A good chunk of Kazakhstan is west of the Urals. Could it be part of the EU?
Given that Turkey is only partially in Europe, and is on the path to membership, presumably similarly Kazakhstan also meets the requirements.
The Council of Europe have accepted that their partial presence in Europe meets their geographical requirements for membership.
Streching for other points, their football teams participate in European, rather than Asian, competitions.
All in all, I'd imagine they can make a reasonable claim for meeting the EU's geographaic requirement.