Kazakhstan suspends NCOC's 2.3 trillion tenge fine collection after court request

September 9, 2026 at 11:29 AM2 min

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Kazakhstan has temporarily suspended enforcement of a 2.3 trillion tenge environmental fine against the NCOC consortium. The suspension follows a complaint by NCOC against the state bailiff, prompting the Atyrau specialized inter-district administrative court to request enforcement case materials. The Ministry of Justice said collection will resume after the court returns the materials.

Key Facts

The Ministry of Justice confirmed that NCOC filed a complaint against the state bailiff, leading the Atyrau specialized inter-district administrative court to request enforcement case materials.
The 2.3 trillion tenge fine was imposed in March 2023 by the Ministry of Ecology and Natural Resources for environmental violations at the Kashagan field.
On April 8, an Astana court upheld the decision to recover 2.3 trillion tenge from NCOC, and the Atyrau regional court confirmed the lower court ruling on June 19.
On July 16, an international arbitral tribunal issued interim measures prohibiting Kazakhstan from enforcing collection against NCOC until the arbitration concludes.

Suspension of Enforcement

The Ministry of Justice stated that NCOC filed a complaint against the state bailiff's actions. The Atyrau specialized inter-district administrative court requested materials related to the enforcement proceedings. Under Kazakh law, enforcement is temporarily suspended when a court requests case materials, and it resumes after the court returns them. The ministry emphasized that collection from NCOC will continue in accordance with the law once the court returns the materials.

Environmental Violations and Fine

The fine stems from environmental violations at the Kashagan field, where the Ecology Department of Atyrau region conducted an inspection in 2022. The inspection found that the Bolashak complex stored over 1.2 million tons of excess sulfur, more than double the permitted norm. The consortium was also cited for unauthorized flaring of raw gas and discharge of contaminated wastewater. In March 2023, the Ministry of Ecology and Natural Resources imposed a fine of approximately 2.3 trillion tenge on NCOC. NCOC denied the violations, stating that sulfur production and storage comply with Kazakh legislation and applicable standards.

Court and Arbitration Proceedings

On August 1, 2025, the Astana administrative court of appeal annulled the Ecology Ministry's order against NCOC, citing procedural violations. The ministry later corrected the deficiencies and reissued the claim against the company. In December 2025, the Astana court rejected NCOC's appeal against the environmental fine. In February 2026, foreign shareholders in the Kashagan project initiated international arbitration against Kazakhstan under UNCITRAL rules. On April 8, the Astana court confirmed the recovery of 2.3 trillion tenge from NCOC, and the Atyrau regional court upheld this decision on June 19. The company was ordered to pay the fine voluntarily by July 20, with forced collection to follow if payment was not made. On July 16, an international arbitral tribunal issued interim measures prohibiting Kazakhstan from enforcing collection against NCOC until the arbitration concludes.