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Cases / Carbon credits · Russia · 2022–2028

Sakhalin carbon-neutrality experiment under Federal Law 34-FZ

Nature's voice · report
No measurement of the harm done to me here is on record.
Did nature suffer? Not measured. Disputed
Not on record
  • The record does not name which of my species, waters, soils or forests were harmed.
What the record lacks: 4 none on record · 3 not disclosed · 1 not measured · 8 disputed See the gaps
Accounts of the harm differ
Whether neutrality reflects real emission changes or an accounting revision
  • Government and regulators Sakhalin Oblast government (Governor Valery Limarenko): Absorption exceeds emissions under the official cadastre agreed with Roshydromet. Kommersant
  • Company or project RSPP representatives: The balance was reached not through quota-setting but as a result of refining the regional cadastre. Kommersant
  • Researchers Institute of National Economic Forecasting, Russian Academy of Sciences: In its current design the quota mechanism brings no budget revenue and no protection against the EU carbon border tax. Kommersant

Federal Law 34-FZ of 2022 set an experiment in Sakhalin Oblast from 1 September 2022 to 31 December 2028 with a goal of carbon neutrality by 31 December 2025. Officials announced on 2 August 2025 that absorption exceeded emissions under the regional cadastre, and representatives of the RSPP were reported as saying the balance came from refining the cadastre rather than from quotas.

RUB 1,000 per tCO2ePayment for exceeding an emissions quota
Paid to the Sakhalin regional budget; 35 companies take part. Total fees collected are not on record.

Status As of August 2026 (latest sources opened): the experiment runs to 31 December 2028; officials report absorption above emissions under the regional cadastre, and no independent verification is on record.

What?
Federal Law 34-FZ set an experiment of regional emissions quotas in Sakhalin Oblast from 1 September 2022 to 31 December 2028, with a goal of carbon neutrality by 31 December 2025, which officials announced as reached on 2 August 2025. President of Russia (kremlin.ru)
Where?
Sakhalin Oblast (Sakhalin island and the Kuril Islands), Russia. President of Russia (kremlin.ru)
When?
Experiment 1 September 2022 to 31 December 2028; neutrality target 31 December 2025; announced 2 August 2025. President of Russia (kremlin.ru)
Who?
Gained
  • Sakhalin regional budget — Receives payments of RUB 1,000 per tCO2e above quota; total collected is not on record The Moscow Times
  • Sellers of carbon units such as RUSAL — Supplied about 40% of the verified carbon units used (Nezavisimaya Gazeta) Nezavisimaya Gazeta
  • PAO Sakhalinenergo — Received 684 quota fulfilment units in 2025 and sold 384 to MP Noglikskiy Vodokanal (Advokatskaya Gazeta) Advokatskaya Gazeta
Lost
  • Participants exceeding quotas — Pay RUB 1,000 per excess tonne or buy units to offset; about 63,000 units bought in the second period Vedomosti
Harmed
None on record
Why?
The law sets carbon neutrality in Sakhalin Oblast as the experiment's goal; Minister Reshetnikov linked it to the competitiveness of low-carbon exports. President of Russia (kremlin.ru)
How?
Quotas for regional regulated organisations, payments above quota to the regional budget, tradable quota fulfilment units and national carbon units, with emissions and absorption entered in a regional cadastre agreed with Roshydromet. President of Russia (kremlin.ru)
6 of 6 questions answered from the record

What happened

The record, in order.

Federal Law of 6 March 2022 No. 34-FZ "On conducting an experiment on limiting greenhouse gas emissions in certain constituent entities of the Russian Federation" set the experiment in Sakhalin Oblast from 1 September 2022 to 31 December 2028, with the goal of carbon neutrality in the oblast by 31 December 2025 (Art. 3). The start was moved from 1 March to 1 September 2022 during the second reading because by-laws, the quota methodology and the fee rules, were not ready. The law defines carbon neutrality as a state in which the mass of anthropogenic emissions does not exceed the mass of absorption in a calendar year (Art. 2(10)). Expansion to other regions requires amending the law (Art. 3).

Quotas are set for each regional regulated organisation. Organisations may use carbon units and quota fulfilment units (EVK) to meet quotas; they pay for emissions above quota at a rate set by the federal government, with the payment going to the regional budget for emission-reduction and absorption measures and research, due by 1 June (Art. 8). Emissions under quota earn one EVK per tonne (Art. 8(14)). An annual inventory of emissions and absorptions is entered into a regional cadastre agreed with the federal hydrometeorology body (Art. 6). Moscow Times, citing Reuters, reported the rate as 1,000 roubles per excess tonne. The starting point reported by Kommersant via EastRussia was 12.3 million tCO2e emitted and 11.1 million tonnes absorbed in 2021; in November 2024 the Ministry of Economic Development and VEB.RF told COP29, according to Reuters, that net emissions were about 732,000 tCO2e in 2023 against about 1.4 million tonnes in 2021, with a target cut of 1.2 million tonnes and 35 organisations, each emitting more than 20,000 tonnes a year, under quotas for 2024–2028.

