On 12 September the government published decree No. 1162, signed the same day. It amends fourteen points and all four annexes of the rules under which Russia provides state guarantees for loans taken out by industrial exporters. The changes pull in opposite directions. The entry test gets easier: a firm with overdue tax debt on the qualifying date can now still qualify if it has since cleared that debt. Scrutiny of the same firm's accounts gets tighter: a company that changed its accounting policy in the last two years must restate its earlier reports; every exporter, not only those legally subject to audit, must now provide an audit opinion; and a new statement must show how much of the applicant's charter capital its founders have not paid in. Neither the government nor Minfin published a release, and no explanatory note is available.

The programme the decree governs

Decree 1162 names no sum. The budget law does. Federal law No. 426-FZ of 28 November 2025, on the 2026 federal budget, carries the guarantee programme in two annexes, and both have a line under the same name as these rules.

Annex 33, in roubles, lists two lines supporting industrial exports: 34,600,000.0 thousand roubles for loans taken out by Russian exporters, and 3,460,000.0 thousand for loans taken out by AO ROSEXIMBANK — exactly a tenth of the first. Together they make 38.06 bn roubles. The whole rouble guarantee programme for 2026 totals 634,060,000.0 thousand roubles, so the export lines account for 6.0% of it. The two larger lines are 296.0 bn for loans to Russian legal entities for purposes set by the government, and 300.0 bn for the state-owned company that insures exports.

Annex 35, in dollars, makes the contrast stark. Support for industrial exports is $50.0 mn. Two lines for loans to the state atomic corporation Rosatom are $3,850.0 mn and $4,900.0 mn. The annex totals $8,800.0 mn, so Rosatom's two lines account for 99.4% of the foreign-currency guarantee programme and the export line for 0.57%.

Both annexes record a right of regress for these lines: if the state pays, it acquires a claim on the borrower.

What the decree makes easier

Two conditions are restated. Point 9 governs the principal — the exporter itself. In the version in force from 1 June 2024, its subparagraph (a) required, alongside the absence of overdue debt to the Russian Federation, simply:

“…and also of an unfulfilled obligation to pay taxes, levies, insurance contributions, penalties, fines and interest payable in accordance with the legislation of the Russian Federation on taxes and levies.”

The repayment alternative in that sentence — “or the repayment of overdue (unsettled) debt existing on that date” — attached only to the debt owed to the state. The tax limb had no alternative at all. The new wording gives it one:

“…and also the absence, as at the 1st day of the month in which the state guarantee is granted, of an unfulfilled obligation on the part of the principal to pay taxes, levies, insurance contributions, penalties, fines and interest payable in accordance with the legislation of the Russian Federation on taxes and levies, or the repayment of overdue (unsettled) debt existing on that date in respect of taxes, levies, insurance contributions, penalties, fines and interest payable in accordance with the legislation of the Russian Federation on taxes and levies.”

Point 17 governs the guarantor and the bank-guarantor — the parties backing the exporter. Its subparagraph (b) previously contained no repayment alternative on either limb:

“the guarantor, the bank-guarantor has no overdue (unsettled) debt, as at the 1st day of the month in which the state guarantee is granted, on monetary obligations to the Russian Federation and on obligations secured by state guarantees of the Russian Federation granted earlier, and also no unfulfilled obligation to pay taxes, levies, insurance contributions, penalties, fines and interest payable in accordance with the legislation of the Russian Federation on taxes and levies.”

The new version adds “or the overdue (unsettled) debt existing on that date has been repaid” to both limbs. For the parties backing the exporter, this is the larger change: the test goes from clean on the date to clean on the date or cleared since.

This is a narrower change than it may sound. The money still has to be paid; what changes is that arrears on the qualifying date no longer disqualify by themselves. But the test was there to sort applicants, and it now sorts fewer of them out.

What the decree makes harder

Earlier reports must be restated. Points 25 and 26 each gain a paragraph, one for the principal and one for the guarantor. The principal's reads:

“In the event of a change, in the last 2 years preceding the year in which the state guarantee is granted, in the principal's accounting policy and (or) the application by the principal of new accounting standards entailing a change in the principal's accounting (financial) statements, […] information (data) shall be submitted on the values of retrospectively adjusted indicators of the accounting (financial) statements used in assessing the principal's financial position, for previous reporting periods in which the changes in accounting policy and (or) the new accounting standards were not applied. The accuracy of the said information (data) must be confirmed by the head and the chief accountant of the principal.”

The decree gives the requirement its own purpose: the restated figures go to the government's agent for the analysis of the principal's financial position under point 34. What the rule removes is the option of putting the assessed periods on bases that cannot be compared with one another. Which way a change of basis had moved anyone's figures, the decree does not say, and neither do we.

The audit opinion stops being optional. Point 7 of annexes 1 and 3 required a copy of the audit opinion on the exporter's annual accounts for 2 years — 3 if the application comes in the first quarter — followed by a parenthesis: “(for legal entities which, in accordance with the legislation of the Russian Federation, must undergo an annual audit)”. The decree strikes that parenthesis in both annexes. Point 7 of annexes 2 and 4 carried a different parenthesis, “(in the event it is provided)”, on the audit opinion of ROSEXIMBANK and of the principal respectively. The decree strikes that too. The requirement remains; in all four cases, the escape from it disappears.

