Environmental Law 2025

KAZAKHSTAN Trends and Developments Contributed by: Arman Bigazin, Mikhail Abdulov, Olzhas Abubakirov and Lidiya Sayenko, Haller Lomax LLP

and reducing the country’s carbon footprint. In 2024, the fund launched a programme focused on recycling, sorting, and waste disposal in collaboration with the MENR and government-owned environmental entity, Zhasyl Damu JSC. The programme includes 94 investment projects with a total funding of KZT185 billion (approximately USD342.59 million) from 2024 to 2026. The approved projects aim to reduce waste, mitigate environmen- tal impact, and promote recycling. Notable initiatives include sorting solid waste, acquiring specialised equipment for waste collection, and modernising tyre recycling processes. The implementation of these projects will enhance waste management practices and create new jobs while fostering innovative technologies in the region. The fund is also accepting applications for financing under favourable conditions, including a 3% annual interest rate and a financing term of three to 15 years. Water Reform Due to facing a significant water resource deficit, Kazakhstan adopted the new Water Code on 9 April 2025, developed by the Ministry of Water Resourc- es and Irrigation, which was established in 2023 in response to the country’s growing water scarcity. The Water Code introduces the notion of “ecologi- cal flow” to prevent the depletion of water bodies and rules on the minimum permissible level of water needed to sustain river, lake, and marine ecosystems. It also broadens public participation in water resource management decisions and strengthens environmen- tal protection requirements. Work is already underway to develop a National Water Resources Information System, while the safety of hydraulic structures has been given a dedicated chapter for the first time. Moreover, in 2024 the government adopted the “Con- cept for the Development of Water Resource Man- agement System of the Republic of Kazakhstan for 2024–2030”. This document includes analysis of the current situation regarding water resources in Kazakh- stan, the vision for the development of the water sec- tor, target indicators and expected outcomes, and an

action plan for implementing the water management system concept from 2024 to 2030. To enhance co-ordination and strengthen partnerships in the water sector, the UNDP in Kazakhstan has sup- ported the establishment of a Coordination Council of Water Sector Development Partners, bringing together representatives from government, the private sector, and civil society. This council aims to foster collabora- tion, streamline decision-making, and ensure that all stakeholders work towards a unified national water management strategy. Strengthening Climate Change Policy At the Summit on Climate Ambition 2020, the Presi- dent of the Republic of Kazakhstan, Kassym-Jomart Tokayev, announced the goal of achieving net zero greenhouse gas emissions by 2060. On 2 February 2023, the Strategy for Achieving Carbon Neutrality Until 2060 (the “Strategy”) was signed by the Presi- dent. The Strategy has been developed considering global climate trends and in compliance with relevant inter- national obligations. The Strategy considers the need to adapt the economy of Kazakhstan to global cli- mate trends, such as the introduction of mechanisms for cross-border carbon regulation, the dissemina- tion of ESG principles, the promotion and attraction of “green” investments, energy-efficient production, electrification and others. Moreover, according to the Action Plan for the Transi- tion to a Green Economy, measures have been adopt- ed for 2030 aimed at adapting to climate change, in particular by reducing water-use intensity, transform- ing agriculture, improving energy efficiency, modern- ising housing and utilities infrastructure, developing sustainable transport, preserving ecosystems, and increasing forest cover. Priority of Industrial Development Until 2029 Under the National Development Plan of the Republic of Kazakhstan Until 2029 (approved by the President in 2024), the state policy set a goal to increase envi- ronmental sustainability in the field of ecology. The development of the industry will be aimed at achieving carbon neutrality, improving air quality, focusing on

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