5 Years, One Order: How Kazakhstan’s HOA Charter Kept Changing

The standard charter of a homeowners' association (HOA) is a document most residents never read and almost everyone signs without looking at a meeting. Yet over five years its model form changed four times — and not cosmetically. The chairperson gained the right to sue neighbors over unpaid debts, the general meeting lost some of its leverage over the building council, and in September 2025 the order suddenly grew a second charter — for an organization now allowed to call itself "PIK" (known in Russian-language documents as "KSK").

We compared, line by line, all four redactions of Order No. 205 of the Minister of Industry and Infrastructure Development of the Republic of Kazakhstan dated April 15, 2020, and cross-checked the new wording against the full text of the Law "On Housing Relations" — here is what actually changed in substance, not just in wording.

Below is an interactive timeline of all four redactions: click a point to open the breakdown for that version.

1. The 2020 redaction: the chairperson has almost no leverage

The original Order No. 205 (registered with the Ministry of Justice of Kazakhstan on April 16, 2020, No. 20412) approved a charter under which the chairperson is elected "for a term of one calendar year" and acts "without a power of attorney," but is given no debt-collection tool: the charter only requires them to "monitor payments by apartment and non-residential premises owners toward the management of the condominium object" — what to do about delinquent owners afterward, the document does not say.

A general meeting could be called without the chairperson's own involvement: only the building council, the audit commission, the housing inspectorate, or a group of at least 10% of owners could initiate one.

2. Order No. 42 of February 2, 2024: the chairperson gets a weapon against debtors

This was the first major update — the charter grew by almost half in volume. The key new provision (charter, subparagraph 24 of paragraph 18):

"...if an apartment or non-residential premises owner fails to pay off a debt on payments..., the HOA chairperson — or, acting under a power of attorney, the manager of the apartment building, or the management company — may apply to a notary or to court to collect the debt after three months have passed from the established payment date."

Before this redaction, no such provision existed in the charter at all. At the same time, conflict-of-interest rules appeared (the chairperson's relatives cannot serve as auditors, and vice versa), meeting minutes were moved to the chairperson's custody, and building council decisions became binding for the first time.

3. Order No. 235 of June 29, 2024: a narrow amendment

The most modest of the four amendments — a single subparagraph was added to the chairperson's duties: "ensuring a set of measures aimed at creating safe living (occupancy) conditions for apartment owners at the condominium object." The rest of the charter's text was left unchanged.

4. Order No. 403 of September 29, 2025: the deepest overhaul

The order was renamed — it now approves "the model charter of the homeowners' association of an apartment building and the model charter of the cooperative of apartment (non-residential premises) owners" — meaning two charters, in two annexes, appeared for the first time.

In the HOA charter, the chairperson's term grew to "three years" (up from one year), and the charter for the first time explicitly names the chairperson a member of the building council (charter, paragraph 17). The deadline for suing over a debt was shortened from three months to two (charter, subparagraph 30 of paragraph 18). The general meeting lost the wording that let it delegate specific decisions to the building council item by item — instead of a list of specific points, the charter now simply refers to Article 42 of the Law "On Housing Relations." The concept of an "authorized representative of a simple partnership," present in the charter since 2020, has effectively disappeared from the text.

5. What actually happened with "KSK" — checked against the law

This requires separate verification, because the wording is easy to misread. We checked it directly against the full text of the Law of the Republic of Kazakhstan "On Housing Relations" No. 94-I (Chapter 7, entirely in the redaction of Law No. 207-VIII of July 15, 2025).

Article 47 of the law names exactly two forms of building management:

"Owners of apartments and non-residential premises are required to choose one of the forms of managing a condominium object for management purposes: 1) direct joint management; 2) a homeowners' association."

"KSK" is not mentioned here as a form of building management at all — neither as currently valid nor as explicitly abolished: the law simply lists two forms. Separately, Article 51-4 introduces the concept of "subjects managing a condominium object" — organizations hired to provide management services:

"The subjects managing condominium objects are: 1) a management company; 2) a cooperative of apartment (non-residential premises) owners."

It is this cooperative that Article 51-6 permits to use an abbreviated name:

"The name of the cooperative of apartment (non-residential premises) owners may be abbreviated using the abbreviation 'KSK' in the name."

But structurally this is not a return of the pre-reform KSK: under paragraph 3 of the same article, it is formed by representatives of owners from "two or more condominium objects," delegated by general meetings — not by direct membership of residents of a single building. In other words, the forms of building management remain two (DJM and HOA), and "KSK" in its new sense is one of two types of management contractor that can be hired, alongside a management company.

One curious detail at the crossroads of Kazakhstan's two state languages: the official Kazakh-language text of the cooperative's charter (Annex 2 to Order No. 205, clause 1.2) assigns this same organization a different abbreviation in Kazakh — "PIK" (pәterler ielerinің kooperativі, "cooperative of apartment owners") — rather than "KSK," which is used only in the Russian-language name of the same annex. It is the same organization; the two state-language versions of its own charter simply abbreviate it differently.

Explains Anuar Kenesbayev, data analyst at ZhKH 24: "For an owner, in practice, the difference is between 'KSK is running the building again' and 'KSK can be hired again.' The building is still managed the same way it always was, by one of two methods — directly (DJM) or through an HOA. But the organization you hire for the technical work — trash removal, utility network maintenance, bookkeeping — can now officially be called KSK (or PIK, in Kazakh-language documents), even if it serves several buildings under one contract. The confusion is understandable: the same word, a different meaning. If someone suggests you 'join a KSK,' the first question isn't 'for or against' — it's 'is this a form of building management, or a service contract with a contractor?' That determines what you're actually signing."

Prepared by the ZhKH 24 Analytics Desk based on the direct text of Order No. 205 (April 15, 2020) in all four redactions (with amendments by Orders No. 42 of February 2, 2024, No. 235 of June 29, 2024, and No. 403 of September 29, 2025) and on the full text of the Law of the Republic of Kazakhstan "On Housing Relations" No. 94-I in its current redaction. Prepared in November 2026.