This presentation focuses on higher education funding reform in Kazakhstan where one of the policy options under consideration has been per-capita per-credit based university funding approach. According to this model, direct higher education subsidies to universities would be allocated based on the number of credits a student takes per term of studies. It is expected that this approach would strengthen outcomes-oriented budgeting, enhance student choice, and competition between universities. However, the success of any reform depends on its implementation. Based on semi-structured qualitative interviews with senior-level leadership representatives at universities, this presentation explores per-capita per-credit funding implementation risks at universities in Kazakhstan. Findings indicate four areas of concern. First, representatives are concerned about adjusting organizational processes to align student choice with organizational planning. Second are concerns about student awareness of their rights and obligations in terms of their academic progress. The third risk acknowledged by representatives of all universities concerns sufficiency of funding. Finally, representatives of universities see the risk of increased administrative costs due to audits which might not be fully aware of the specifics of per-capita per-credit higher education funding conditioning university operations.