{"url_path":"/sec/frhc/10-k/2026/item-9a","section_key":"item-9a","section_title":"Item 9A CONTROLS and PROCEDURES","topic":"sec","document":{"doc_type":"10-K","doc_date":"2026-06-01","source_url":"https://www.sec.gov/Archives/edgar/data/924805/0000924805-26-000012-index.html","accession_number":"0000924805-26-000012","cik":"0000924805","ticker":"FRHC","issuer_name":"Freedom Holding Corp.","edgar_url":"https://www.sec.gov/Archives/edgar/data/924805/0000924805-26-000012-index.html","primary_entity_key":"0000924805","primary_entity_name":"Freedom Holding Corp."},"word_count":546,"has_tables":true,"body_markdown":"ITEM 9A. CONTROLS and PROCEDURES    \n\nEvaluation of Disclosure Controls and Procedures\n\nAs of the end of the period covered by this Annual Report on Form 10-K, our management, under the supervision and with the participation of our principal executive officer and principal financial officer, evaluated the effectiveness of our disclosure controls and procedures. Disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”)) are designed to provide reasonable assurance that information required to be disclosed by a company in the reports that it files or submits under the Exchange Act is recorded, processed, summarized and reported, within the time periods specified in the U.S. Securities and Exchange Commission’s rules and forms and that such information is accumulated and communicated to the company’s management, including its principal executive officer and principal financial officer, as appropriate, to allow timely decisions regarding required disclosure. Based upon that evaluation, our principal executive officer and principal financial officer concluded that, as of March 31, 2026 our disclosure controls and procedures were effective.\n\nManagement's Report on Internal Control over Financial Reporting\n\nOur management is responsible for establishing and maintaining adequate internal control over financial reporting as defined in Exchange Act Rules 13a-15(f) and 15d-15(f). Internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with U.S. GAAP. Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. In addition, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.\n\nThe Company acquired Astel Group Ltd. (renamed Freedom Cloud Holding Ltd. on January 8, 2026) (the \"Acquired Company\") on April 30, 2025, and management excluded from its assessment of the effectiveness of the Company’s internal control over financial reporting as of March 31, 2026, the internal controls of the Acquired Company, which represent total assets of $38,748 (or 0.3% of total consolidated assets) and total revenues of $23,144 (or 1.1% of total consolidated revenues) included in the consolidated financial statements of the Company as of and for the year ended March 31, 2026, respectively.\n\nManagement conducted an assessment of our internal control over financial reporting as of the end of the period covered by this annual report based on the framework established by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control-Integrated Framework (2013). Based on this assessment and the criteria set forth by COSO, management concluded that our internal control over financial reporting was effective as of March 31, 2026.\n\nThe effectiveness of our internal control over financial reporting as of March 31, 2026, has been audited by Deloitte LLP, an independent registered public accounting firm based in Kazakhstan, as stated in their report which is included herein.\n\nChanges in Internal Control over Financial Reporting\n\nThere was no significant change in our internal control over financial reporting during the fiscal year ended March 31, 2026, that has materially affected, or is reasonably likely to materially affect our internal control over financial reporting."}