completed in full, proving renown specifically among Kazakh consumers.

How Trademarks Are Recognized: Procedure and Evidence

The application is filed with the authorized body — the Ministry of Justice of the Republic of Kazakhstan — and must relate to a single trademark. It states the owner’s details and address for correspondence, data on the legal protection of the trademark, the image, the list of goods and services for which the trademark is claimed to be well-known, and the date from which, in the applicant’s opinion, the trademark became well-known.

The core of the evidence is a sociological survey of consumers conducted by a specialized independent organization in the territory of Kazakhstan. In addition to the survey, information is submitted on the intensity and manner of use of the trademark, sales volumes and distribution channels, the average annual number of consumers, the value of the trademark, advertising expenditure, the number of licensees and distributors, and the existence of registrations abroad.

1. The application is accepted for examination, and information about it is published in the official source so that interested persons may submit reasoned objections to recognition;

2. Three months after the date of publication, a meeting of the Commission for Recognition of a Trademark as Well-Known is scheduled. If third parties object, or if the arguments are insufficiently persuasive, there may be several meetings;

3. The Commission’s decision may be appealed in court;

4. In the event of a positive decision, the date from which the trademark is recognized as well-known is set, a serial number is assigned, and after payment of the state fee the trademark is entered in the State Register and information about it is published in the “Industrial Property” bulletin:

In established practice, the procedure takes from six months to a year; the term of a WKTM is ten years from the date the trademark is recognized as well-known.

Renewing the status means, in effect, going through the proof of renown anew: the owner again submits evidence. In other words, well-known status is not a perpetual privilege but a condition that must be confirmed every ten years.

The New Rules of 10 February 2026

The new Rules for Recognition of a Trademark as Well-Known entered into force on 10 February 2026. The changes affect all three key elements of the procedure.

1. Survey: The Sample Is Doubled

• 2002: the first Instruction on Recognition of a Trademark as Well-Known in the Republic of Kazakhstan was approved², which laid down the basic legal framework for the procedure on the basis of the 1999 law;

• 2010: the 2002 Instruction³ was repealed. A new procedure for examining applications was introduced in its place. During this period, the requirements for the evidence base and for proof of brand recognition were tightened.

• 2026 (the largest reform): fundamentally new Rules for Recognition of a Trademark or Designation Used as a Trademark as Well-Known were approved⁴, but additional clarifications were already made to them in July 2026.

What changed fundamentally in 2026?

The 2026 reform substantially detailed the requirements for applicants, making the procedure more transparent but stricter. In particular, the document requirements have been specified: a strict list of financial and business documentation has been fixed. The applicant must now attach distribution agreements, invoices, customs declarations, archive catalogues and sales reports for the entire claimed period.

The survey requirement is the most expensive element of the procedure, and this requirement has changed radically. The 2002 Rules required at least 3,000 respondents in at least six localities, 500 people in each. The bar was then substantially lowered — to 800 people in eight cities. From 2026, the sample has been doubled: at least 200 respondents in each of eight cities, at least 1,600 people in total.

The practical consequence is simple. The survey is conducted by a marketing company, and by market benchmarks of recent years it cost roughly KZT 4.5 million for a sample of 800 people. Doubling the sample, other things being equal, leads to a comparable increase in cost — that is, entry into the procedure has become noticeably more expensive. For a right holder planning recognition, this means that a budget calculated under the previous rules needs to be revised.

In the CIS countries there is no single fixed figure for the total number of respondents for the whole Commonwealth, since the patent office of each country sets its own regulations. National requirements determine the minimum sample size per locality and the geographic coverage.

In Kazakhstan (population 20.4 million), the requirements are regulated by the 2026 rules of the Ministry of Justice:

• Geographic coverage: the survey must be conducted in the capital (Astana), cities of republican significance (Almaty, Shymkent) and in at least 5 cities of regional significance.

• Number of respondents: at least 200 people in each of the localities surveyed.

