On 29 September the Bank of Russia's board of directors allowed banks to save capital on loans that finance the protection of critical infrastructure against air attack. The press release is short and we quote its operative sentences in full. It carries no sums, no expected volume of lending and no estimate of the capital saved.
What it does carry is a list of borrowers, and the list is the news:
“The decision applies to borrowers — legal persons, and also regions and municipalities — and will be in force from the moment of publication until 31.12.2026 inclusive.”
What was decided
Banks may apply reduced coefficients when calculating credit risk on such loans: 30% for investment-grade borrowers, 50% for other borrowers. They may also stop applying macroprudential add-ons to these exposures. The saving fits inside the limit already set for projects of technological sovereignty and structural adaptation of the economy; the central bank states that the free limits there are sufficient for both purposes at once. It gives no figure for that limit and none for what remains of it.
The measures “may subsequently be included in permanent regulation”. For now, they expire on the last day of this year.
The other half was signed five weeks earlier
The press release defines its subject by a footnote, and the footnote points at a presidential decree: No. 604 of 24 August 2026, on measures to secure critical infrastructure. That is the decree we wrote about on 28 August, when it appeared as the state's power to take over firms that fail to protect a site — the owner bears the cost of protection, or risks losing control of the asset to the federal property agency.
Re-reading the decree in the original alongside the new decision, two things in it matter here that did not matter then. The first is its opening line, which names its own cause: it was issued “in connection with the growth, during the period of the special military operation, of threats to the security of critical infrastructure objects of the Russian Federation”. The second is the width of the circle it draws — fuel and energy facilities, industry, communications, utility, transport and logistics infrastructure, power generation including nuclear, life-support systems, critically important and potentially hazardous facilities, and then a catch-all for “other objects of especially great importance for ensuring the security and economic stability of the Russian Federation and the life activity of the population”. Everything inside that circle is now also the perimeter of a cheaper loan.
So the sequence is this. In August the state made protecting these objects an obligation enforced by the threat of losing control of the asset. At the end of September the regulator made the loan that pays for that obligation cheaper to carry — through regulatory capital, not through a budget subsidy. The stick came first and the discounted credit five weeks later.
Who pays
Not the federal budget. It appears nowhere in this construction. The cost is split between two other balance sheets.
Banks carry the first part: a lower risk weight means less capital held against the same loan, which is a real transfer of risk-bearing capacity, not a grant. Borrowers carry the second — and among them the press release names regions and municipalities outright. A region that borrows to put air defence around a substation adds to a debt stock that lands in the consolidated regional balance, for a cost that was in no regional budget when the year was planned.
Our regional budget indicator reads that consolidated balance and the guide explains how it is built. The channel is not new to this autumn: on 27 September we wrote about the deferral of 300 bn roubles of regional budget credits, another decision that moves a regional obligation without retiring it. This one moves an obligation the regions did not previously have at all.
Why this is about the ability to pay for the war
Protecting refineries and substations from drones is a war cost. It is being paid for, and it is not appearing in the federal deficit — because the expense never enters the budget. Instead it enters bank capital and regional debt, which is why the federal deficit will look formally better for it and measure less of the truth.
Writing about decree No. 604 in August, we said its effect on the deficit could, if anything, be to improve it, if private money replaced budget money for protection and restoration. This decision is that substitution made explicit and given a price: the state is not paying, and it has now arranged the terms on which someone else does.
The 31 December expiry and the sentence about possible inclusion in permanent regulation are worth reading together: this is a trial run, not a one-off concession. Whether it becomes permanent is a decision the same board will take, and the press release does not say when.
What this changes in our model
Today — nothing. No number our indicators read has moved. The consolidated regional budget balance stands at 31 of 100 — a rolling twelve-month balance of −1.509 trn roubles, against a pre-war anchor that was a surplus of 0.661 trn. The budget deficit stands at 65 of 100, at 3.3% of GDP on a rolling twelve-month basis. The strength index stands at 47.1 of 100, in the stress zone; the current state of all eight indicators is on the monitor.
What we do not know
The size of the limit. The central bank says the free limits for technological sovereignty and structural adaptation are sufficient for both purposes. Neither the limit nor the unused remainder is published in the release, so the claim cannot be checked against a number.
How much will be lent. No expected volume, and no estimate of the capital freed.
What counts as a protection project. The release gives no criteria for deciding that a project is one of air attack protection, and does not say who decides.
Whether a 20% floor exists. Some coverage of 29 September mentions a lower coefficient of 20%. It is not in the text of the central bank's release, and we do not confirm it.
The regulation itself. What was published is the board's decision. The amending act — the change to the instruction that carries these coefficients — was not on the central bank's site on the date of writing.