Kazakhstan suspends enforcement of 2.3 trillion tenge environmental fine against Kashagan operator

September 8, 2026 at 04:00 PM2 min

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Kazakhstan suspended enforcement proceedings to collect a 2.3 trillion tenge environmental fine from North Caspian Operating Company (NCOC), operator of the Kashagan oil field, on September 7, 2026. The suspension was recorded in the Ministry of Justice's automated enforcement system, though the reason was not disclosed. The move follows a July 16 UNCITRAL arbitral order barring Kazakhstan from enforcing the fine until the arbitration concludes.

Key Facts

Kazakhstan suspended enforcement of the 2.3 trillion tenge environmental fine against NCOC on September 7, 2026, according to the Ministry of Justice's automated enforcement system.
On July 16, 2026, a UNCITRAL arbitral tribunal issued an interim order prohibiting Kazakhstan from enforcing the fine until the arbitration concludes.
On July 21, 2026, the Ministry of Justice imposed restrictions on NCOC's property and transport as part of the enforcement process.
The environmental claims stem from a 2022 inspection that found about 1.7 million tonnes of sulfur stored at Kashagan, exceeding the permitted 773,000 tonnes.
NCOC shareholders include Shell, Eni, TotalEnergies, ExxonMobil, KazMunayGas, CNPC, and Inpex, with total project investment estimated at $60 billion.

Enforcement Suspension

Kazakhstan suspended enforcement proceedings to collect a 2.3 trillion tenge environmental fine from NCOC on September 7, 2026. The suspension was recorded in the Ministry of Justice's automated enforcement system, but the reason was not disclosed. The suspension does not cancel the fine itself, only the enforcement procedure. Deputy Justice Minister Daniil Vaisov had previously stated that NCOC must voluntarily pay the fine by July 20, after which authorities would proceed with forced collection. On July 21, the Ministry of Justice imposed restrictions on NCOC's property and transport as part of the enforcement process.

Arbitration and Legal Dispute

NCOC is challenging the fine in international arbitration under UNCITRAL rules. On July 16, the arbitral tribunal issued an interim order prohibiting Kazakhstan from enforcing the fine until the arbitration concludes. The current suspension aligns with that interim order. The environmental claims arose from a 2022 inspection by the Atyrau Region Ecology Department, which found about 1.7 million tonnes of sulfur stored at Kashagan, exceeding the permitted 773,000 tonnes. NCOC rejects the allegations and maintains it complied with all requirements and permits.

Kashagan Project and Consortium

NCOC operates the Kashagan field, one of Kazakhstan's largest oil and gas projects. The NCOC consortium includes Shell, Eni, TotalEnergies, ExxonMobil, KazMunayGas, CNPC, and Inpex. Total investment in the project is estimated at approximately $60 billion.