On 17 October the Russian government signed and published Decree No. 1369, which rewrites the standard form of the refinery modernisation agreement and the rules for concluding and terminating it. The agreement is the instrument that, under article 179⁷ of the Tax Code, opens a refinery’s investment premium on the excise deduction for oil feedstock: Decree No. 82 of 30 January 2021, which the new text amends for the seventh time, was adopted expressly under that article. Two things changed in the test a refinery has to pass. The agreement now runs to 1 July 2027 instead of 1 July 2026. And the fuel that counts towards performance is no longer defined by a fixed environmental class. We read all four pages of the decree and the 2021 text it amends.
“in the second paragraph: after the words ‘the volume of production’ insert the words ‘of high-octane (research method 92 and above)’; replace the words ‘of class 5’ with the words ‘, the release into circulation and circulation of which are permitted on the territory of the Russian Federation’”. And: “b) in the first paragraph of section II replace the words ‘to 1 July 2026’ with the words ‘to 1 July 2027’”.
The words that were swapped in
Section I of the 2021 form offers a refinery two ways to satisfy its modernisation obligation, and it needs only one of them. The first is an output test: the ratio of class-5 motor petrol produced from the feedstock the investor sent for refining, to the volume of feedstock sent for refining, “shall be no less than 0.1 based on the results of each year”. The decree leaves the 0.1 — the ten per cent — exactly where it was. What it changes is which petrol counts.
The replacement wording is not new language invented for this decree. It is word for word the category that Decree No. 976 of 5 August 2026 created, which we read again today:
“1. To establish that until 1 July 2027 the following is permitted: the release into circulation and circulation on the territory of the Russian Federation of motor petrol of environmental classes K3, K4, including with a methanol content of no more than 3 per cent by volume, K2 and K5…”
We reported that decree on 1 September. It rests on presidential decree No. 509 of 24 July 2026, whose text is not on the legal portal. Its permission ends on 1 July 2027 — the same day on which the modernisation agreement, as amended yesterday, now ends.
So the performance test has been re-pointed. Until this decree, only class-5 petrol counted towards the ten per cent; from now on, any petrol that is lawfully in circulation counts, and for as long as No. 976 stands that includes classes K2, K3 and K4, methanol and all. The change is not a pure widening: the inserted phrase “high-octane (research method 92 and above)” excludes lower-octane grades that class 5 did not exclude. A refinery is now measured on RON 92 and up, at whatever quality the state currently permits to be sold.
The same substitution is made seven times — in sections I, III, IV and V of the agreement and in points 2, 5 and 7 of the rules. The words replaced are “of class 5” in four of them and “of ecological class K5” in the other three. An eighth appearance comes by restatement rather than replacement: the decree reissues annex No. 4 in full, so the title of the report a refinery files on its production plans now carries the same long phrase about circulation.
A second way in, at 100 billion roubles
The other route through section I is a property test, and it gained an alternative. The 2021 text set it at fixed assets “commissioned in the period from 1 July 2014 to 1 January 2024” with an aggregate initial cost of “no less than 60 billion roubles”. The decree shows how that clause reads today by quoting it: the window now ends on 1 January 2026, moved out by two years in an amendment we could not isolate — the two earlier decrees whose titles name Decree No. 82, No. 763 of 16 May 2023 and No. 1601 of 15 October 2025, we read in full, and neither touched this clause.
To that window the decree adds another: “or from 1 July 2014 to 31 December 2026”, with the threshold “or no less than 100 billion roubles respectively”. The same pair appears in section V and in point 9 of the rules, there spelled out as a parenthesis — “(to 31 December 2026 inclusive, if the aggregate initial cost of the fixed-asset items included in the Agreement and commissioned in the period from 1 July 2014 to 31 December 2026 inclusive is no less than 100 billion roubles)”. A refinery that will not meet the old deadline gets another twelve months of capital spending to count, provided the total it can count reaches a figure well above the original bar.
Backdated, in two steps
Decree No. 1369 takes effect on the day of publication, but two groups of its paragraphs are given retroactive force, and the groups map cleanly onto the two changes. The paragraphs that carry the 100-billion route — paragraphs five to seven of subparagraph “a” and the matching paragraphs of subparagraph “d” in point 1, and their counterparts in point 2 — apply to relations arising from 1 January 2026. The paragraphs that carry the petrol redefinition — paragraphs two to four of subparagraph “a”, subparagraphs “v”, “g” and “e” in point 1, and their counterparts in point 2 — apply from 1 June 2026.
The term extension is in neither group. Section II of the form, which carried 1 July 2026 and now carries 1 July 2027, and point 4 of the rules, where the same date is moved, take effect on 17 October 2026 and no earlier. The decree does not say how the new expiry reaches agreements already signed on the old form, or what governed them between 1 July and 17 October.
Why this is about the ability to pay for the war
The investment premium is not a budget expenditure with a line of its own. It is a deduction inside the excise on oil feedstock, which means it reduces what the budget collects from refining rather than what the budget pays out — it lives inside oil and gas revenue, and it is invisible as a cost until the revenue arrives smaller. An agreement in force is what keeps that deduction open for a given refinery; an agreement that expires closes it.
By the form’s own text the instrument was due to run out on 1 July 2026. Instead the government extended it by a year, kept the ten per cent threshold, and redefined the fuel that satisfies it as whatever is lawful to sell — a category the government itself sets, and which it lowered in August to K2. Read together, the two documents describe a state that would rather move the measuring line than let the agreements lapse, and that has put both deadlines on the same day in 2027. For the budget the effect is to hold open, for another year, an outflow inside oil and gas revenue that the 2021 text had scheduled to end.
What this changes in our model
Nothing today. Oil and gas revenue scores 10 out of 100 — it measures the level against 2021, not the rate against last year, and it stands at 0.549 of that level against a pre-war anchor of 1× and a registered zero line at 0.5×. Our own monitor read September at 452 billion roubles against 582 billion a year earlier, −22.3 per cent year on year and −17.2 per cent for the year to date. The strength index is 46 of 100, in the stress zone. No reading moved today; all eight indicators are on the monitor. What is inside the monthly oil and gas figure is set out in the guide.
What we do not know
Any sum. The decree names no money: not the volume of the investment premium, not the number of agreements in force, not which refineries hold them. The reporting that would price it is behind services unreachable from here.
The consolidated text of Decree No. 82. We verified the 60-billion threshold and the 1 January 2024 window in the 2021 original, and the move of that window to 1 January 2026 from this decree’s own quotation of the clause. The decree that moved it is one of the amendments recorded only by their Collected Legislation citations; whether the 60 billion itself survived unchanged, we could not confirm.
Whether anyone will use the 100-billion route. A twelve-month extension of the counting window paired with a threshold well above the old one is a narrow door. How many refineries can walk through it, the text does not say.
What happens on 2 July 2027. Decree No. 976’s permission and the agreement’s new term end on the same day. Whether the fuel category that now satisfies the test will still exist the day after, neither document answers.