For many years, the Russian market for carbon units existed in a strange state: climate projects were launched, carbon units were produced, companies announced compensation for the trace, but there was no legal infrastructure that would determine the rules of the game for all participants. Verifiers worked without a law confirming their status. Carbon units, once released, did not have a cancellation mechanism even if the forest planted to create them was burned or cut down. And the Sakhalin experiment, designed to test emission quotas at the regional level, remained the only territory where this model actually worked. In one 2026, all three levels of the problem moved at once: the State Duma received a bill on verification, the federal law included the concept of “release,” and six regions began to build their own pilot programs on the Sakhalin model.
Verification gets a legal definition for the first time
Until now, verification of information on greenhouse gas emissions in Russia existed in a kind of legal vacuum. There are already about twenty accredited verifiers in the country, they actually worked and checked climate projects, but the term “verification” itself was not in the legislation. This created an uncomfortable situation: the procedure on which the release of carbon units and the credibility of companies’ climate reporting depend did not actually have a clear legal status.
On August 21, 2026, the government submitted to the State Duma bill No. 1322877-8, which for the first time enshrines in the legislation the concept of “verification of information on greenhouse gas emissions.” Formally, the procedure remains voluntary, the law does not oblige each company to pass an emissions audit. But there are clear rules of the game for those who pass such a test or conduct it.
The main rule: the verifier cannot be affiliated with the company whose emissions it checks to eliminate conflicts of interest. The form of the verifier report and the procedure for entering the results into the emissions register will be established by the government. For the market, this means a transition from the situation “everyone checks as he wants and as he knows how” to a standardized procedure with understandable requirements for qualifications and independence.
The bill creates a legal framework for the entire chain:
- the company counts emissions,
- verifier checks them,
- the result is entered in the register,
- carbon units are issued or compensation decisions are made based on verified data.
Without the verification link enshrined in the law, this whole chain rested on trust and corporate procedures, and not on legal norms.
Release: what happens to the carbon unit now
From September 1, 2026, Federal Law No. 296-FZ “On Limiting Greenhouse Gas Emissions” includes a new concept – “release.” The amendment was introduced by Federal Law No. 578-FZ of 29.12.2025, and its practical meaning is more important than the legal wording.
Imagine a climate project: a company restores a forest plot, performs verification, receives carbon units for proven CO ₂ absorption and uses them to compensate for its footprint. Several years pass, and a fire occurs on this site. Or illegal logging. Or force majeure, that destroys landings. What happens to already released and possibly already sold or credited carbon units? Until now, the answer to this question has not been spelled out in the law.
The release mechanism solves this very problem. If the result of the climate project is reversible, previously counted emissions reductions can be canceled. For the carbon unit market, this means a fundamentally new level of requirements for the sustainability of projects: now it is not enough to prove that the forest is planted and absorbs carbon today. It is necessary to ensure the conditions under which this absorption will continue for decades, and take into account the risk of loss.
The law also introduces the concept of “reserve account” – a special mechanism through which units at risk of release will be taken into account. This is a kind of insurance buffer: some of the issued units are reserved in case the project suffers from fire, illness or felling. If nothing happens, the reserve can be unlocked. If the project has lost part of the takeover, the reserved units go to cover the losses and do not go into circulation.
For forest climate projects, these amendments are of particular importance. Forest, unlike the carbon capture technology solution, is vulnerable to natural and human-induced risks. A fire in the taiga can destroy the result of many years of work in one season. The release mechanism and reservation account force designers to lay this risk from the very beginning, and not count on the fact that the fire will bypass their site.
Six regions queue for Sakhalin model
Law No. 34-FZ “On conducting an experiment to limit greenhouse gas emissions in certain constituent entities of the Russian Federation” was originally written so that any region could join voluntarily, by decision of its own authorities and without the need for a separate federal law for each entity. This was used by Yakutia, the Komi Republic, Tatarstan, Irkutsk and Arkhangelsk regions, and the Stavropol Territory: in the spring and summer of 2026, they began to form their own pilot programs according to the Sakhalin model.