• Minimum total volume: automatically at least 1,600 people (8 cities with 200 respondents each).

Kazakh legislation (including the new 2026 Rules) contains no fixed percentage threshold of recognition of a trademark that would automatically guarantee its recognition as well-known. The Commission decides on the basis of a comprehensive assessment of all the evidence.

Requirements in Other Countries

Russia (146.0 million people). Rospatent relies on the “Recommendations for Conducting a Consumer Survey”. What matters here is not so much the total number of respondents as their correct geographic distribution:

• Geographic coverage: the survey must be conducted in at least 6 large cities of the country. Moscow and St Petersburg are always included.

• Number of respondents: at least 500 people in total in the two largest cities (as a rule, 250 or more each in Moscow and St Petersburg) and at least 125 people in each of the other selected cities.

• Minimum total volume: in practice, the leading centers (VTsIOM, the Institute of Sociology of the Russian Academy of Sciences) form a representative sample of 1,500–2,000 people for Rospatent.

In most other countries of the region (Belarus (9.1 million), Uzbekistan (38.0 million), Kyrgyzstan (7.4 million), Azerbaijan (10.2 million)), legislation uses a flexible wording: the sample must be statistically significant and representative.⁵

• Patent offices require coverage of the capital and large regional centers.

• The average standard for passing the local commission is 1,000 to 1,500 respondents across the whole republic, divided proportionally to the population of the regions.

Important Nuances

• Product specificity: the figures above (1,500+) are relevant for the mass market (B2C). If your product is specialized (for example, B2B equipment, rare IT platforms or medical equipment), the persons surveyed are not ordinary citizens but narrow specialists (experts, buyers). In that case, the sample size may lawfully be as small as 100–300 people for the whole country.

• Recognition rate: it is not enough simply to recruit people — the threshold for treating a brand as well-known is considered to be when at least 60–70% of surveyed consumers confidently recognize the trademark and associate it specifically with your company.

In most of the world’s leading countries (USA (347 million), European Union (450 million), China (1,408 million), Japan (123.1 million)), there are no minimum limits on the number of consumers surveyed fixed in law. Instead of fixed numbers, courts and patent offices assess the methodological correctness, representativeness and statistical margin of error of the study.

In practice, for mass markets (B2C), samples of 500 to 1,500 respondents are considered the standard in international jurisprudence.

USA (USPTO and federal court standards): there is no fixed minimum. If the audience is narrow, courts accept samples of 300–400 people. For mass-market goods, samples of 800–1,200 people are recognized as the standard. However, the correct definition of the consumer “universe” is more important than the numbers. If random people on the street are surveyed instead of actual buyers of the product, a court will reject the survey even if it covers 10,000 people. The permissible statistical margin of error should not exceed 4–5%.

The European Union Intellectual Property Office (EUIPO) and the European Court of Justice (ECJ) assess the renown of a brand both on the scale of individual countries and of the Union as a whole. There are no precise normative figures, and the volumes depend on the standards of the particular research institutes (for example, Eurobarometer). Usually, for one large European country (Germany, France), the sample is 1,000 respondents. The key factor is geographic coverage. If renown is claimed at EU level, surveys must be conducted in several representative member states (for example, covering Western, Southern and Eastern Europe).

The China National Intellectual Property Administration and the courts of the PRC approach the question of renown extremely strictly owing to the high density of the local market. There is no official minimum threshold in the law, but in practice the scale of surveys here is the largest in the world. For nationwide recognition of a B2C brand, research agencies form a sample of 2,000 to 5,000 people, which, given the much larger population, is comparable to the current Kazakh requirement of 1,600 people.

Unlike the CIS countries, where the emphasis is often on formal administration (the number of cities and the exact number of questionnaires), in the world’s leading practices the key importance lies in:

1. Recognition rate: for a brand to be recognized as well-known in the USA and the EU, the level of unaided or aided recognition must be at least 50–70% of the target audience.

