The Agency for Protection and Development of Competition of the Republic of Kazakhstan has completed an analysis of the state of competition in the wholesale primary coal market in the Republic of Kazakhstan for 2024–2025.

The results of the analysis showed that the wholesale primary coal market is characterized by a high level of concentration, with an almost unchanged oligopolistic market structure and the continued dominance of the same market participants.

During the period under review, the following market participants held dominant positions in the wholesale primary coal market:

• Coal for municipal and household needs – the ERG group of companies and JSC “Karazhyra”, with a combined market share of more than 65% (74.8% in 2024 and 67.9% in 2025);

• Coal for energy-generating organizations – LLP “Bogatyr Komir” and LLP “Kazakhmys Coal”, with a combined market share of more than 80% (84.1% in 2024 and 81.6% in 2025);

• Coal for industrial needs – the ERG group of companies, with a market share of more than 60% (62.3% in 2024 and 69.1% in 2025).

Against the backdrop of the oligopolistic market structure, a significant increase in prices has been observed. On average, nationwide prices for municipal and household coal sold through primary wholesale channels increased by approximately 30–35% over the period from 2022 to 2025, while prices for energy coal increased by 45%.

The high level of market concentration is primarily due to limited access to resources. Currently, all major deposits are allocated among market participants, while long-term contracts valid for 25 years or more are in place, with the possibility of further extension.

Given the unchanged oligopolistic structure of the energy and municipal and household coal markets, measures are required to mitigate the risks of restricting competition in related downstream consumer markets. To address these risks, the Agency has initiated a number of measures, including the introduction of price regulation for energy and municipal and household coal; increasing the share of coal sold through commodity exchanges to 52%; and recognizing off-exchange coal sales volumes as key capacity, followed by transferring such volumes to digital platforms.

The analysis also showed that competition is restricted by differences in contracts with subsoil users regarding the amounts of mandatory payments, as well as by a non-transparent mechanism for granting certain entities exclusive rights to export coal. In addition, market participants have raised concerns regarding the insufficient transparency and predictability of procedures for coordinating transportation plans with JSC “NC “Kazakhstan Temir Zholy”, particularly with regard to approval of the transportation of the required volume of goods.

In this regard, the Agency recommended that the authorized bodies establish criteria for inclusion in the list of foreign trade operators granted exclusive rights to export coal, ensure equal conditions for entities operating in the same product market, and increase the transparency of information on the capacity of the railway infrastructure of JSC “NC “Kazakhstan Temir Zholy”.

As part of the analysis, the Agency also identified the following holders of key capacity:

• Coal for municipal and household needs – JSC “Shubarkol Komir” and JSC “Karazhyra”;

• Coal for energy-generating organizations – LLP “Bogatyr Komir” and LLP “Kazakhmys Coal”;

• Coal for industrial needs – JSC “Eurasian Energy Corporation” and JSC “Shubarkol Komir”.

Following the recognition of these entities as holders of key capacity, coal sales will be carried out in accordance with the Rules for Equal Access to Key Capacity.

Against the backdrop of the oligopolistic market structure, a significant increase in prices has been observed. On average, nationwide prices for municipal and household coal sold through primary wholesale channels increased by approximately 30–35% over the period from 2022 to 2025, while prices for energy coal increased by 45%.

Previously, based on the results of the coal wholesale market analysis conducted by the Agency in 2022, signs of abuse of a dominant position by JSC “Karazhyra” were identified. Following the investigation, a violation of antimonopoly legislation was established, and the entity was held administratively liable in the amount of KZT 87.4 million. To date, the court decision has entered into legal force, the fine has been paid voluntarily, and the monopolistic income has been fully confiscated in favor of the state.

If the application of monopoly pricing is identified for a new period, the relevant entities will be subject to antimonopoly enforcement measures.

Source : https://www.gov.kz/memleket/entities/zk/press/news/details/1272646?lang=ru