The Government of Kazakhstan has approved a comprehensive Action Plan for the implementation of the Strategy for Achieving Carbon Neutrality of the Republic of Kazakhstan until 2060 (the “Action Plan”). The Action Plan was approved by Order of the Prime Minister of the Republic of Kazakhstan No. 145-р dated 1 September 2026. It implements Presidential Decree No. 121 dated 2 February 2023 approving Kazakhstan’s Carbon Neutrality Strategy to 2060.
The Action Plan establishes an extensive long-term implementation architecture and covers electricity and heat generation, hydrogen, mining and oil and gas, transport, buildings and utilities, industry, agriculture and forestry, waste, energy efficiency, carbon markets, climate adaptation, green technologies, financing and climate reporting.
A significant number of measures include studies, strategies, roadmaps, methodologies, standards, pilot projects or proposals for future regulation. At the same time, the Action Plan provides an important indication of the direction of Kazakhstan’s regulatory policy and the areas in which new requirements and investment mechanisms may emerge.
For developers and investors, the most relevant developments include the planned assessment of coal-generation replacement, development of hydrogen regulation and infrastructure, industrial decarbonisation, carbon capture and storage (“CCS”), carbon offsets, changes to the emissions trading system (“ETS”), potential carbon taxation, climate reporting, green-project classification and new financing mechanisms for the low-carbon transition.
A long-term implementation roadmap
The Action Plan establishes measurable emissions trajectories through 2060. The Government’s stated targets include reducing net greenhouse gas emissions to 327.8 million tonnes by 2030, 302.1 million tonnes by 2040, 163.0 million tonnes by 2050 and zero by 2060. For the energy sector, the corresponding targets are 117.3 million tonnes, 110.8 million tonnes, 48.7 million tonnes and 3.2 million tonnes respectively.
The Action Plan also sets sector-specific trajectories for transport, buildings, methane emissions, industry, agriculture and forestry, land use and waste. It targets 37.1 million tonnes of CO₂-equivalent captured through CCS technologies by 2060.
Implementation is centrally coordinated, with responsible state bodies and participating organisations required to take the necessary measures under the Action Plan and report monthly to the Ministry of Ecology and Natural Resources.
Why this matters
The significance of the Action Plan lies in the targets it sets and also in the measures envisaged to achieve them. For investors, the key issue is how these measures will translate into subsequent legislation, technical requirements, market mechanisms and state support, and what implications this may have for particular projects.
Power sector: transition of the generation fleet
The electricity and heat-generation section places the existing coal fleet within the long-term decarbonisation framework.
The Ministry of Energy is tasked with analysing the current condition of coal-fired generating assets, including their technical condition, economic efficiency and potential replacement by alternative sources. The analysis is scheduled for 2027. A further measure envisages an assessment of the possibility of phased withdrawal or replacement of coal-generation equipment, taking into account priorities, required investments and the development of corresponding action plans, with completion scheduled for 2028. The Action Plan therefore creates a basis for future decisions concerning the evolution of Kazakhstan’s generation fleet.
At the same time, the Action Plan identifies a broader set of technologies capable of supporting the transition. It provides for a 2028–2030 plan for the development of hydrogeothermal resources for combined electricity and heat production. It also envisages the deployment of intelligent energy-management and energy-saving technologies through 2060.
For developers, we believe this points to potential growth in projects involving renewable electricity generation, renewable heat, geothermal and hydrogeothermal resources, energy-efficiency technologies, smart energy-management systems, electrification of heat, and technologies enabling the decarbonisation of existing generation and industrial assets.
Hydrogen moves from policy concept towards a regulatory framework
One of the most notable elements of the Action Plan is the development of Kazakhstan’s hydrogen economy. The Government plans to establish an interagency council on hydrogen energy in 2026–2027, followed by proposals to improve the regulatory framework for hydrogen energy in 2027–2028.
The Action Plan also provides for an assessment of Kazakhstan’s domestic market for potential producers and suppliers of low-carbon hydrogen and the establishment of a corresponding register in 2026–2027.
Importantly, the Government intends to develop decarbonisation roadmaps for the metallurgical, chemical and cement industries, agriculture and transport using low-carbon hydrogen and hydrogen derivatives, including green ammonia, methanol and green steel. These roadmaps are scheduled for 2027–2028.
The Action Plan further envisages:
- assessment of localisation potential for hydrogen-chain equipment and components;
- pilot low-carbon hydrogen projects in industrial, agricultural, transport and energy sectors;
- development of hydrogen-sector skills and training; and
- R&D in hydrogen technologies.
The Action Plan also calls for the development of national standards for hydrogen infrastructure addressing safety, resource efficiency, certification of origin and carbon-footprint accounting, with a view to integrating hydrogen into the national ETS and supporting compliance with international requirements for exported products.
Investor perspective
The regulatory development of hydrogen is particularly relevant for projects combining renewable generation with hydrogen production.
The Action Plan’s reference to renewable electricity as part of the hydrogen value chain and its focus on certification of origin and carbon-footprint accounting suggest that future project structures may need to address not only electricity production, but also the traceability and carbon attributes of hydrogen and its derivatives.
Industrial decarbonisation and green technologies
The industrial component of the Action Plan is designed to create a framework for reducing the carbon intensity of Kazakhstan’s industrial base. Among the measures is an assessment of the use of carbon, together with CCS technologies, for the production of various materials. A further measure would examine the introduction of material passports and lifecycle greenhouse-gas accounting, including possible verification and “green product” labelling systems.