2. Control group: the survey must include a “control” (fictitious or little-known similar) trademark in order to exclude random guessing. If respondents begin to “recognize” the fictitious trademark as well, the results of the main study are invalidated.

In our view, the above comparison is not in Kazakhstan’s favor: despite the far larger populations of the leading countries mentioned, Kazakhstan’s requirements for the number of respondents are much higher, which probably unjustifiably increases the cost of a public opinion survey and, consequently, the cost of having a trademark recognized as well-known.

In Kazakhstan, the new 2026 Rules expressly list the documents to be attached to the application:

• documents on the scale and duration of use: supply, sale and purchase and distribution agreements, invoices, waybills, sales reports, archive documents, first samples of packaging, catalogues;

• advertising and marketing materials, including layouts, video clips, banners and outdoor advertising, as well as confirmation of advertising expenditure — agreements, invoices, acceptance certificates, data on advertising campaigns;

• publications and mentions in the media, including online sources;

• analytical reports of research companies;

• financial and accounting documents on the volumes of production and sales under the claimed designation;

• statistics of website visits and social media pages;

• search query data — Google Trends, Yandex Wordstat;

• information on prizes, awards and inclusion in industry rankings;

• certificates of participation in exhibitions and competitions;

• letters and confirmations from partners, counterparties and retail chains;

• marketplace data on sales and popularity of the product;

• expert opinions of industry specialists;

• results of a sociological or marketing study on the renown of the designation.

The appearance in this list of search statistics, marketplace data and social media metrics is a substantive change, not a technical one. It means that a brand’s digital footprint has for the first time acquired the status of independent evidence. For brands that grew up mainly online, this rather simplifies proof than complicates it: where archive invoices and catalogues were once required, an analytics export now works. The flip side is that such data must be collected in advance and kept, since historical snapshots are hard to reconstruct after the fact.

A New Ground for Refusal Has Appeared

The following has been added to the previous grounds: a designation that lacks distinctiveness, is false, or is capable of misleading consumers is not recognized as well-known.

This is the most serious of the changes — in substance it narrows the advantage of the institution described above. Previously, lack of distinctiveness did not prevent recognition, and it was by this route that protection was obtained by some designations that had been refused ordinary registration. How the new ground will be applied in practice will be shown by future decisions of the Commission: if established renown continues to be treated as evidence of acquired distinctiveness, the change will prove technical; if not, one of the key scenarios for using the institution will be closed.

Registrations by Year: The Institution Works in Waves

Year	Trademarks	Year	Trademarks
2006	4	2016	1
2007	2	2017	2
2008	4	2018	4
2009	6	2019	3
2010	0	2020	8
2011	0	2021	17
2012	0	2022	7
2013	2	2023	1
2014	0	2024	2
2015	13	2025	3
		2026 (7 months)	6

The table shows that the Register grew not evenly but in jumps:

• 2006–2009 — launch of the institution: 16 trademarks in the first four years, mainly international brands. The most intensive start in the entire history of the Register;

• 2010–2014 — effective standstill: two trademarks in five years, including three consecutive calendar years without a single registration;

• 2015 — 13 trademarks, 11 of which were recognized on just two days, 16 and 28 September. This was not a flow of applications but a one-off examination of an accumulated pool: five RG Brands, two Toyota, two Lexus, two Toffifee;

• 2021 — a record 17 trademarks, again in blocks: three Kaspi on one day, five Alina Group on two dates, two WTM Establishment;

• 2023–2025 — a new decline to 1–3 trademarks a year;

• 2026 — 6 trademarks in seven months, the second-best result of the five years, based on applications filed under the old requirements. This figure does not show how many applications were filed after the new rules were introduced.

