Quarterly report [Sections 13 or 15(d)]

STATUTORY CAPITAL REQUIREMENTS

v3.25.4
STATUTORY CAPITAL REQUIREMENTS
9 Months Ended
Dec. 31, 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 December 31, 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 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 December 31, 2025, we, through our subsidiaries, held: (a) brokerage licenses (i) in Kazakhstan issued by the NBK 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, (v) in Uzbekistan issued by the Center of Coordination and Development of Securities Market, (vi) in Kyrgyzstan issued by the Financial Market Regulatory and Supervision Service under the Ministry of Economy and Сommerce of the Kyrgyz Republic, and (vii) in UAE issued by the Abu Dhabi Global Market Financial Services Regulatory Authority; (b) a banking license for foreign currency operations in Kazakhstan issued by the ARDFM; (c) banking licenses (i) in Kazakhstan for corporate and retail banking services issued by the ARDFM (including for currency exchange operations), and (ii) in Tajikistan issued by the National Bank of Tajikistan; (d) a payment service provider in Kazakhstan registered in such capacity with the NBK, payment services providers in Uzbekistan and Kyrgyzstan holding licenses from the Central Bank of Uzbekistan and the National Bank of the Kyrgyz Republic, respectively; and (e) a securities portfolio management license in Tajikistan issued by the Ministry of Finance of Tajikistan. Our U.S. broker-dealer subsidiary is subject to regulatory oversight by U.S. authorities, including the SEC and 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 December 31, 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 Bank KZ Bank $ 474,785  $ 215,678  $ 259,107  $ 255,060 
Freedom EU Brokerage 449,525  21,961  427,564  644,366 
Freedom Holding Corp.
Kazakhstan bank holding company 393,480  200,000  193,480  37,415 
Freedom Global Brokerage 139,910  37,528  102,382  214,192 
Freedom Life Life Insurance 116,841  11,667  105,174  102,641 
Freedom Armenia ("Freedom AR") Brokerage 87,954  789  87,165  85,449 
Freedom KZ Brokerage 65,289  389  64,900  131,238 
Freedom Insurance
Property and Casualty Insurance
36,215  11,667  24,548  31,582 
Other regulated operating subsidiaries Other 19,944  260  19,684  (38,079)
$ 1,783,942  $ 499,938  $ 1,284,004  $ 1,463,864 
According to the requirements of the NBK, 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 CySEC 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.
Kazakhstan 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 Casualty 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