On 15 September the government published decree No. 1165 of 12 September 2026, a 44-page act on a state guarantee of the Russian Federation for the obligations of the Russian legal entity that provides insurance support for exports. The decree has nine points. Point 1 approves the rules. Points 2 to 9 each read, in full: “For official use only.”
The rules approved under point 1 say what a government act granting this guarantee must contain — and that list is what the classified points hold. The budget law gives the ceiling: 300 bn roubles, the largest single line in Russia's rouble guarantee programme for 2026.
What the published half says
The decree's first point carries the operative text; the rest is a column of identical lines:
“1. To approve the attached Rules for granting a state guarantee of the Russian Federation for the obligations of a Russian legal entity providing insurance support for exports. 2. For official use only. 3. For official use only. … 9. For official use only.”
The rules run to 44 pages and are public. Point 1 sets the year: this is a guarantee granted in 2026, in roubles, for the principal's obligations under contracts of insurance and reinsurance. Point 2 defines the principal — a Russian legal entity, 100% of whose shares belong to the Russian Federation, on which the government has conferred the functions of insurance support for exports under part 1¹ of article 46¹ of the law on foreign trade regulation. Part 1 of that article names the three known operators — the Russian Export Centre, EXIAR and Roseximbank. Part 1¹ is the separate limb for “another organisation”, and it exists only because of government decisions “taken in 2022 and 2023”. Point 7 confirms the distance: EXIAR and the government's agent cannot be beneficiaries under this guarantee.
Point 9 sets the coverage. The guarantee secures the performance of up to 100 per cent of the principal's obligations to pay insurance indemnity to beneficiaries, within the sums insured, in roubles, on insured events under the contracts the principal concludes from the date the guarantee is issued. Point 10 narrows that to beneficiaries and contracts entered in a register the principal itself keeps. Point 11 excludes interest, commissions, penalties, early performance and damages. Point 12: there is one guarantee.
Three numbers in the published text bound the instrument. Point 52: the guarantee is granted without any guarantor's fee. Point 53: the Russian Federation bears subsidiary liability. Point 54: the guarantee runs no later than 31 December 2042 inclusive — an outer limit more than sixteen years out.
The other side is the right of regress. Under subparagraph (g) of point 13, the guarantee is granted only if security for the state's regress claims is provided in favour of Minfin in the form of a surety by a Russian legal entity that the government itself designates. Point 15 requires that security to be no less than the guarantee sum plus any regress claims already made and unpaid. Point 16 applies to the surety the same conditions as to the principal — no bankruptcy proceedings, no reorganisation, no overdue debt to the state and no unpaid taxes — and adds that at least 3 years must have passed since it was created.
The payout chain has fixed deadlines. On a beneficiary's demand, the government's agent has 30 working days to deliver an unambiguous conclusion to Minfin (point 68). Minfin then pays under the guarantee within 30 calendar days of receiving it (point 70). Payment gives the Russian Federation a regress claim on the principal, to be satisfied within 5 working days (points 71 and 72); if the principal does not pay, the agent turns to the surety (point 73).
And then point 27, which lists what the government act granting the guarantee must state:
“The act of the Government of the Russian Federation granting the guarantee must state: a) the principal's full name, location and address, taxpayer identification number and principal state registration number; b) the principal's obligations to be secured by the guarantee; c) the ceiling sum and term of the guarantee; d) the ceiling sum and term of the surety contract, and the surety's full name, location and address, taxpayer identification number and principal state registration number.”
Who, how much, for how long, and who stands behind it. That is points 2 to 9.
The ceiling is in the budget law, and it is the largest line
The sum is not entirely invisible. Federal law No. 426-FZ of 28 November 2025 on the 2026 federal budget carries the rouble guarantee programme, and its annex 33 lists the guarantees to be granted in 2026. Line 2.1 describes the principal in the same words decree 1165 uses — a Russian legal entity wholly owned by the Russian Federation, designated under part 1¹ of article 46¹ — for obligations under contracts of insurance and reinsurance. It lists 300,000,000.0 thousand roubles and a right of regress: “Yes”.
The whole programme comes to 634,060,000.0 thousand roubles. This one line is 47.3% of it. The next largest, 296.0 bn for loans to Russian legal entities for purposes the government sets, is smaller. The two lines that support industrial exports — 34.6 bn for exporters' loans and 3.46 bn for Roseximbank — together come to 38.06 bn, about an eighth of this line. The same annex repeats the 2042 term and the up-to-100% coverage, and adds a condition the decree does not: the 2026 guarantee is available only if a guarantee on analogous terms was not granted in 2025 under the previous budget law.
So the ceiling is public and the instrument already sits in the budget. Decree 1165 makes it operational — and classifies every parameter of the instrument that will actually be issued.
Why a guarantee nobody can size is a budget question
A state guarantee costs nothing while the principal pays. It is a contingent obligation: it sits in the state's debt, not in its spending, and becomes money only when the guarantee is called — at which point, under point 70, it becomes money within thirty days. We made the same point about the export guarantee rules the government rewrote on the very same day, decree 1162, which reached the industrial-export lines of this same annex.
What is covered here is narrower and harder. The principal insures export credits and investments against commercial and political risk, and reinsures that risk. Since 2022 it has had no home in the global reinsurance market. The state is putting its own balance sheet where reinsurance used to be, charging nothing for it under point 52, and securing its regress with a surety the government itself designates. Who ends up carrying the risk is therefore settled by the government rather than by a market — though the published rules never require that surety to be state-owned.
The other half is measurement. A contingent obligation is useful to readers only if they can size it and place it in time. Here the ceiling is known from the budget law. Everything else — the sum actually guaranteed, the term actually set, the identity of the principal and of the surety — is under a classification stamp. It is the same kind of decision as classifying a budget line, applied here to a decree.
The portal's own listing does not show the restriction: nothing in the document's metadata marks it. Decree 1165 appears in the feed as an ordinary 44-page act. The only way to see the stamp is to open the first page.
What this changes in our model
Nothing. Contingent obligations are not one of our eight components, and no guarantee enters the index until it is called and paid.
Today's data update moved one indicator: the liquid NWF rose from $46.2 bn to $46.7 bn on August data, lifting that score from 28 to 29. The strength index stands at 47.3 out of 100, in the stress zone, against 47.2 yesterday. Overdue receivables remain the weakest of the eight at 9, and oil and gas revenue the second weakest at 14. No trigger.
What we do not know
Who the principal is. The public half never names it. It says only what the entity is not: not EXIAR, not the government's agent, not one of the operators listed in part 1 of article 46¹. The government decisions of 2022 and 2023 that conferred the functions on “another organisation” are referred to in the law but we did not find their texts.
The sum and term actually granted, and who the surety is. These are points 2 to 9. The 300 bn is the budget law's ceiling for the line, not an amount issued, and the 2042 date is an outer limit, not a term.
Whether a guarantee on analogous terms was granted in 2025. Annex 33 makes the 2026 line conditional on it not having been. We did not open the 2025 budget law or any register of guarantees issued, and we found no public accounting of either.
Why the eight points are classified. There is no explanatory note; regulation.gov.ru returns 308 on its projects section. The rules themselves offer no reason, and we do not impute one.
What is on the pages we did not read. We read the decree page and rules points 1 to 17, 23 to 31, 35, 36, 51 to 54 and 68 to 75. The remaining pages are the forms and annexes, and we did not open them page by page.