The pause surfaced first in the ministry's enforcement database, where the entry against the Kashagan operator changed to “suspended, 07.09.2026”, as Interfax-Kazakhstan reported on Tuesday evening. The ministry explained it on Wednesday morning: NCOC has appealed the state bailiff's actions, and the Specialised Interdistrict Administrative Court of Atyrau region has requested the enforcement file. Until then, the proceedings wait. The fine stands; its collection waits on a court that has asked to see the file.
The debt the ministry is collecting is precise to the tenge: 2,356,293,268,036, or $5.2 billion at the National Bank's rate for 10 September. The deadline for voluntary payment expired on 20 July. On 21 July the bailiff froze NCOC's property and vehicles and banned notarial actions on them. Accounts stayed open, Kapital reported. The consortium's managing director, Giancarlo Ruiu, was warned of administrative and criminal liability for non-compliance with the court ruling, according to The Times of Central Asia.
The fine goes back to an inspection by the Atyrau region's ecology department in 2022. The regulator accused NCOC of storing sulfur, a by-product of Kashagan's sour oil and gas, in volumes above the environmental permit, more than 1.2 million tonnes over the norm by Kapital's account, and added untreated wastewater sent to evaporation ponds and gas flared without a permit. The penalty, imposed in March 2023, rests on part 1 of article 328 of the Code of Administrative Offences, the article on breaching the norms of permissible anthropogenic impact on the environment, which fines a company 10,000% of the payment rate for negative environmental impact, applied to the excess quantity of pollutants; that formula produced the 2.3 trillion tenge. The first order fell on procedural grounds. The regulator reissued it, and the reissued penalty has held in court, the Atyrau Regional Court's decision of 19 June the latest, as the Times of Central Asia and Petrocouncil record it; Kapital counts the Supreme Court among the instances that have rejected NCOC's appeals.
NCOC's position, as the ministry's statement relays it, is that its handling of sulfur complies with the law and that the company will use every available means to defend its rights. The foreign shareholders opened treaty arbitration in February, Vlast recalls, and on 16 July the consortium said a tribunal sitting under UNCITRAL rules had ordered Kazakhstan not to enforce the fine while the case runs. The ministry's answer, in Kapital's account, is that such an order takes no priority over national law, and its Wednesday statement attributes the pause to the domestic court challenge alone.
The fine stands; its collection waits on a court that has asked to see the file.
Kashagan produced 18.2 million tonnes of oil in 2025, the Times of Central Asia recalls. KazMunayGas holds 16.88%; Eni, ExxonMobil, Shell and TotalEnergies about 16.81% each; CNPC 8.33%; Inpex 7.56%. The sum in dispute is larger than the 2 trillion tenge targeted transfer from the National Fund that the finance minister wrote into the 2027 draft budget on 25 August.
The sulfur case is one of several between Astana and the field's investors. The government has also claimed against the consortium over costs it booked as recoverable under the production-sharing agreement, the outlet notes, and some companies and analysts have called the approach resource nationalism, a label Astana rejects. The ministry says it intends to resume collection when the court returns the file. No date for that is on the record.