The Action Plan also contemplates the potential inclusion of hydrogen technologies in references for Best Available Techniques (“BAT”) and the register of green technologies, subject to compliance with environmental legislation.
These measures could become increasingly relevant for industrial investors whose projects depend on:
- BAT compliance;
- environmental permitting;
- low-carbon technology classification;
- product carbon-footprint disclosure;
- green certification; or
- access to international markets requiring carbon-related information.
Buildings, energy efficiency and distributed generation
The Action Plan also addresses buildings and distributed energy. Key measures include thermal modernisation, energy-efficiency improvements, heat pumps and the use of renewable energy in buildings.
In particular, the Action Plan provides for:
- incentives for rooftop solar collectors and photovoltaic panels on residential and municipal buildings (2030–2060);
- phased deployment of heat pumps for heating and hot-water supply (2026–2050); and
- mandatory energy-efficiency classification of new and reconstructed buildings, from A+ to E, with subsequent expansion to existing buildings during major renovations (2030–2040).
These measures may support further development of distributed renewable generation, energy-efficiency services, heat-pump deployment and building modernisation in Kazakhstan.
Carbon market: potentially significant changes ahead
The Action Plan contains several measures that could materially affect Kazakhstan’s carbon-market architecture.
These include consideration of:
- expanding participation in the ETS, including potentially bringing financial institutions and carbon-market brokers within the definition of market participants;
- introducing paid auctions of carbon allowances, including allowances currently distributed through allocation mechanisms;
- considering the introduction of a carbon tax for non-regulated sectors by 2035;
- developing automatic systems for accounting for greenhouse-gas emissions, reductions and removals;
- establishing an optimal carbon regulation framework and a carbon market ecosystem with clearly defined mandatory and voluntary markets under Article 6 of the Paris Agreement; and
- creating a Carbon Fund in 2028–2029.
The Action Plan also contemplates the development of carbon-offset projects, including projects involving methane reduction and carbon absorption.
In agriculture and forestry, the Government intends to adapt existing methodologies for monitoring, verification and certification of carbon units generated through carbon absorption and storage in agricultural soils. A pilot project involving carbon offsets on state forest-fund lands is also envisaged during 2026–2030.
What to watch
These measures could gradually transform carbon from a predominantly compliance-related consideration into a broader financial and investment asset class. For project developers, bankability of carbon-related revenues will depend on the future rules governing eligibility, additionality, monitoring, verification, certification, ownership and transfer of carbon units.
Climate reporting and carbon-footprint regulation
The Action Plan also signals a move towards greater corporate climate disclosure. It provides for analysis of international standards and guidance concerning quantitative carbon-footprint accounting and management by sector and product, together with proposals to adapt such standards as national standards and guidance documents.
Of particular relevance to corporate investors is the planned introduction of:
- voluntary non-financial reporting from 2027; and
- mandatory climate reporting from 2028 within companies’ annual reports.
The Action Plan also provides for mandatory carbon-footprint-reduction criteria to be incorporated into digital platforms and processes used for selecting projects under state programmes in 2028–2029. This may be particularly relevant for businesses seeking state support, public financing or participation in government programmes.
Green finance and access to capital
The Action Plan recognises that achieving carbon neutrality will require mobilisation of both public and private capital. By 2027–2029, the Government intends to develop a strategic vision for financing the transition to carbon neutrality, including classification of financing sources (budgetary, private and foreign), proposals relating to tariff policy and the phased introduction of different financing mechanisms depending on the relevant sector and stage of decarbonisation. The Action Plan also envisages a mechanism for rapid and low-cost verification of projects against the thresholds of the taxonomy for green projects.
For developers, streamlined taxonomy verification could become relevant to the structuring of green loans, green bonds and other sustainable-finance instruments.
Climate adaptation becomes an investment consideration
The Action Plan is not limited to mitigation, as the Government plans a comprehensive assessment of climate risks and vulnerabilities affecting key economic sectors and regions, including an assessment of the interaction between climate change and decarbonisation measures.
It also provides for the incorporation of climate risks and adaptation measures into state and budget planning and for the preparation of regional climate-adaptation plans during 2026–2030.
For infrastructure investors, this may become increasingly relevant to project development and financing. Climate resilience may need to be considered alongside traditional environmental and technical due diligence, particularly for power, water, transport, industrial and real-estate projects.
Future outlook
The Action Plan marks an important shift from Kazakhstan’s high-level carbon-neutrality commitment towards a structured implementation programme extending across the economy.
The immediate legal effect of many measures will depend on subsequent legislation, subordinate regulations, technical standards and government decisions. Nevertheless, the timetable established by the Action Plan, with significant regulatory work scheduled for 2026–2030 and further measures extending to 2060, provides investors with an early view of the areas likely to shape Kazakhstan’s decarbonisation framework.
For developers and investors, this creates opportunities across the emerging low-carbon economy, including renewable energy, energy efficiency, hydrogen and its derivatives, green industrial technologies, CCS, carbon offsets, climate-resilient infrastructure and sustainable finance.
At the same time, companies operating in carbon-intensive sectors should anticipate increasing requirements concerning emissions measurement, carbon pricing, climate disclosure and the carbon intensity of products and operations.
Unicase continues to monitor the development of Kazakhstan’s energy-transition and environmental legal and regulatory framework and advises investors and project developers on the legal aspects of low-carbon projects throughout their lifecycle, including regulatory structuring, permitting and licensing, environmental compliance, investment and financing arrangements, and carbon market regulation.
This Legal Alert is provided for general information purposes only and does not constitute legal advice. The legal effect of individual measures under the Action Plan will depend on subsequent implementing legislation and regulatory instruments.