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October 13, 2023
Mikheil Lomtadze
Chief Executive Officer
Joint Stock Co Kaspi.kz
154A Nauryzbay Batyr Street
Almaty, 050013, Kazakhstan
Re:Joint Stock Co Kaspi.kz
Draft Registration Statement on Form F-1
Submitted September 11, 2023
CIK No. 0001985487
Dear Mikheil Lomtadze:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form F-1 filed September 11, 2023
Cover Page
1.Please advise as to why you believe the selling shareholders are not underwriters pursuant
to Section 2(a)(11) of the Securities Act. In this regard, we note that each of your selling
shareholders is an affiliate and holds a substantial amount of your ordinary shares. Refer
to Question 612.09 of our Compliance & Disclosure Interpretations for Securities Act
Rules.
2.Please disclose on the cover page that Kazakhstan law prohibits or restricts legal entities
registered in certain jurisdictions, including the U.S. Virgin Islands, Wyoming, Guam,
Delaware and the Commonwealth of Puerto Rico, to own the company's common shares
or exercise voting rights with respect to the ADSs.

 FirstName LastNameMikheil Lomtadze
 Comapany NameJoint Stock Co Kaspi.kz
 October 13, 2023 Page 2
 FirstName LastName
Mikheil Lomtadze
Joint Stock Co Kaspi.kz
October 13, 2023
Page 2
Prospectus Summary, page 1
3.Please provide the basis for the statements that the company owns “state-of-the art
biometrics technology” and that it has created the "most recognized brand in online
travel." To the extent that these statements are limited to a geographic market, please
revise.
4.Please disclose the percentage of revenue from your three business platforms (Payments,
Marketplace and Fintech) and clarify that the majority of your revenue is generated from
Fintech.
5.You state that any shareholder holding shares through a nominee and whose identity is not
disclosed to the Central Securities Depository is not entitled to vote at a meeting of
shareholders.  You also disclose that any person acquiring 10% or more of your voting
shares, or otherwise falling within the definition of an affiliate as provided for in
Article 64 of the JSC Law, is considered your affiliate and must disclose its identity and
information about its affiliated persons.  Disclose in the summary and in the risk factors
how this will impact the rights of holders of ADSs and the uncertainties related to their
voting rights.
Risk Factors
Our business generates and processes a large amount of data..., page 43
6.You disclose that your business generates and processes a large amount of data.  Please
revise your disclosure to discuss the general application of the General Data Protection
Regulation, or GDPR, to your business as well as any risks related to the applicability of
this regulation to your business.
The Issuer is a holding company and, as such, we depend on our subsidiaries for cash..., page 62
7.We note that your disclosure that your subsidiaries' ability to distribute cash to you may
be subject to, among other things, restrictions that may be contained in your subsidiary
agreements. Please expand your disclosure on the nature of such restrictions.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
90
8.Please provide your critical accounting policies. Refer to Item 303(3) of Regulation S-K.
Years Ended December 31, 2022 and 2021, page 110
9.Expand your discussion for each of your Segments’ change in Revenue to identify and
quantify the significant factors for the increases in revenue period over period. Your
current presentation does not appear to fully explain the factors for the increases. Refer to
Item 303(2) of Regulation S-K. Similar concerns apply to your discussion of changes in
Segment revenue for the six months ended June 30, 2023 and 2022.

 FirstName LastNameMikheil Lomtadze
 Comapany NameJoint Stock Co Kaspi.kz
 October 13, 2023 Page 3
 FirstName LastNameMikheil Lomtadze
Joint Stock Co Kaspi.kz
October 13, 2023
Page 3
Liquidity and Capital Resources
Cash Flows, page 119
10.We note that your discussion of cash flows from operating activities is limited in nature.
This does not appear to contribute substantively to an understanding of your cash flows.
Rather, it repeats items that are readily determinable from the financial statements.  When
preparing the discussion and analysis of operating cash flows, you should address material
changes in the underlying drivers that affect these cash flows. These disclosures should
also include a discussion of the underlying reasons for changes in working capital items
that affect operating cash flows.  Refer to Item 303(b)(1) of Regulation S-K.
Business, page 157
11.Please include here a breakdown of total revenues by geographic market for each of the
last three financial years in line with Item 4.B.2 of Form 20-F.
Employees, page 189
12.We note that you have operations in Ukraine and Azerbaijan in addition to Kazakhstan.
Please disclose here the geographic location of employees as required by Item 6.D. of
Form 20-F.
Management
Executive Officer and Director Compensation, page 213
13.Please provide the compensation information on an individual basis as required by Item
6.B of Form 20-F or tell us why individualized information is not required.  As part of
your response, address whether compensation information on an individual basis is
publicly available elsewhere.
Related Party Transactions, page 219
14.You state that since January 1, 2020, Kaspi Bank has issued loans in the form of Kaspi
Red to one of your executive officers and BNPL and car loans to your key management
personnel.  Please identify the executive officer and key management personnel and the
amount of the loans that were issued and currently outstanding.  Tell us how you intend to
comply with Section 13(k) of the Securities Exchange Act of 1934 with respect to the loan
to the executive officer.
Notes to Consolidated Financial Statements, page F-40
15.We note your disclosures on page 17 that you have operations in other countries such as
Ukraine, Azerbaijan, and Uzbekistan. Please separately disclose revenue attributed to
customers in Kazakhstan from revenue generated in foreign countries. In addition,
separately disclose non-current assets between those located in Kazakhstan and other
foreign countries. Refer to IFRS 8.33(a)-(b).

