For years, concerns have been raised about the Almaty International Airport Extension Project which is being financed by the European Bank for Reconstruction and Development (EBRD). Locals question the inadequate protection of cultural heritage and a lack of public participation and access to information. To address this, a formal complaint was recently filed with the Independent Project Accountability Mechanism (IPAM), and the outcome of a compliance review is pending.
Polina Veretelnikova, Central Asia Coordinator | 8 December 2025
Demolished historical building of the VIP Terminal vs. newly constructed international terminal. (photo: Green Salvation)
The EBRD’s Almaty Airport Expansion Project, funded with the participation of the International Finance Corporation (IFC), was signed in 2021 in order to build a new international passenger terminal to address growing traffic needs. Local activists have for years raised concerns about the project’s harm to cultural heritage – the historical 1947 VIP Terminal building. The building had the status of protected cultural and historical heritage of local significance and was slated to be relocated in the project description. According to the complaint filed by the environmental organisation Green Salvation, the USD 55 million project has caused irreparable damage to the historical and cultural heritage: instead of relocation, the historical building was demolished in November 2022. This was done despite a resolution from the Almaty City Hall requiring the relocation of the building, since the demolition of protected cultural and historical heritage in Kazakhstan is prohibited by law. The company also ignored public concerns raised at the original public hearings.
The complaint alleges there has been frivolous interpretation of national law and an application of arguments based on international conservation charters and IFC performance standards rather than national legislation to justify decisions regarding this project. The commissioned cultural heritage study for the EBRD project was not based on national legislation but rather independent analysis and international documents. In fact, some of the arguments and terminology on which the study based its evaluation did not apply to Kazakhstan’s laws at all. For example, the study refers to ‘replicable cultural heritage’ in order to justify only partial preservation of the VIP terminal building, but ‘replicability’ or any related concept or term is nowhere present in Kazakhstan’s national legislation on protected cultural heritage.
The airport company claimed that the local government supported the idea of preserving only key structural elements of the building. The Almaty City Hall resolution, dated 11 November 2020, ordered to ensure integrity and safety of the cultural monument during the process of relocation. Nevertheless, despite clear inconsistencies and public criticism, the historical building was demolished in November 2022.
Consequently, Almaty environmentalists have sent requests to the EBRD and the Almaty International Airport, organised advocacy meetings and engaged in litigation at the municipal level in order to clarify the legality of the demolition of the historical building. In the end, Green Salvation was unable to identify any valid documents related to the relocation process. This lack of any evidence of relocation monitoring reports indicates a failure to properly preserve the building or its original elements.
Seeking accountability, environmentalists submitted a formal complaint to the EBRD’s IPAM and requested a full compliance review and thorough investigation of this case. Green Salvation alleges there has been a violation of the EBRD’s Environmental and Social Policy in relation to compliance with the national law, potential environmental harm and destruction of cultural heritage, as well as failure to ensure access to information and meaningful public participation. The organisation hopes that a fair investigation will prove wrongdoing, ensure accountability and provide fair remedy. The monitors are also advocating for strengthening of the bank’s policies in relation to heritage protection, responsible risk and impact assessment procedures, meaningful engagement with the public, as well as upholding commitments to national laws.
In September 2025, an additional USD 60 million loan to the Almaty Airport Expansion Project was proposed and is pending approval by the end of the year. Formally aimed at improving the original project, the additional funding came as an unpleasant surprise to the monitoring organisations, which have been flagging the above-mentioned violations as well as risks connected to the airport company’s failure to establish a sanitary protection zone (SPZ) around the active airport. Despite their steady engagement with the bank and the airport company, the local monitors were not informed about or invited to the public hearings related to the proposed extension project. The EBRD originally stated it would step out of the project unless specific conditions, including establishment of the SPZ, were ensured. In this situation it remains unclear why the bank refused to adhere to this condition and instead proposed further funding.
The EBRD should carefully consider all implications of this project and the alleged violations by their client under the ongoing compliance review before making a decision on extended funding and further participation.
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