A “grey” salary is a situation in which part of an employee’s actual remuneration is paid outside the official payroll and HR records. In 2026, such an arrangement creates risks for all parties involved: the employee cannot reliably verify their full income, the accountant faces distorted accounting records, and the executive may face claims concerning the organization of payments and reporting.
What Is Considered a “Grey” Salary
A “grey” salary is generally understood as a combination of official and unofficial remuneration. One amount is recorded in the documents, while the employee actually receives more—for example, in cash, as a transfer from another person, or disguised as a payment for another purpose.
The problem lies not in the method used to transfer the money as such, but in the discrepancy between the actual arrangements, HR documents, payroll calculations, and accounting records. If a payment is related to the employee’s work, its nature must be clear and supported by documents.
Verbal arrangements are also dangerous for a company: the promised amount may not match the information in the employment contract, payroll slip, payment documents, and accounting system. In the event of a dispute, each party will seek to prove its own version of the remuneration terms.
Risks for the Employee
The main risk for an employee is the lack of reliable proof of their full earnings. The unofficial portion is more difficult to take into account when resolving a labor dispute, verifying income, and checking the accuracy of salary-related accruals.
In addition, payments calculated on the basis of official earnings and recorded accruals may be lower than expected. The employee also depends on the employer’s good faith: a verbal promise of an additional payment does not provide the same transparency as a formally documented remuneration term.
Employees are advised to regularly compare:
- the terms of the employment contract and supplementary agreements;
- payroll slips;
- the amounts actually received;
- payment purposes;
- information on accruals and deductions available to them from official sources.
If the amounts differ, it is advisable to request a written explanation from the employer and retain the documents relating to the payments.
Risks for the Accountant and Executive
An accountant is responsible for accurately recording transactions within the scope of their job duties. If an actual payment does not correspond to the source documents or is processed under an incorrect purpose, there is a risk of distorting the accounting records and reports. Requests to document money that has already been transferred retroactively or to devise a fictitious basis for a payment are particularly dangerous.
Accountants should not accept questionable instructions given only verbally. They should request documents, clarify the economic substance of the transaction, and notify the executive in writing of the identified discrepancy. An executive’s instruction does not, by itself, make an unsupported transaction correct.
The risks for an executive are broader: management decisions determine the remuneration procedure, document workflow, and internal controls. Claims may arise due to discrepancies between HR documents and the actual terms, non-transparent movement of funds, incorrect accounting for payments, or a conflict with an employee. The specific consequences depend on the circumstances and applicable rules, so they must be assessed under the current regulatory legal acts of the Republic of Kazakhstan and the company’s documents.
What the Company Should Do
The safe approach is to bring the actual remuneration terms into compliance with the documents and accounting records. The practical course of action may be as follows:
- Compare employment contracts, staffing documents, timesheets, accruals, and payments.
- Identify payments whose stated purpose does not correspond to their actual substance.
- Discontinue undocumented payments and do not create documents containing inaccurate information.
- Formalize the current remuneration terms using the appropriate HR documents.
- Verify the accuracy of accounting and mandatory accruals in accordance with current legislation.
- If past discrepancies are identified, obtain an opinion from a relevant specialist on the correction procedure.
Employees, accountants, and executives should not destroy documents or artificially alter the substance of transactions. Any correction must leave a clear audit trail: what was identified, the data on which the decision was based, and how the discrepancy was resolved.
Frequently Asked Questions
Is every salary paid in cash considered “grey”? — No. What matters is not only the form of payment, but also whether the payment has been properly documented, whether it complies with the employment terms, and whether it has been recorded in the accounts.
Can the unofficial portion of a salary be proven using bank transfers? — Payment documents may be relevant, but they do not always prove the purpose of the money on their own. The full set of documents and circumstances is generally assessed.
What should an accountant do if verbally instructed to process a questionable payment? — Request the basis and supporting documents, clarify the substance of the transaction, and set out the identified risks in writing. A fictitious purpose for the payment should not be recorded.
How can an employee reduce the risk of a dispute? — Retain the employment contract, supplementary agreements, payroll slips, and payment confirmations, and promptly discuss any discrepancies with the employer in writing.
Can previously identified discrepancies be corrected? — The possibility and procedure for correction depend on the facts and documents. The company should conduct a review and check its actions against the current requirements of Kazakhstan’s legislation.
Sources
“Grey” Salary in Kazakhstan: Risks for Employees, Accountants, and Company Executives in 2026