Sarytogan Graphite Project
Kazakhstan
prj-kz-sarytogan
What does the record establish?
This registered undertaking is linked below to its financial instruments, policy context and available industrial evidence.
Financial standing
2 directly linked instruments. Recorded financial states: Disbursed. A commitment, a payment and a project cost remain separate.
Inspect instruments and termsLegal and policy context
2 parent policy records; 1 project designations. Designation confers standing, not finance. Material and stage overlaps with controls do not establish a restriction on this project.
Read the policy recordsIndustrial evidence
No source-reviewed project milestone is published in this corpus. Financing records may still contain attributed activity reports; this gap does not establish inactivity.
See evidence gapsFinancial evidence and chronology
Each instrument keeps its own financial history. These dates describe financial states, not construction or production. Amounts are the current recorded terms, not historical amounts at every date below.
Equity · European Bank for Reconstruction and DevelopmentAUD 5 million (€3 million) · Disbursed · Commitment
- Provider organizations
- European Bank for Reconstruction and Development
- Recipient
- Sarytogan Graphite LimitedSarytogan Graphite Limited
- Legal authority as stated
- Not stated in this financial record
Exact status date not stated · Contracted
EBRD project 54699 is signed, but the source does not state an exact execution date.
European Bank for Reconstruction and Development· Disbursed
EBRD transaction counsel identifies completion of the two-tranche A$5M equity purchase on 10 February 2025.
Fasken (transaction counsel to EBRD)
No additional structured terms are recorded. See the full instrument for its evidence and qualifications.
This existing EBRD Sarytogan financing row is the original A$5M share purchase, not a new award. EBRD 2024 and project 54699 identify the initial A$5M (€3M approximate) commitment to Sarytogan Graphite Limited; transaction counsel dates completion to 10 February 2025. The European Commission's December 2025 summary reports around €3.6M without identifying component transactions; it remains contextual and is not a separately counted sum. A later, independently paid A$1,396,581.12 follow-on placement is coded separately as fin-ebrd-2026-sarytogan-topup-equity, not rolled into this amount. EBRD is multilateral: no tracked national government receives financing credit.
Full financial instrument, conditions and field-level evidenceEquity · European Bank for Reconstruction and DevelopmentA$1,396,581.12 in cash received from EBRD on 30 April 2026 · Disbursed · Commitment
- Provider organizations
- European Bank for Reconstruction and Development
- Recipient
- Sarytogan Graphite LimitedSarytogan Graphite Limited
- Legal authority as stated
- Not stated in this financial record
· Contracted
The 30 April 2026 ASX filing retrospectively reports an EBRD top-up placement agreed 6 November 2025 and amended 18 November 2025, conditional on regulatory and shareholder approvals.
Sarytogan Graphite Limited / ASX (announcement reproduced by Market Index)· Disbursed
Sarytogan states it received A$1,396,581.12 cash from EBRD on 30 April 2026 after conditions were fulfilled.
Sarytogan Graphite Limited / ASX (announcement reproduced by Market Index)
No additional structured terms are recorded. See the full instrument for its evidence and qualifications.
Separate EBRD follow-on share placement with Sarytogan Graphite Limited, agreed conditionally on 6 November 2025 and paid on 30 April 2026. 17,457,264 shares at A$0.08; issuer confirms exact A$1,396,581.12 cash receipt. EBRD's separate announcement describes an approximately A$1.4M stake increase to 18.4%. This amount is incremental to original A$5M, not additive to or a breakdown of the Commission's approximate €3.6M retrospective summary. Receipt of equity does not demonstrate construction or delivery at mine. This row uses existing RESourceEU policy event as a contextual cross-reference to EBRD financing; it does not mean that the December 2025 Commission narrative reported completed 2026 cash receipt. Multilateral capital is not attributed to any tracked national government.
Full financial instrument, conditions and field-level evidenceCapital stack
One layer per value role. Only committed public money, and joint-vehicle money apart from it, is summed, per currency; everything else is listed. There is no total across layers.
Public commitments
2 rows · summed per currencyCommitted to a recipient by a government or public enterprise, at the status each row states. A contracted, partially disbursed or disbursed row is binding because an agreement is executed; payment is tracked separately by status. A contracted row need not mean funds are obligated or paid, and a partially disbursed row is not fully paid. Summed per currency and per instrument, never across either; a part is never added to its package.
AUD
Equity2 rows
Binding
- Stated exactly
- 6,396,581.12
2 counted
Source-reviewed industrial observations
No source-reviewed project milestone is published for this undertaking. Any financing-row activity reports below remain attributed observations, not independently reviewed project milestones. Missing evidence does not establish inactivity.
Policy context
These records directly parent the project's finance or designation entries. Their presence does not establish a causal effect on industrial activity.
4 Jun 2025 · In force
Commission Decision recognising 13 critical raw material projects in third countries and overseas countries or territories as Strategic Projects under the Critical Raw Materials Act
European Commission
3 Dec 2025 · Active
RESourceEU Action Plan: Accelerating our critical raw materials strategy to adapt to a new reality
European Commission
Designations
Recognition under a scheme confers standing, not money, and is never counted as capital.
4 Jun 2025
Sarytogan Graphite Project
Strategic Projects under the Critical Raw Materials Act · C(2025) 3491 final
KZ · Mining
Control clauses on the same materials and stages
Clauses whose covered items share a material and a supply-chain stage with this project, with their legal status on 3 Nov 2026. An overlap of items, not a finding that the project is affected.
Record
- Sponsors
- Sarytogan Graphite LimitedCompany
- Location
- KazakhstanKZ
- Stages
- Mining
- Materials
- GraphiteTracked materials only
- Programmes
- None recorded
- Latest financing-row activity report
- No physical status recorded
What remains unknown
Gaps describe the available SMPT record. They do not establish that an activity did not occur.
- No project-native source-reviewed industrial milestone is published. Attributed activity in financing histories remains a separate evidence class; no exact milestone date or facility-wide conclusion is inferred.
- Historical amount review is incomplete. Current amounts cannot be read as a time series of earlier commitments.
- Structural links and shared materials do not demonstrate that a government measure caused an industrial outcome.
Evidence
Every project fact names the source that states it.
European Commission
- Fields supported
- Name · Location · Materials · Supply-chain stages
- Evidence level
- Explicit
- Location in document
- Entry (10)
European Commission
- Fields supported
- Sponsors
- Evidence level
- Explicit
- Location in document
- Article 2, row 10
| Source | Fields supported | Evidence level | Location |
|---|---|---|---|
| Annex to Commission Decision C(2025) 3491 final: list of Strategic Projects in third countries and overseas countries or territories European Commission · Source dossier |
| Explicit | Entry (10) |
| Commission Decision of 4.6.2025 recognising certain critical raw material projects located in third countries and in overseas countries or territories as Strategic Projects under Regulation (EU) 2024/1252 (C(2025) 3491 final) European Commission · Source dossier |
| Explicit | Article 2, row 10 |
For citations, open a parent policy record for BibTeX, RIS and CSL formats. Cite original documents for claims about government action.
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