How much does ESG cost business, and what will inaction cost?
Do spending on the environment, people and governance pay off? Analysts at the ESGQ rating agency have added up both bills — the cost of ESG and the cost of inaction — using Kazakhstan's figures. A report costs a company anywhere from a few thousand euros a year to a million or more. Refusing to modernize now also has a price, and it is written into law: by 2031 the largest polluters without an environmental permit will pay 12 times more for their emissions than they do today.
Two bills for one decision
Taking care of the environment, people and the quality of governance costs money. Reporting on it costs a medium-sized company several thousand euros a year, and a large one hundreds of thousands or more. But abandoning ESG now has a price too. ESGQ calls it the second bill: it arrives later, and the amount on it is usually larger.
The clearest example is emission charges. Under the new Tax Code, a Category I enterprise that has obtained an integrated environmental permit pays nothing for emissions within the standards. Without a permit the charge rises every year, and for the 50 largest polluters it will grow 12-fold by 2031. For now the amounts are small — in 2024 all 190 subsoil users in the EITI report paid 47 billion tenge for emissions, — and many postpone modernization. But, as ESGQ analysts note, each further delay costs more than the last.
The second bill comes from Europe. Since 2026, importers of steel, aluminum, ferroalloys and fertilizers into the EU have been buying CBAM certificates — one per tonne of CO₂; in the second quarter a certificate cost about 75 euros. If a producer cannot verify its emissions, the EU calculates them using inflated values. According to an estimate cited by the EU Delegation, this costs Kazakhstan exporters more than 100 million euros a year.
The third bill is accidents and fines. The oil spill in the Gulf of Mexico cost BP 67 billion dollars, and the Brumadinho dam collapse cost Vale 37.7 billion reais. And in Kazakhstan the fine per tonne of missing carbon allowance is 43 times the price of the allowance itself.
Does modernization pay off? ESGQ analysts calculated a hypothetical example: a metallurgical plant on the list of 50 replaces its equipment for 100 billion tenge. Over ten years, in today's money, it spends 63 billion on equipment and saves 109 billion on emission charges — ending up about 69 billion tenge ahead. For a plant outside the list with expensive equipment, modernization does not pay off within ten years: the law raises its charges more slowly.
Which threats are the most dangerous, and who can send the bill? Scheduled risks — rising charges, CBAM, mandatory new technologies, allowance shortages — cannot be avoided, but companies can prepare for them in advance and more cheaply. Rare disasters — accidents and tailings dam failures — cost the most, and here ESG works as insurance. According to ESGQ, the strongest levers are held by the environmental regulator, the financial regulator and the stock exchange, lenders and buyers in Europe.
With a subscription — the full version of the publication: six quotable figures, the statutory fork in charges with the composition of the list of 50, the plant model with a breakdown and three cases, the model's assumptions, the risk map and the 5×5 stakeholder matrix, and a review of research on the link between ESG and financial performance.
How to cite
According to calculations by ESGQ Rating Agency, “ESG economics” model, September 2026.
- The plant, the bank and the medium-sized company in the calculation are made up for the example. Do not label the figures with the names of real companies.
- The statutory amounts (×12, ×6, zero charge with a permit) are provisions of the Tax Code and can be cited with a reference to the article.
- The estimate of “more than 100 million € a year” for CBAM is cited by the EU Delegation with reference to the International Trade Centre and QazTrade; cite them as the source.
- The material is an ESGQ expert opinion, not a credit rating or an investment recommendation.
Terms
- ESG
- Environment, people and governance: how a company affects nature and society and how honestly it is run.
- Category I facility
- An enterprise with a significant environmental impact under the Environmental Code. The list of 50 includes those of them with the largest emissions as of January 1, 2021.
- IEP
- Integrated environmental permit. An enterprise receives it after switching to best available techniques. With it, the charge for emissions within the standards is zero.
- BAT
- Best available techniques: the level of equipment the law requires of large polluters.
- MCI
- Monthly calculation index, the unit for payments and fines. In 2026 it is 4 325 tenge.
- CBAM
- A carbon charge at the EU border. The importer buys one certificate for each tonne of CO₂ emitted in producing the goods.
- Default values
- Emissions per tonne of goods that the EU assigns to a country when a producer has no verified data.
- ETS and allowance
- Kazakhstan's emissions trading system. An enterprise receives an allowance for tonnes of CO₂ and pays a fine for any shortfall.
- Today's money (NPV)
- Future costs and income converted to today: a tenge in five years is worth less than a tenge today.
Sources
- European Commission. Commission Staff Working Document SWD(2026) 500, pp. 14, 21. ec.europa.eu
- Tax Code of the Republic of Kazakhstan No. 214-VIII of July 18, 2025, Art. 639(2)–(3), Art. 640(2)–(5). adilet.zan.kz
- Law of the Republic of Kazakhstan No. 239-VIII “On the Republican Budget for 2026–2028”, Art. 7. adilet.zan.kz
- European Commission. Price of CBAM certificates. taxation-customs.ec.europa.eu
- Commission Implementing Regulation (EU) 2025/2621 of December 16, 2025, Annex I. eur-lex.europa.eu
- Commission Implementing Regulation (EU) 2026/1740 of July 20, 2026 correcting Annex I to Implementing Regulation (EU) 2025/2621. eur-lex.europa.eu
- Directive (EU) 2023/959 of May 10, 2023, recital 46. eur-lex.europa.eu
- Delegation of the European Union to Kazakhstan. Assessing CBAM readiness in Kazakhstan, June 9, 2026. eeas.europa.eu
- ICAP. Kazakhstan Emissions Trading System, October 2025 update. icapcarbonaction.com
- BP p.l.c. Annual Report and Form 20-F 2018, note 2, p. 151. sec.gov
- Vale S.A. Form 6-K, February 4, 2021, p. 1. sec.gov
- Kazakhstan EITI, national report for 2023–2024, Annex 3 (emission charges, budget classification code 105316); the total by company is an ESGQ calculation. eiti.org
- Resolution of the Government of the Republic of Kazakhstan No. 187 of April 1, 2022, as amended by Resolution No. 1131 of December 27, 2024. adilet.zan.kz
- ESGQ. “Cost of ESG versus cost of inaction” model, September 2026, recalculated on September 28, 2026. Three cases (unfavorable, typical, favorable), calculation based on assumptions.
- Friede G., Busch T., Bassen A. ESG and financial performance: aggregated evidence from more than 2000 empirical studies. Journal of Sustainable Finance & Investment, 2015, 5(4), 210–233. doi.org
- Whelan T., Atz U., Van Holt T., Clark C. ESG and Financial Performance: Uncovering the Relationship by Aggregating Evidence from 1,000 Plus Studies Published between 2015–2020. NYU Stern Center for Sustainable Business, Rockefeller Asset Management, 2021. stern.nyu.edu
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