Part of this unevenness is explained by the evidentiary requirements. The five-year trough of 2010–2014 falls in the period of Rules that required a survey of at least 3,000 respondents — a sample that made the procedure accessible to only a few. The surges of 2015 and 2021 fall in a period when the survey requirement was 800 people, that is, three and a half times milder. The coincidence does not prove a causal link: the dynamics were also affected by the Commission’s working practice, the accumulation of unexamined applications, and the general activity of right holders. But the scale of the divergence — 2 trademarks in five years versus 30 in two — is too large to be explained by chance alone.

If this relationship is real, then raising the bar to 1,600 respondents from February 2026 should be read as a signal: the flow of registrations is likely to narrow again. The six trademarks recognized in the seven months of 2026 relate exclusively to applications filed under the previous rules.

The practical conclusion for a right holder remains the same: recognition as well-known cannot be planned as a process with a predictable timeline. The history of the Register shows that decisions are taken in batches, and getting into such a batch largely determines the actual timeline.

Largest Portfolio Holders

Right holder	Country	Trademarks
RG Brands	Kazakhstan	6
Alina Group	Kazakhstan	5
The Coca-Cola Company	USA	4
Philip Morris Products S.A.	Switzerland	4
Toyota Motor Corporation	Japan	4
Halyk Bank of Kazakhstan	Kazakhstan	3
Kaspi Bank	Kazakhstan	3
WTM Establishment	Liechtenstein	3

Eight more right holders have two trademarks each: Philip Morris Brands, August Storck, Inter IKEA Systems, FoodMaster, B.S.A. International, Eurasian Foods Corporation, Mareven Food Holdings, MAI.

Geography

Country of the owner’s registration	Trademarks	Country	Trademarks
Kazakhstan	42	Cyprus	3
Russia	8	Germany, Belgium, United Kingdom	2 each
Switzerland	6	Armenia, Korea, Ukraine, Sweden, Ireland	1 each
USA, Japan, Netherlands	4 each
Liechtenstein	3

Main Shift: The Institution Has Become Kazakhstani

Period	Total	Of which KZ	KZ share
2006–2014	18	5	28%
2015–2019	23	12	52%
2020–2026	44	25	57%

In the first decade, well-known status in Kazakhstan was an instrument of transnational corporations: Coca-Cola, Philip Morris, Toyota, IKEA. Today most new registrations go to Kazakh business — primarily food and beverage producers (RG Brands, Alina Group, FoodMaster, Eurasian Foods, Maslo-Del, MAI) and banks (Halyk Bank, Kaspi).

The categories represented are also telling. The Register is concentrated in three segments: beverages and food, tobacco (six Philip Morris trademarks through two legal entities) and financial services. The automotive industry is present and, since 2026, construction — the BI group trademark.

Eight trademarks lost their well-known status owing to the simple expiry of the ten-year term.

Recent Registrations: 2025–2026

No.	Date	Trademark	Right holder
77	20 Jan 2025	helios “Solntse nashikh dorog!”	Helios (KZ)
78	20 Jan 2025	GORILLA energy drink	Gorilla Drinks (CY)
79	3 Nov 2025	detsky mir	DM (RU)
80	26 Jan 2026	ROLLTON®	Mareven Food Holdings (CY)
81	26 Jan 2026	BIGBON®	Mareven Food Holdings (CY)
82	2 Feb 2026	MASLOZAVOD No. 1	MAI (KZ)
83	2 Feb 2026	“MASLOZAVOD No. 1”	MAI (KZ)
84	25 May 2026	BI group	BI Group (KZ)
85	23 Jun 2026	Nezhny	Erman (RU)

Two trends are visible here. The first is the entry into the Register of industries new to it: construction (BI Group) and dairy products. The second is the noticeable presence of brands of Russian origin, directly or through holding structures: “Detsky Mir”, Rollton and BigBon, “Nezhny” — three of the nine most recent registrations.

This is consistent with what is observed in other Kazakh registers as well: right holders connected with the Russian market are strengthening their positions in Kazakhstan, choosing the strongest of the available protection instruments.

