Mandatory greenhouse gas (GHG) emissions reporting is a component of Russian climate regulation. In accordance with Federal Law No. 296-FZ “On Limiting Greenhouse Gas Emissions” of July 2, 2021, entities required to submit GHG reports (regulated organizations) include legal entities and individual entrepreneurs whose activities:
- Are accompanied by GHG emissions, the mass of which is equivalent to 150,000 or more tons of carbon dioxide equivalent per year for the period up to January 1, 2024. After this period, the emission threshold is reduced to 50,000 or more tons of carbon dioxide equivalent per year;
- Meet the criteria for production processes and (or) types of economic and other activities established by Decree of the Government of the Russian Federation No. 355 of March 14, 2022:
- Stationary combustion of gaseous, liquid, and solid fuels;
- Combustion of hydrocarbon mixtures – natural gas or associated petroleum gas – in flare installations;
- Technological operations carried out during the exploration, production, processing, transportation, and storage of oil and gas;
- Technological operations carried out during the extraction, processing, transportation, and storage of coal;
- Ferrous metallurgy;
- Non-ferrous metallurgy;
- Production of mineral materials;
- Chemical industry;
- Petrochemical production and production of soot;
- Fuel combustion in transport;
- Waste management.
The list of GHGs for which state accounting of GHG emissions is carried out and the register of GHGs is maintained is approved by Order of the Government of the Russian Federation No. 2979-r of October 22, 2021 (carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), nitrogen trifluoride).
Regulated organizations with GHG emissions of 150,000 or more tons of carbon dioxide equivalent submit the first GHG report by July 1, 2023, with emissions of 50,000 or more tons – by July 1, 2025. The report is submitted through the GIS “Energy Efficiency” service to the Ministry of Economic Development of the Russian Federation for entering the data contained therein into the unified national register of greenhouse gases.
Legal entities and individual entrepreneurs who are not regulated organizations have the right to submit a GHG report.
Organizations can independently calculate their GHG emissions using the Methodology approved by Order of the Ministry of Natural Resources of the Russian Federation No. 371 of May 27, 2022. To simplify calculations, you can use the online calculator on the GIS “Energy Efficiency” website. The calculator allows you to quickly assess whether a report is required.
The GHG emissions reporting for the calendar year is compiled in the form approved by Decree of the Government of the Russian Federation No. 707 of April 20, 2022, and is signed with a qualified electronic signature (QES).
From July 1, 2025, administrative responsibility is introduced for non-submission or untimely submission of GHG reports, or for the provision of deliberately false information in the report.
The law adopted by the State Duma establishes fines for:
- Officials: from 10,000 to 50,000 rubles.
- Individual entrepreneurs: from 50,000 to 150,000 rubles.
- Legal entities: from 150,000 to 500,000 rubles.
Until this time, Article 8.5. of the Administrative Code of the Russian Federation “Concealment or distortion of environmental information” may be applied, which provides for:
- Imposition of an administrative fine on citizens in the amount of from 500 to 1,000 rubles;
- On officials – from 3,000 to 6,000 rubles;
- On legal entities – from 20,000 to 80,000 rubles.