Governor Valery Limarenko announced early carbon neutrality on 2 August 2025, saying absorption exceeded emissions under the cadastre as agreed with Rosgidromet. Kommersant reported that 35 companies take part, that participants together had to cut emissions by almost 160 thousand tCO2e for 2024–2025, and that the 2024 inventory was carried out by the Yu. A. Izrael Institute of Global Climate and Ecology and agreed by Roshydromet. It reported a quota market volume of 266 thousand tCO2e and 131 thousand carbon units credited in 2025, eight times the 2024 figure; the consultancy publication INFRAGREEN assigned the 266 thousand and 131 thousand figures to 2024 compliance. Nezavisimaya Gazeta reported emissions cut threefold and regional output up by a third, with RUSAL supplying 40% of the verified carbon units used and RUSAL, NOVATEK, SIBUR, Gazprom, Russian Railways and SakhalinEnergo named as trading firms. A lawyer writing in Advokatskaya Gazeta said PAO Sakhalinenergo received 684 quota fulfilment units in 2025 and sold 384 to MP Noglikskiy Vodokanal. The first exchange trades of Sakhalin EVK took place on 30 June 2025, and the registry shows 13,195 quota units fulfilled. Official results were reported at a State Council commission meeting on 16 December 2025.

Vedomosti reported that in the second period (2025–2026) the number of companies exceeding quotas fell from 12 to 4 and the excess fell to 67,800 tCO2e; companies bought about 63,000 units to offset and EVK were barely used, with one participant using 1,000 EVK bought at 200 roubles each. Kontur said about 90% of all retirements in the national registry were by Sakhalin participants, and that retirements totalled 72,400 tonnes in the first half of 2026 against 145,700 tonnes in all of 2025; Kontur's Yevgeny Panin said Sakhalin reporting had just closed, so the fall was hard to interpret. EastRussia, reporting a forum on 31 July 2026, said prices of carbon units fell from about 1,000 to 150–250 roubles per tonne and that six regions (Yakutia, Komi, Tatarstan, Irkutsk, Arkhangelsk and Stavropol) were adopting Sakhalin practices.

Representatives of the RSPP (Russian Union of Industrialists and Entrepreneurs) were reported by Kommersant on 25 December 2025 as saying the balance was reached "not through quota-setting but as a result of refining the regional cadastre". Experts from the Russian Academy of Sciences' Institute of National Economic Forecasting were reported as saying that in its current design the quota mechanism brings no budget revenue and no protection against the EU carbon border tax. Minister Maxim Reshetnikov said the aim was the competitiveness of low-carbon exports and asked whether neutrality could be sustained long term; presidential climate envoy Ruslan Edelgeriev said the target was achieved alongside economic growth.

  1. 2022Law 34-FZ signed (6 March); start moved to 1 September
  2. 2023Payment rate of RUB 1,000 per tCO2e applies from 1 March (reported)
  3. 2024Quotas apply for 2024–2028; 2024 inventory by the Izrael Institute agreed with Roshydromet
  4. 2025First exchange trades of Sakhalin EVK (30 June); governor announces carbon neutrality (2 August); results reported to State Council commission (16 December)
  5. 2026Second-period results reported: companies above quota fall from 12 to 4 (Vedomosti, August)
  6. 2028Experiment period ends (31 December)

What was said

Claims, in the words of those who made them.

“clean air, unique wildlife and a high quality of life”

Governor Valery Limarenko, on what the experiment produced (translated by The Moscow Times) · August 2025 · translated from Russian · The Moscow Times

“not through quota-setting but as a result of refining the regional cadastre”

Representatives of the RSPP, on how the balance was reached, as reported by Kommersant (translated) · 25 December 2025 · translated from Russian · Kommersant

“soft”

Minister Maxim Reshetnikov, on regulation for business for now, as reported by Kommersant (translated) · 4 August 2025 · translated from Russian · Kommersant

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Whether neutrality reflects real emission changes or an accounting revision
Government and regulators
Sakhalin Oblast government (Governor Valery Limarenko)

Absorption exceeds emissions under the official cadastre agreed with Roshydromet.

Kommersant
Company or project
RSPP representatives

The balance was reached not through quota-setting but as a result of refining the regional cadastre.

Kommersant
Researchers
Institute of National Economic Forecasting, Russian Academy of Sciences

In its current design the quota mechanism brings no budget revenue and no protection against the EU carbon border tax.

Kommersant
The year neutrality was reached
Government and regulators
Governor's results (announced August 2025)

By the end of 2024.

Kommersant
Press and investigations
EastRussia forum report (31 July 2026)

In 2025.

EastRussia
The year of the 266 thousand tCO2e quota volume and 131 thousand credited units
Press and investigations
Kommersant (4 August 2025)

131 thousand carbon units credited in 2025, eight times the 2024 figure.