A new statement on the applicant's own capital. Annexes 1 and 3 gain new points 10 and 11, in near-identical wording:

“A statement of the Russian exporter containing information on the receivables of founders (participants, shareholders, owners, members) in respect of contributions (deposits) to the charter capital (charter fund, unit fund, joint capital) of the Russian exporter, on the payment for shares of the Russian exporter, on deferred income recognised by the Russian exporter in connection with the receipt of state aid and also in connection with the gratuitous receipt of property (as at the end of each reporting period).”

Three things are asked for together, and they are not the same kind of thing. The first two — capital the owners subscribed but have not paid in, and shares not paid for — are equity carried on paper without the money behind it. The third is not that: aid and property received from the state for nothing are real assets, genuinely received. What declaring them shows is that they did not come from trading. Between them the three tell the agent how much of the reported position was neither paid in by the owners nor earned by the business.

Two smaller tightenings. Point 23 gains a requirement to file certified copies of the constituent documents of the principal, the beneficiary, the guarantor and the pledgor with Minfin, except where the beneficiary is the state development corporation VEB.RF. And in point 24 the deadline for filing the complete set of documents in order to obtain a guarantee in the current financial year moves from 1 December to 1 November — a month less.

What is routine, and should not be read as new

Point 1 of the rules is extended from “in 2023 – 2025” to “in 2023 – 2026”. Last year's amendment did the same thing, moving the window from 2024 to 2025. Points 56 and 65 gain a paragraph under which a 2026 guarantee covers obligations due after 1 January 2029, and points 57 and 66 add the matching exclusion. The rules already carried 1 January 2026 for a guarantee granted in 2023, 1 January 2027 for 2024 and 1 January 2028 for 2025: this is the next rung of an existing ladder, not a new deferral. In point 5 of the decree being amended, the word “Promsvyazbank” is replaced by “Bank PSB”. And in points 61 and 71, which set out what a guarantee agreement must contain, a formula about credit funds “received before the date the state guarantee enters into force” is extended to further subparagraphs — on liability for misuse of the money, and on changes to the credit agreement that need the agent's prior approval. That formula is not new: it has stood in subparagraph (e) of both points since 14 August 2025, when decree No. 1171 put it there. The decree extends an existing formula; it does not create a new one.

The one substantive addition on the recovery side is in point 3. Subparagraph (l) is restated so that the government's agent takes measures to recover debts owed by principals, guarantors, bank-guarantors, pledgors and others to the Russian Federation, represented by Minfin. Those debts may arise not only from granting and executing state guarantees but also from non-performance of the guarantee agreements themselves. Subparagraph (zh) adds that the agent “has the right to request all necessary documents” for its monitoring.

Why a state guarantee is a budget question

A state guarantee costs the budget nothing while the borrower pays. It is a contingent obligation: the state's exposure sits in its debt, not in its spending, and it becomes money only if the borrower fails, at which point the Russian Federation pays and — these lines all carry a right of regress — tries to collect. So a change in who may qualify does not show up in the deficit on the day it is made, and would show up late and all at once.

Read in that light, the two halves of this decree are one decision. Widening a condition cannot narrow the pool it selects from: everyone who passed before still passes, and some who failed this particular test no longer fail it. Whether that larger pool is weaker in credit terms is not something the decree establishes, and we have not measured it. What the decree does set out is the evidence the state wants before it lets anyone in: restate the old numbers on the new basis, produce the audit opinion whether or not the law forces you to have one, and declare how much of your own capital your owners never actually paid in. The entry test now excludes fewer applicants, and what every applicant must show has gone up.

One caution about our own series: the new statement concerns receivables owed by an exporter's founders on their charter-capital contributions. That is not the series overdue receivables measures, which is Rosstat's pile of unpaid bills between Russian organisations. The two share a word and nothing else.

What this changes in our model

Nothing. Guarantee rules are not one of our eight components, and no rule change enters the index.

The strength index stands at 46.8 out of 100, in the stress zone. No indicator moved in today's data update. Overdue receivables remains the weakest of the eight at 9 out of 100, and oil and gas revenue the second weakest at 14.

What we do not know

How much has actually been guaranteed, and whether any guarantee has ever been called. The 38.06 bn roubles and $50.0 mn above are ceilings the budget law sets for 2026, not amounts issued. We found no public accounting of guarantees granted under these rules, and none of calls made on them. Without that, the cost of easing the entry test cannot be estimated from these documents — and unpriced is not the same as small.

Why the change was made. There is no explanatory note. The project cards on regulation.gov.ru did not answer, so the reading above is drawn from the decree's own text and from what the text replaced, not from a stated purpose.

When it takes effect. The decree contains no commencement clause of its own. Russian law supplies a default for government acts that have none, and which limb of that default applies turns on how the act is classified. We did not open that rule in this session, so we put no date on it here.

What point 7 of annexes 2 and 4 requires in full. We read the prior wording of those points in a consolidated redaction rather than in the annexes as originally published, and the decree prints only the words it strikes.