 FirstName LastNameMikheil Lomtadze
 Comapany NameJoint Stock Co Kaspi.kz
 October 13, 2023 Page 4
 FirstName LastName
Mikheil Lomtadze
Joint Stock Co Kaspi.kz
October 13, 2023
Page 4
16.We note your disclosure on page 111 that you made a 10,000 million contribution in 2022
to the public fund “Kazakhstan Halkyna”. Provide footnote disclosure to explain the
nature of this fund and the requirement to make the payment. Tell us why you recorded
this payment as a Sales and marketing expense instead of a general and administrative
expense.
Note 3. Significant accounting policies, page F-43
17.We note your customer accounts represent the majority of your total liabilities. Disclose
your accounting policy for customer accounts, including accrued interest.
Revenue recognition, page F-55
18.We note your chart on page 4 shows the various products and services that you currently
offer. Expand your revenue recognition policy to disclose more specifically your
recognition policy for all of your significant products and services. Refer to paragraphs
110 to 129 of IFRS 15. Ensure that your disclosures address Steps 1 through 5 in
recognizing revenue under IFRS 15.
19.Please clarify your disclosure related to the recognition of fees. You state that banking
service fees are recognized over a period in which the related services are provided,
typically monthly. Please explain how you determined the contract duration for such
services. Explain whether the service fees are considered variable consideration. Please
advise or revise accordingly.
20.Please clarify your disclosures to address whether your key services, including payments,
marketplace, financial services, travel, grocery, or classifieds are recognized on a gross or
net basis. Provide your accounting analysis that supports your conclusion for each of those
services.  Additionally, your disclosure should include how you are estimating and
allocating the transaction price to the performance in satisfying your obligations to your
customers. Refer to paragraphs 84 to 86 of IFRS 15.
21.We note you refer to Membership fee revenue. Please explain in greater detail the nature
of this revenue (e.g., the nature of the goods or services that the entity has promised to
transfer). In this regard, we note that you do not discuss Membership fee revenue in your
Overview of your business or discussion of your Segments on pages 90 through 99.
Please ensure that your disclosures comply with the requirements outlined in paragraph
119 of IFRS 15.
22.Expand your revenue recognition policy to disclose when you utilized significant
judgment in determining which of your products and services are recognized on a gross
versus net basis. Refer to paragraph 123 of IFRS 15.  Further tell us and expand your
disclosures to explain how you made these determinations. Refer to paragraphs B34 and
B34A of IFRS 15.

 FirstName LastNameMikheil Lomtadze
 Comapany NameJoint Stock Co Kaspi.kz
 October 13, 2023 Page 5
 FirstName LastName
Mikheil Lomtadze
Joint Stock Co Kaspi.kz
October 13, 2023
Page 5
23.Please clarify in detail how your accounting for Rewards program complies with IFRS 15.
In this regard, tell us whether the bonuses accumulated represent a material right.  Refer to
paragraph B40 of IFRS 15.
Note 4. Revenue, page F-60
24.Tell us your consideration to provide a disaggregation of revenue from goods or services
transferred to customers at a point in time and revenue from goods or services transferred
over time. Refer to paragraph 114 and B89 of IFRS 15.
Note 12. Loans to customers, page F-70
25.We note Loans to customers represents 62% of your total assets on December 31, 2022.
Further, we note your chart on page 160 that shows you offer consumer loans, BNPL,
merchant financing, and car financing within your Fintech platform.  Indicate whether
management separately evaluates credit risk based on these categories or geographic
regions. In addition, if past due information is the only borrower-specific information
available and an entity uses past due information to assess whether credit risk has
increased significantly since initial recognition, tell us what consideration you gave to
providing an aging schedule for loans to customers. Refer to paragraph B8H and B8I of
IFRS 7.
26.Please clarify why you extended the write off criteria by increasing it from 761 days to
1,080 days. In addition, tell us why the allowance is below the gross loans for those loans
that continue to be recognized.  Further, explain how you identify NPL
for restructuring by providing an interest free extended repayment schedule. Please clarify
if the difference between the amount that was restructured during the year, the amounts
collected, and the gross carry amount classified as Stage 3 is a result of write
offs. Confirm whether the restructured NPL outstanding amount as of the year end is
classified as Stage 3.
27.Tell us what consideration you gave to disclosing maturity analyses for the loans to
customers that show their remaining contractual maturities. Refer to paragraph B11C of
IFRS 7.  Please advise or revise accordingly.
Note 21. Share-based compensation, page F-78
28.Expand your footnote disclosure to provide the inputs used in the measurement of the fair
values at grant date. Refer to IFRS 2.47.
Exhibits
29.Please file the related party agreements with Kolesa and Magnum or tell us why they are
not required to be filed pursuant to Item 601(b)(10) of Regulation S-K.

 FirstName LastNameMikheil Lomtadze
 Comapany NameJoint Stock Co Kaspi.kz
 October 13, 2023 Page 6
 FirstName LastName
Mikheil Lomtadze
Joint Stock Co Kaspi.kz
October 13, 2023
Page 6
            Please contact Ryan Rohn at 202-551-3739 or Stephen Krikorian at 202-551-3488 if you
have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Jan Woo at 202-551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Nicholas P. Pellicani