Official Statement of LLP “Documentolog”. Refutation and Legal Position Regarding the Actions of the APDC

LLP “Documentolog” has been operating in the electronic document management market of Kazakhstan since 2007. In 2016, the company, with its own resources, developed an innovative solution for the exchange of electronic correspondence between private legal entities – the CCOED (Corporate Center for Electronic Document Exchange). Access to correspondence through the CCOED was provided to all market participants on equal terms. This model did not limit the activities of other systems and was fully in line with business legislation.

Until 2025, the activity of organizing electronic correspondence between organizations was not regulated by any legal or regulatory acts. Amendments introducing a prohibition on withholding electronic documents from delivery to recipients by blocking software and/or technical means of electronic document management systems were added to Article 24 of the Law of the Republic of Kazakhstan “On Electronic Document and Digital Signature” only by Law No. 115-VIII of 05.07.2024, which came into force on January 7, 2025.

Therefore, claims of “years of blocking practices” have no legal basis.

In its press release, the APDC stated that it had conducted a market analysis, based on which the Partnership was recognized as holding a dominant position in the market for the period from 2021 to 2024. The Partnership has reviewed the APDC’s documents and arguments and considers that the competition analysis conducted in January 2025 cannot be deemed lawful due to numerous violations of procedural and methodological standards.

Accordingly, LLP “Documentolog” has filed a lawsuit, in which legal proceedings are still ongoing. The court’s first-instance ruling has not yet entered into legal force. LLP “Documentolog” is in the process of filing an appeal and is confident that the appellate court will restore legality. Moreover, the APDC has suspended its investigation into LLP “Documentolog,” as confirmed by an official notification sent to the company in August 2025.

By making public allegations of “violations” before any court ruling has entered into legal force, the APDC has breached the principle of legality. Such actions are not only premature but also contrary to the law, exerting pressure on the judiciary and harming the business reputation of LLP “Documentolog.”

The company will hold an open press conference on August 25, 2025, at 11:00 a.m. in Almaty, at the Grand Hotel Tien Shan, “Almaty” Hall, 2nd floor. Address: 115 Bogenbai Batyr Avenue. We will provide detailed information and clarifications regarding the current situation to the media, clients, and partners.

All Documentolog services continue to operate stably, ensuring uninterrupted document management for the state, businesses, and citizens.