Kaspi.kz (KSPI) CEO Lomtadze discloses 43.8M ADS beneficial ownership

Rhea-AI Filing Summary

Joint Stock Co Kaspi.kz director and Chairman/CEO Mikheil Lomtadze has reported his initial beneficial ownership in the company. He directly holds 43,790,623 American Depositary Shares, each representing one common share of Kaspi.kz. This filing establishes his status as a major shareholder and insider.

Insider Trade Summary

1 transaction reported

Mixed 1 txn

Insider Lomtadze Mikheil

Role Chairman, CEO

Type	Security	Shares	Price	Value
holding	American Depositary Shares, no par value	--	--	--

Holdings After Transaction: American Depositary Shares, no par value — 43,790,623 shares (Direct)

Footnotes (1)

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Understanding Insider Trading Forms →

SEC Form 3

FORM 3

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0104
Estimated average burden
hours per response:			0.5

1. Name and Address of Reporting Person^*

Lomtadze Mikheil

(Last) (First) (Middle)

154A NAURYZBAI BATYR STREET

(Street)

ALMATY 050013

(City) (State) (Zip)

UNITED STATES

(Country)

2. Date of Event Requiring Statement (Month/Day/Year)
03/18/2026

3. Issuer Name and Ticker or Trading Symbol
Joint Stock Co Kaspi.kz [ KSPI ]

3a. Foreign Trading Symbol

5. If Amendment, Date of Original Filed (Month/Day/Year)

4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director	X	10% Owner
X	Officer (give title below)		Other (specify below)
	Chairman, CEO

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Beneficially Owned
1. Title of Security (Instr. 4)	2. Amount of Securities Beneficially Owned (Instr. 4)	3. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	4. Nature of Indirect Beneficial Ownership (Instr. 5)

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 4)	2. Date Exercisable and Expiration Date (Month/Day/Year)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
American Depositary Shares, no par value	(1)	(1)	Common shares, no par value	43,790,623	(1)	D

Explanation of Responses:

1. Each American Depositary Share represents one common share of the issuer.

Remarks:

Due to the issuer's status as a foreign private issuer pursuant to Rule 3a12-3(b) under the Securities Exchange Act of 1934 (the "Act"), the reporting person's transactions in the issuer's equity securities are exempt from Sections 16(b) and 16(c) of the Act. Exhibit 24 - Power of Attorney

	/s/ Yuri Didenko as attorney-in-fact for Mikheil Lomtadze	03/18/2026
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 5 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.
* Form 3: SEC 1473 (03-26)

FAQ

What insider position did Lomtadze Mikheil report for KSPI?

Lomtadze Mikheil reported direct beneficial ownership of 43,790,623 American Depositary Shares of Joint Stock Co Kaspi.kz. This disclosure reflects his substantial stake as a director, Chairman, CEO, and more than ten percent beneficial owner in the company.

What does each Kaspi.kz (KSPI) American Depositary Share represent?

Each Kaspi.kz American Depositary Share represents one common share of the issuer. This 1:1 relationship means the reported 43,790,623 ADS correspond to the same number of underlying common shares of Joint Stock Co Kaspi.kz.

Is the KSPI insider holding reported by Lomtadze direct or indirect?

The reported holding is direct beneficial ownership. The filing shows ownership type as direct for 43,790,623 American Depositary Shares, indicating the shares are held directly by Lomtadze Mikheil rather than through an intermediary entity or trust.

Does the KSPI Form 3 show any recent buy or sell transactions?

The filing does not report any buy or sell transactions. It is an initial statement of beneficial ownership, listing 43,790,623 American Depositary Shares held directly, rather than disclosing new purchases, sales, or option exercises by Lomtadze Mikheil.

Why is Lomtadze Mikheil considered a ten percent owner of KSPI?

Lomtadze Mikheil is identified as a more than ten percent beneficial owner because his reported direct holding of 43,790,623 American Depositary Shares represents a significant stake. This status, combined with his roles as director and Chairman/CEO, requires detailed ownership disclosure.