As Freedom Holding Corp. expands its international business, corporate governance and transparency have become increasingly important drivers of its long-term growth. Operating as a Nasdaq-listed company across multiple regulated jurisdictions, the Freedom has established a disclosure, internal controls, and compliance framework aligned with regulatory requirements in the United States, the European Union, and Kazakhstan. This article examines how that framework is structured and the role it plays in supporting the company’s international expansion.
The Challenge of Growth
In the recent months, Freedom Holding Corp. has continued to expand its global fintech ecosystem, which combines financial, lifestyle and telecommunications segments, while increasing its presence across several regulated financial markets, from Turkey to France.
Moreover, Freedom Holding has set an even more ambitious long-term objective: becoming eligible for inclusion in the S&P 500 Index. To qualify for inclusion, a group must meet a range of criteria, including a minimum market capitalization of $22.7 billion, as well as requirements related to liquidity, public float, and financial performance. However, inclusion in the index is not automatic: the final decision is made by the S&P Dow Jones Indices Index Committee based on the index methodology.
Therefore, for a holding seeking to become a major U.S.-listed issuer with a broad international footprint, long-term success depends on meeting the standards expected of public companies: regular disclosure, independent audits, and effective internal control systems. Freedom Holding has already implemented these practices through its existing reporting, corporate governance, and compliance framework.
At the same time, further international expansion increases the importance of applying consistent standards across all jurisdictions in which the Group operates. For a business of this scale, these elements are an integral part of its operating model.
What Transparency Looks Like on Nasdaq
As a Nasdaq-listed public company since 2019, Freedom Holding Corp. discloses information in accordance with U.S. Securities and Exchange Commission (SEC) requirements. This includes annual reports on Form 10-K, which provide a comprehensive overview of the group’s business and financial condition, risk factors, management’s discussion and analysis, and include audited financial statements, quarterly reports on Form 10-Q, which give interim updates on the company’s financial position and include unaudited financial statements, and current reports on Form 8-K to announce major events that shareholders should know about, as well as the annual report to shareholders.
All of these filings are publicly available through the SEC’s EDGAR database Company Search. The latest annual report for the fiscal year ended March 31, 2026, audited by Deloitte LLP, was filed with the SEC on June 1, 2026, and is available on the SEC website and through the Freedom Holding Corp. Investor Relations website.
Operating Under Europe’s Rulebook
In Europe, Freedom Holding operates through its subsidiary Freedom Finance Europe Ltd, working under the Freedom24 brand, with official representative offices and tied agents located in Cyprus, Germany, France, Italy, Poland, Bulgaria, Greece, Austria, Lithuania and the Netherlands. Its activities as an international online broker in the form of a Cyprus Investment Firm (CIF) are regulated by the Cyprus Securities and Exchange Commission (CySEC).
The company functions under the European regulatory framework for investment firms. This means compliance with MiFID II (Directive 2014/65/EU), which sets common standards for how investment firms serve clients, provide information about their products and risks, and organize their internal operations. In addition, the company is subject to the prudential requirements established by the Investment Firms Regulation (IFR, Regulation (EU) 2019/2033) and the Investment Firms Directive (IFD, Directive (EU) 2019/2034), which require firms to maintain sufficient capital, manage risks responsibly and provide regular public disclosures about their financial position. Together, these rules are designed to ensure that investment firms remain financially resilient, manage risks effectively and operate transparently.
The disclosures in accordance with the IFR/IFD framework, are done on the company’s website an annual basis and verified by external auditors. Besides that, Freedom Finance Europe also prepares its Financial Statements on an individual (solo) basis, in accordance with the International Financial Reporting Standards (IFRS).
If Freedom Holding obtains a banking license, for which it has already applied in France, the company will enter the European banking regulatory framework, which imposes additional requirements for financial stability, capital adequacy, risk management and transparency. As a credit institution, it will be subject to supervision by banking regulators and will be required to submit prudential reports to supervisory authorities and publicly disclose information on its capital position, risks, risk management practices and overall financial resilience under EU banking rules.
Kazakhstan: Another Layer of Accountability
Freedom Bank Kazakhstan JSC and Freedom Finance JSC as a broker operate in Kazakhstan under the supervision of the Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market (ARDFM), the country’s financial market regulator responsible for the financial market, including banking and securities.
Freedom Bank Kazakhstan JSC publicly discloses audited annual consolidated and separate financial statements prepared in accordance with IFRS. The bank’s 2025 consolidated and separate financial statements and auditor’s report were published on its website and through the Kazakhstan Stock Exchange (KASE) on June 1, 2026. The audit was performed by Ernst & Young LLP. In addition, the bank publishes unaudited quarterly consolidated and separate IFRS financial statements, as well as monthly balance sheet position reports on its website. Freedom Finance JSC also prepares and discloses both separate and consolidated IFRS financial statements. The company’s 2025 consolidated financial statements and auditor’s report were published through KASE on June 3, 2026, with the audit performed by Ernst & Young LLP.
Both entities provide public disclosures as part of their transparency framework; however, their regulatory reporting obligations are significantly broader and include detailed prudential, risk and operational information submitted to the ARDFM for ongoing supervision.
The Ratings Perspective
Freedom Holding’s transparency and strong risk management are reflected in its credit ratings. In June 2026, just three months after its previous review, S&P Global Ratings upgraded the ratings of the Group’s core banking and brokerage businesses — Freedom Bank Kazakhstan, Freedom Finance JSC, Freedom Finance Europe and Freedom Finance Global — from B+ to BB-. In its rationale, S&P specifically pointed to three years of demonstrated group-wide risk management and compliance practices that are now embedded across subsidiaries and jurisdictions.
Freedom Bank Kazakhstan also holds Moody’s ratings, including a Ba3 long-term deposit rating with a stable outlook and Ba2 long-term Counterparty Risk Ratings, reflecting the bank’s solid credit profile.
Transparency Tested and Proved: The Short Seller Challenge
Freedom Holding’s disclosure framework has also been tested during periods of heightened public scrutiny. Like many publicly traded companies, the Group became the target of activist short-seller campaigns in 2023, when Citron Research and later Hindenburg Research published reports questioning the Company’s governance, compliance and business practices. Freedom rejected the allegations, and the independent members of its Board commissioned an external review by Morgan, Lewis & Bockius LLP and Forensic Risk Alliance. The findings, disclosed to the SEC in January 2024, concluded that the allegations were not supported by evidence.
Subsequent developments involving the founders of both short-selling firms further reinforced the speculative nature of the allegations. In January 2025, Hindenburg Research founder Nate Anderson announced that he was shutting down the firm. In June 2026, Citron Research founder Andrew Left was convicted by a U.S. federal jury on multiple securities fraud charges in a case involving a long-running market manipulation scheme.
Beyond Reporting: The Compliance Infrastructure
The group’s disclosure framework extends far beyond financial reporting. Freedom Holding Corp. has established a group-wide compliance framework covering regulatory compliance, business ethics, conflicts of interest, anti-bribery and corruption, AML/CFT, sanctions compliance, whistleblowing and insider trading controls. The framework is overseen by the Chief Compliance Officer and supported by compliance functions across the Group.
Freedom Holding Corp. also maintains corporate governance policies, including a Code of Ethics and Business Conduct, Risk Committee Charter and Insider Trading Policy. These policies are designed to prevent misconduct, protect confidential information and ensure responsible decision-making across the organization.
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