Kommersant
Press and investigations
INFRAGREEN (consultancy publication)

Quota volume of 266 thousand tCO2e and 131 thousand units credited for 2024 compliance.

INFRAGREEN

How it looked

What was shown, beside what was recorded.

Shown

  • Sakhalin is the first Russian region where absorption exceeds emissions under the official cadastre; the next task is to move from experimental to systemic practice.
    Governor Valery Limarenko, as reported by Kommersant, 2025 · Kommersant
  • The target was achieved alongside economic growth.
    Ruslan Edelgeriev, presidential climate envoy, as reported by INFRAGREEN · INFRAGREEN
  • The quota methodology needs revision with business; Russia seeks international recognition of its registry.
    Milena Milich, the governor's climate representative, as reported by Kommersant and EastRussia · Kommersant
  • Emissions cut threefold while regional output rose by a third.
    Nezavisimaya Gazeta, 5 August 2025 · Nezavisimaya Gazeta

Recorded

  • Experiment period 1 September 2022 to 31 December 2028; target date for carbon neutrality 31 December 2025 (Art. 3 of 34-FZ).
    President of Russia (kremlin.ru)
  • 35 companies participate; for 2024–2025 they must together cut emissions by almost 160 thousand tCO2e.
    Kommersant
  • Quota market volume of 266 thousand tCO2e and 131 thousand carbon units credited (Kommersant: 2025; INFRAGREEN: 2024 compliance).
    Kommersant
  • Second period: companies exceeding quotas fell from 12 to 4; excess 67,800 tCO2e; about 63,000 units bought to offset.
    Vedomosti
  • Registry shows 13,195 quota units fulfilled; first exchange trades of Sakhalin EVK on 30 June 2025.
    JSC Kontur
  • About 90% of all retirements in the national registry are by Sakhalin participants (Kontur).
    Vedomosti

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: RUB · Window: 2023–2028. All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • Sakhalin Oblast government (August 2025): Sakhalin is the first Russian region where absorption exceeds emissions under the official cadastre (Governor Valery Limarenko). · Kommersant
  • Ministry of Economic Development (August 2025): Aim is competitiveness of low-carbon exports; asked whether neutrality can be sustained long term (Minister Maxim Reshetnikov). · Kommersant

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

No court case on record. No court has ruled on this case.

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Neutrality target
31 Dec 2025
Date set in Art. 3 of 34-FZ; announced reached on 2 August 2025
Participants
35 companies
Under quotas for 2024–2028
Companies above quota
12 to 4
Second period, 2025–2026 (Vedomosti)
Payment above quota
RUB 1,000 per tCO2e
To the regional budget

What we don't know

Undisclosed, unproven, untried: recorded as data.
No court caseNo independent ecological evaluationKey earnings undisclosed

Nature

  • Not measured Harm to nature: No independent ecological evaluation is on record.
  • Disputed Whether neutrality reflects real emission changes or an accounting revision

Court

Accounts

  • Disputed The year neutrality was reached
  • Disputed The year of the 266 thousand tCO2e quota volume and 131 thousand credited units

Record

  • Not disclosed Not disclosed: absolute emissions and absorption tonnage in the August 2025 announcements.
  • None on record None on record: post-recalculation emission and absorption figures in tonnes.
  • Not disclosed Not disclosed: the methodology for forest absorption in the regional cadastre and any independent verification of the cadastre figures.
  • None on record None on record: the cadastre methodology change that the RSPP representatives referred to.
  • Not disclosed Not disclosed: quota allocations per company, total fees paid to the regional budget and the programme budget.
  • None on record None on record: final 2025 results; the 2025 results were to be summarised in 2026.
  • Disputed Figures differ: net emissions in 2021 are given as 12.3 million tCO2e emitted and 11.1 million tonnes absorbed (Kommersant via EastRussia) and as about 1.4 million tonnes net (VEB.RF via Reuters).
  • Disputed Figures differ: INFRAGREEN assigns the quota volume of 266 thousand tCO2e and 131 thousand carbon units to 2024 compliance, while Kommersant reports 131 thousand credited in 2025, eight times 2024.
  • Disputed Figures differ: carbon-unit prices are reported as falling from about 1,000 to 150–250 roubles (EastRussia), while Vedomosti cites exchange bids of 550–625 roubles in July 2026.
  • Disputed Disputed: the year neutrality was reached, by the end of 2024 in the governor's results announced in August 2025 and in 2025 in the forum report.
  • Disputed Disputed: whether neutrality reflects real emission changes or an accounting revision of the cadastre.

Did the harm stop?

None on record.

Who paid?

None on record.

Sources

Voices on record: — Company or project✓ Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers✓ Standard-setters and registries

Government and regulators

Press and investigations

Standard-setters and registries

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.
Terms used on this page

Carbon and conservation finance

Offset
Using carbon credits to balance emissions released elsewhere, so that a buyer can claim lower or zero net emissions.
Standard-setter and registry
An organisation that writes the rules for carbon credits, approves projects, and records when credits are issued and retired. Such bodies typically charge fees per credit.
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