Quarterly report [Sections 13 or 15(d)]

STATUTORY CAPITAL REQUIREMENTS

v3.25.3
STATUTORY CAPITAL REQUIREMENTS
6 Months Ended
Sep. 30, 2025
Broker-Dealer [Abstract]  
STATUTORY CAPITAL REQUIREMENTS STATUTORY CAPITAL REQUIREMENTS
The Company has two insurance subsidiaries operating in Kazakhstan: Freedom Life (a regulated life insurer) and Freedom Insurance (a regulated property and casualty insurance entity). The Law of the Republic of Kazakhstan No. 126-II "On Insurance Activities" (the "Insurance Law") is the main law regulating the insurance sector in Kazakhstan. It establishes a framework for insurance activities, registration and licensing of insurance companies and regulation of insurance activities by the Agency of the Republic of Kazakhstan for Regulation and Development of Financial Market ("ARDFM").
Freedom Life and Freedom Insurance are required by ARDFM to notify it of any proposal to declare or pay a dividend on its share capital, and the ARDFM may, following the notification, decide to restrict such proposal. The amount of dividends these subsidiaries are permitted to declare is limited to the relevant subsidiary's realized retained earnings and dividends can only be paid to the extent they will not cause a breach to the minimum solvency and capital requirements of the relevant subsidiary. As of September 30, 2025 and March 31, 2025, Freedom Life and Freedom Insurance were in compliance with the ARDFM dividend, minimum solvency and minimum capital requirements. Freedom KZ in its capacity of an insurance holding is also limited in declaration and payment of dividends if such payment leads to breach of capital ratios applicable to insurance Freedom Life and Freedom Insurance.
There are no significant differences between the statutory accounting practices and statements prepared in accordance with U.S. GAAP for the insurance subsidiaries.
In addition, our subsidiaries operate under various securities brokerage, banking and financial services regulations and must maintain such licenses in order to conduct their operations. As of September 30, 2025 and March 31, 2025, we, through our subsidiaries, held: (a) brokerage licenses (i) in Kazakhstan issued by ARDFM and the Astana Financial Services Authority (the "AFSA"), (ii) in Cyprus issued by the Cyprus Securities and Exchange Commission ("CySEC"), (iii) in the United States issued by FINRA, (iv) in Armenia issued by the Central Bank of Armenia, and (v) in Uzbekistan issued by the Ministry of Finance of the Republic of Uzbekistan; (b) a banking license for foreign currency operations license in Kazakhstan issued by the ARDFM; (c) a banking license for corporate and retail banking services in Kazakhstan issued by the ARDFM (including for currency exchange operations); (d) payment service provider in Kazakhstan is specially registered in such capacity with National Bank of the Republic of Kazakhstan, payment services providers in Uzbekistan and Kyrgyzstan hold licenses from the National Bank of the Kyrgyz Republic and the Central Bank of Uzbekistan, respectively; and (e) a banking license in Tajikistan issued by the National Bank of Tajikistan. Our U.S. broker-dealer subsidiary is subject to regulatory oversight by U.S. authorities, including the Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA), with respect to its brokerage and investment advisory activities in the U.S. In addition, following receipt of a principal approval by the Turkey's financial regulatory and supervisory authority granted on January 9, 2025, we are in the process of obtaining a license to provide brokerage services in Turkey.
The table below presents net capital/eligible equity, required minimum capital, excess regulatory capital and retained earnings as of September 30, 2025 for the Company and each of subsidiaries that are regulated entities that is material for our consolidated financial statements.
(amounts in thousands) Regulated activities Net Capital/Eligible Equity Required Minimum capital/solvency Excess regulatory capital Retained earnings
Freedom Holding Corp.
Bank holding company $ 486,790  $ 200,000  $ 286,790  $ (121,966)
Freedom EU Brokerage 451,258  19,320  431,938  562,152 
Freedom Bank KZ Bank 388,080  182,333  205,747  184,141 
Freedom Global Brokerage 141,067  34,827  106,240  176,288 
Freedom Life Life Insurance 84,742  10,742  74,000  86,283 
Freedom Armenia ("Freedom AR") Brokerage 73,905  786  73,119  76,856 
Freedom KZ Brokerage 42,915  358  42,557  104,170 
Freedom Insurance Property and Casual Insurance 41,631  10,742  30,889  41,787 
Other regulated operating subsidiaries Other 18,492  260  18,231  (30,420)
$ 1,728,879  $ 459,368  $ 1,269,511  $ 1,079,291 
According to the requirements of National Bank of Republic of Kazakhstan, the regulator of Freedom KZ and Freedom Life, capital is adjusted through subtraction of non-liquid assets. Consequently, net capital for regulatory purposes may be lower than retained earnings balances. For the purposes of capital requirements applicable to Freedom EU, which is regulated by the Cyprus Securities and Exchange Commission and Freedom Global regulated by Astana Financial Services Authority, current year profit is not included within net capital for regulatory purposes, as profits can only be included in net capital after a statutory audit is completed.
The table below presents net capital/eligible equity, required minimum capital, excess regulatory capital and retained earnings as of March 31, 2025 for each of our subsidiaries that are regulated entities that is material for our consolidated financial statements.

(amounts in thousands) Regulated activities Net Capital/Eligible Equity Required Minimum capital/solvency Excess regulatory capital Retained earnings
Freedom Holding Corp.
Bank holding company $ 526,906  $ 200,000  $ 326,906  $ (256,096)
Freedom EU
Brokerage
450,903  19,320  431,584  607,659 
Freedom Bank KZ
Bank
382,259  175,396  206,862  159,119 
Freedom KZ
Brokerage
43,568  390  43,178  100,440 
Freedom Global
Brokerage
66,217  21,564  44,653  56,941 
Freedom Life
Life Insurance
58,246  11,692  46,554  70,574 
Freedom Armenia ("Freedom AR")
Brokerage
47,994  773  47,221  48,067 
Freedom Insurance
Property and Casual Insurance
33,646  11,692  21,954  29,150 
Other regulated operating subsidiaries
Other
14,130  267 13,863  (28,622)
$ 1,623,869  $ 441,094  $ 1,182,775  $ 787,232