Internal audit under Kazakhstan’s 2019 risk-management and internal control requirements: A continuous-treatment difference-in-differences analysis of commercial banks’ financial stability

Type of the article: Research ArticleAbstractWeak risk governance and legacy non-performing loans have repeatedly destabilized banks in emerging markets, making the payoff from regulatory strengthening of internal control and internal audit a first-order policy question. This study aims to determine whether Kazakhstan’s 2019 risk-management and internal control requirements (National Bank Resolution No. 188), whose core assurance mechanism is a strengthened internal audit function, improved the financial stability of the country’s commercial (second-tier) banks, and to identify the channel of this effect. The analysis applies a continuous-treatment difference-in-differences design to an annual panel of 37 banks over 2015–2025 (287 bank-years), interacting each bank’s pre-intervention (2016–2019) weakness with the post-intervention period and measuring stability by the log Z-score. The results show that the stabilizing effect is concentrated in the asset-quality channel: banks that entered the post-2020 period with a one-standard-deviation greater non-performing-loan weakness recorded a 0.38-0.41 log-point (roughly 40-50%) larger post-intervention increase in the Z-score (p < 0.01), whereas composite pre-intervention weakness yields no robust effect under any weighting scheme. The effect emerges with a multi-year lag, becoming statistically detectable only toward the end of the sample period, and operates through capital rebuilding. Because pre-intervention weakness strongly predicts market exit (Cox hazard ratio ≈ 3.95), the estimates are a lower bound on the intervention’s full association with sector stability. The findings imply that supervisors should target credit-risk governance, loan classification, timely recognition of problem loans, and provisioning, where strengthened internal control and audit yield the largest stability gains.