Annotation

The article analyzes the new legal structure introduced by Government Decree No. 178 of the Russian Federation dated February 21, 2026, which provides for the registration of agreements on the implementation of forest climate projects (FCP) in the state forest register. Based on the analysis of the current norms of the Forest Code of the Russian Federation and the practice of implementing the first Russian forest climate projects under the Kyoto Protocol (Altai and Bikin), the author substantiates the thesis that the FCP implementation agreement performs a registration and permitting function and does not replace the forest plot lease agreement. The absence in Article 25 of the Forest Code of the Russian Federation of such a type of forest use as "implementation of forest climate projects" creates legal uncertainty regarding the ownership of the obtained carbon units (CUs). The author argues that only the presence of a real right to a land plot (lease) guarantees that the "harvest" of carbon units belongs to the project initiator. The article also raises issues of continuity of carbon units obtained during the Kyoto Protocol period and suggests ways to improve legislation to stimulate the development of the CU market in Russia.