The Sakhalin model, which started in September 2022 on the basis of Law No. 34-FZ, includes several key elements: an inventory of greenhouse gas emissions in the region, quotas for the largest issuers, the creation of a carbon conversion system and verification of results. At the end of 2025, the Sakhalin Region announced the achievement of carbon neutrality: the absorption of greenhouse gases in the region exceeded their emissions. The experiment was extended until December 31, 2028 to assess the stability of the result and study the scaling to other subjects.
Six new regions follow the same route. Each of them forms its own inventory of emissions, determines the circle of quota enterprises and begins to build a regional accounting infrastructure. The difference in terms and starting conditions: Sakhalin has gone from the start of the experiment to the declared neutrality in three years, and new participants will have to do the same, taking into account their regional specifics. Yakutia, for example, has a huge low-density area and a specific emission pattern associated with diamond and gold mining. Tatarstan, on the contrary, is a compact industrial region with a high concentration of petrochemicals and oil refining, where quotas will affect most of the economy.
It is 2028 that will become the point of reconciliation. By this time, the Sakhalin experiment will be completed, and the federal center will decide whether to scale the model throughout the country. If it turns out that the model works only on an island territory with a unique economic structure, the conversation about the national quota system may be postponed.
What it means for forest climate projects
All three changes that occurred in 2026 converge at one point: forest-climatic projects in Russia should become more professional, transparent and sustainable.
The Verification Act creates a legal framework for verifying any climate project. The verifier, not affiliated with the designer, does not check the fact of planting trees, but the reliability of the absorption calculation, the correctness of the baseline, and the quality of monitoring. This closes the door for projects where planting exists only on paper, and no one is interested in survival.
The release mechanism and reservation account force the project to take into account the risk of loss. A forest-climatic project that does not lay a reserve in case of fire becomes obviously more risky for the investor: units can be canceled, and the compensation of the trace will be invalid. It is beneficial for the designer to invest in fire protection, monitoring and protection of the site, because this directly affects the number of units that will go into circulation.
The expansion of the Sakhalin model into six regions creates a potential demand for carbon units from companies that will be subject to quotas. If a region imposes emission quotas, the facility must either reduce its own emissions or buy quota fulfillment units. And one of the tools for fulfilling quotas can be forest climatic projects – this turns the forest from a charitable activity into an asset in demand by the market.
Rosleskhoz in March 2026 estimated the absorption of Russian forests at about 1 gigaton equivalent of CO ₂ and directly linked forestry with low-carbon development. But this is an estimate of natural potential, not the amount of carbon units available to businesses. The difference is fundamental: planting a thousand trees and releasing a thousand carbon units are different actions. The unit needs methodology, demonstrable incremental effect, monitoring, independent verification, and accounting for loss-of-takeover risk. The correct sequence is as follows: first reduce your own emissions, then compensate for the remainder through verifiable projects. Forest is an asset with a provable result and verification price, not a photograph for the annual report.
Business will have to prove, not declare
The Russian carbon market in 2026 passes the point after which “planting a forest and declaring compensation” becomes insufficient. The market receives rules on three fronts at the same time: who checks (the law on verification) what happens when the result is lost (release mechanism) and where quotas work (expansion of the Sakhalin model).
For companies that are already launching or planning climate projects, that means three practical steps.
- Provide independent verification under rules that will soon become law rather than industry custom.
- Lay a reserve for the risk of loss of absorption, especially if the project is associated with a forest vulnerable to fires and logging.
- Monitor the deployment of regional quotas in six new regions – this is where the demand for carbon units from enterprises that need to fulfill quotas is formed.
Companies that start building this infrastructure now will have an advantage: by the time the rules become mandatory, and quotas cover more regions, they will already have a ready-made portfolio of verified, sustainable projects with a digital footprint. Those who continue to work in the “planted, photographed, reported” mode will face the fact that their units do not pass verification, do not have a reserve for risk and are not in demand by the market, which has already learned to distinguish a high-quality climatic asset from a beautiful picture.
By Andrey Khoroshilov, General Director and founder of the Save the Forest environmental service, member of the Skolkovo Foundation