What This Means for the Right Holder

1. The status remains rare and valuable — 85 trademarks over the entire twenty-year history of the institution means this is not a mass procedure. Protection beyond the Nice classes and immunity from cancellation for non-use make it a weighty argument in disputes, including disputes over bad-faith registration and domain names.

2. Recognition timelines vary, and this must be built into the strategy. The Register also shows multi-year pauses followed by batch examinations. Filing an application does not guarantee a decision within a foreseeable time, so well-known status should be viewed as a long-term investment in brand protection, not as an operational response to a specific infringement.

3. Since February 2026, entry into the procedure has become more expensive. The survey sample has been doubled, and budgets calculated under the previous rules need to be revised. Applicants who had the procedure in their plans should assess what has already been collected and what is missing against the new list.

4. Digital evidence works, but it needs to be accumulated. Search statistics, marketplace data and social media metrics are expressly named in the new Rules. Historical snapshots are hard to reconstruct after the fact, so collection should begin before, not during, preparation of the application.

5. The institution is open to national business — and national business is using it. 57% of registrations of the last six years go to Kazakh right holders.

6. A portfolio approach works. The leaders of the Register — RG Brands and Alina Group — received trademarks in blocks of several at a time. Preparing several applications simultaneously, judging by the history of the Register, is more effective than filing them one by one.

7. The status requires renewal, and renewal requires proof anew. The expiry date should be kept in the calendar on a par with renewal deadlines for ordinary registrations.

8. Well-known status established abroad does not apply in Kazakhstan: the procedure must be completed in full, proving renown among Kazakh consumers.

In forecasting which brands may in future claim this status, several categories of market leaders can be singled out (the examples are not exhaustive):

Leaders of Kazakhstan’s food industry and FMCG — domestic food producers with a brand history of more than 15–20 years and sales covering all regions of the country:

• Rakhat (confectionery, one of the most recognizable brands on the market)

• Bayan Sulu (a major Kostanay confectionery brand)

• Piala / Piala Gold (leader of Kazakhstan’s tea market, from RG Brands)

Telecom operators and digital providers — companies whose services are used by millions of subscribers across the republic:

• Kcell / Active

• Tele2 (Kazakhstan)

Automotive and retail — brands with a growing trademarket share and investment in localizing production:

• Chery / Haval / Jetour — Chinese car brands that in recent years have taken top positions in sales in Kazakhstan and are building multi-brand plants in Almaty and other regions.

• Magnum Cash & Carry — the largest retail chain in the country, with a high level of recognition in large cities.

By Way of Conclusion

The eighty-five entries in the Register of Well-Known Trademarks of Kazakhstan, accumulated since the institution was introduced in 2006, describe the history of brand protection: from a platform that only “Coca-Cola” and “Toyota” entered to an instrument used today by local food producers, banks and construction companies.

At the same time, the main practical conclusion lies not in the numbers but in their unevenness. An institution that works in waves requires patience and advance preparation from the right holder. The new 2026 Rules only reinforce this logic: the bar of proof has been raised, the list of required documents has been formalized, and renown must now be confirmed not only by sales volumes but also by the brand’s digital footprint. Whoever waits for an infringement before thinking about well-known status will almost certainly be too late — and it will now cost more than a year ago.

This material is based on an analysis of the open data of the Register of Well-Known Trademarks of the Republic of Kazakhstan. All 85 registrations were processed; the calculations are available on request. The regulatory part is presented as of August 2026, taking into account the Rules approved by Order of the Minister of Justice of the Republic of Kazakhstan No. 97 of 28 January 2026.

Bolotov & Partners LLP — a law firm located in Almaty, Kazakhstan, successfully working in the field of protection and enforcement of intellectual property and providing legal services in Kazakhstan and Central Asia since 1994. We provide legal services exclusively on intellectual property and related matters. 45 well-known trademarks out of total 85 that are 53% of the total were recognized as well-known with the help of our firm.