Current status of Gazprom dividends over the first half of 2022

Gazprom paid a record dividend of 51.03 Rubles per ordinary share over the first 6 months of 2022.

These dividends were not paid on ADRs due to the legal restriction of Clause 2 of Part 5 of Article 6 of the Federal Law of April 16, 2022 No. 114-FZ "On Amendments to the Federal Law "On Joint-Stock Companies" and Certain Legislative Acts of the Russian Federation" that was present back in 2022. Gazprom recently confirmed in their annual report over 2025 (for English version: https://drive.google.com/file/d/1LG8DMtSqVtdqNPoryoDAfJfR-hbKr3i1/view?usp=drivesdk) that over 100 billion Rubles (over a billion Euros) of unpaid dividends were restored as retained earnings because the statutory period to claim these dividends expired. This amount is largely due to the past restriction on the payment on ADRs. 

Dividends on converted ADRs

In 2025 Gazprom paid approximately 11 billion Rubles in unpaid dividends.

Magenta legal has reported that BNY (as the depositary bank for the ADRs) received the dividends for Gazprom ordinary shares underlying ADRs that were converted after the dividend registration date: https://t.me/ADR_conversion/98

We tried to look for confirmation of this in the annual report of Gazprom. Unfortunately this is not explicitly stated, but the reported payment of 11 billion Rubles in unpaid dividends in 2025 could be an indication of this payment. 

Such a payment would hopefully result in a later distribution of dividends by BNY. It remains to be seen if BNY will limit the payment to ADR holders that converted their Gazprom ADRs before the statutory period expired or whether they will distribute such payment over all holders (including these with unconverted ADRs for which no dividends were received).

Since the decision of the Central Bank of Russia was changed in 2024 to instruct for the payment of dividends to the type C account of foreign nominee holders, it is very interesting that Gazprom may have applied this change in framework retrospectively for the dividends over the first months of 2022. Apparently in an attempt to pay as much unpaid dividends as possible. Hopefully this will result in other issuers (such as Sberbank) taking similar approaches.