How the Cryptocurrency Market in Russia May Evolve: Analysis of the New Legislative Proposal, 2026/04/02 17:02:24

The Government has submitted a package of bills to the State Duma concerning state control over the circulation of cryptocurrencies. There is no doubt that these documents will be approved. What changes await Russians?

The main element of the package is the upcoming law “On Digital Currency and Digital Rights.” We have already analyzed the key aspects of the document during its development stage. However, after the initiative appeared in the State Duma database and compared the final text, questions arose to which Denis Polyakov, head of the “Digital Economy” practice at GMT Legal law firm, agreed to answer for Bits.media.

Key changes for cryptocurrency exchange clients

— If the bill is adopted in its current form, what changes will occur in the operations of cryptocurrency exchanges that currently offer their services to Russians almost exclusively “in the gray”? What exactly will change for exchange clients?

— Cryptocurrency exchanges will have one year to either close down or prepare to obtain a license. If they choose the second option, they will have to suspend their activities for a certain period (from July 1, 2027, until the license is obtained), but after obtaining the license, they will be able to continue working with their existing client base.

The main change for clients: without the status of a qualified investor, they will not be able to access cryptocurrencies that have not been approved by the Bank of Russia. In addition, a limit will be set on transactions with “approved cryptocurrencies.” Currently, a limit of 300,000 rubles per year through one exchange/broker is being discussed, but the Central Bank may increase it.

Another change for clients: the verification process at exchanges will become more thorough and strict. On the other hand, requirements for information security standards regarding client data will also increase. If users of exchanges were previously worried about handing over their data to “unknown parties” — and these fears were justified — now data transfer will be carried out by an organization controlled by the Central Bank, which will bear responsibility for any violation not only reputationally, as is the case now, but also in the form of registry records, financial sanctions, and in some cases, criminal liability for officials.

Undoubtedly, more difficult times will come for those exchange clients who came with cash and received their USDT or other cryptocurrency without explaining the source of funds. Now, when dealing with cash, exchanges will also have to adhere to higher standards for verifying the source of funds.

Key changes for cryptocurrency entrepreneurs

— What will change for entrepreneurs wishing to legalize their exchanges? Can existing Russian banks become cryptocurrency exchanges? Can existing stock exchanges become cryptocurrency exchanges?

— It is assumed that the process of obtaining exchange status for “third-party entrepreneurs,” that is, those who currently do not have licenses of financial organizations or licenses of professional participants of the Central Bank market, will be available. That is, although the requirements will be formalized, they will largely be based on compliance with Federal Law No. 115-FZ “On Counteracting the Legalization (Money Laundering) of Criminal Proceeds.” There will likely be requirements for staff and authorized capital as well, but I expect that these requirements will not be overly strict at the level of Central Bank regulatory acts.

However, obtaining the status of any other subject of the regulated cryptocurrency circulation market in the Russian Federation for an “unprepared candidate” will be significantly more difficult. Stricter rules will apply here regarding staff and financial indicators of the organization, as well as requirements for the technical infrastructure of the potential licensee.

Therefore, we expect that the list of exchanges will include both existing financial organizations and new ones from among the current “gray” exchanges. Other types of activities, including digital depositories, will be available only to those who already have financial licenses.

As for cryptocurrency exchanges, the main question lies in the availability of the necessary technical infrastructure at existing Russian “classic exchanges.” With high probability, Moscow Exchange’s functionality is already ready or in the final stages of testing. Other exchanges may also follow suit.

What is a digital depository and why is it needed

— Is a digital depository an analogue of stock market depositories? In what cases will clients of exchanges, private investors, “organizers of digital currency circulation” themselves, and miners need to interact with a Digital Depository (DD)?

— A digital depository, by its nature, does resemble a depository in the stock market, but it is more correct to compare it with a cryptocurrency wallet operator.

In many foreign states where laws for the crypto business exist, the storage of cryptocurrencies is a separate regulated type of activity. Our country has simply adopted this experience.

The main difference between our digital depositories and foreign licensed wallets is the dual model of operation:

A digital depository can maintain client wallets on internal infrastructure (in this case, all client cryptocurrency is accumulated at a single address on public networks, and operations within the depository itself take place via digital accounts).

A digital depository can administer public network addresses. I would call this mechanism a quasi-custodial solution, quite unique for regulation. On the one hand, with this method of accounting for cryptocurrency, each client of the depository will have their own separate address on the blockchain where the cryptocurrency is stored — but any transfer from the wallet will require the consent of the digital depository. How this will work technically? Time will tell.

A digital depository is a key player in the Russian crypto market, as the main part of operations between regulated market subjects and clients must pass through a digital depository.

At the same time, miners can still receive mined cryptocurrency on third-party wallets and sell cryptocurrency from them, including to foreigners. There will be fewer changes for miners: they will effectively receive only a new tool for realizing cryptocurrency within the country — not only abroad, as is the case now.

Why is an identifier address needed

— Is it correct to understand that “identifier addresses” are a means of linking a specific person/organization to a specific cryptocurrency wallet? What does this mean for a specific person/organization?

— An identifier address is a public address on the blockchain. This is not a new concept; it has existed since 2024, when state regulation of mining began. A new concept is the digital account I mentioned earlier. At the same time, indeed, both the digital account and the administered identifier address are used to link a specific person and their owned cryptocurrency.

What will change for non-custodial storage of crypto

— The popular thesis among old-school crypto investors, “not your keys, not your crypto,” does not apply to “organizers of digital currency circulation” permitted in Russia? According to the bill, you will only be able to withdraw your cryptocurrency from your own address with the permission of the digital depository. At the same time, the DD itself has the right to block transactions from the address and, for example, debit funds by court order.

— Non-custodial wallets as part of the Russian cryptocurrency circulation infrastructure are not provided for by law.

However, fortunately, there are currently no bans on Russians storing cryptocurrency in non-custodial wallets. It is only more difficult to deposit cryptocurrency from such wallets into the Russian infrastructure (it will be necessary to explain where the cryptocurrency came from, whether it is truly your wallet, etc.), and direct withdrawal of funds to non-custodial wallets is prohibited. However, if a user successfully withdraws cryptocurrency to a foreign exchange, no one will subsequently prohibit them from transferring it to a non-custodial wallet.

How the use of foreign crypto services will change

— Is it true that Russian banks will be able to use foreign crypto platforms only for buying and selling cryptocurrency for importers-exporters and miners, while access for others will be closed? What should private investors or people who simply want to store a small amount of cryptocurrency or make small exchange operations — for example, for services accepting cryptocurrency payments — do now?

— It is precisely for these purposes that the Russian infrastructure is being created. Moreover, no one prohibits combining a Russian regulated organization with a foreign one and developing a comprehensive solution for the convenience of Russian users. I believe that mechanisms for such integration will actively develop in the coming year or two.

The main difference from currently operating mechanisms: previously, it was sufficient for a user to buy cryptocurrency without explaining where the money came from and why the cryptocurrency was needed, but now such explanations will have to be provided in case of suspicion regarding the legitimacy of the cryptocurrency.

— How will the interaction of Russians, primarily private investors, with foreign crypto platforms be structured now? How legal will this interaction be, and should we expect the criminalization of trading on a hypothetical Binance or the storage of bitcoins in a MetaMask wallet over time?

— Such fears are currently completely unfounded. There are no bans on the aforementioned actions. It simply becomes more difficult to establish a “starting capital.”

What is the transition period and who does it affect

— The conditional transition period of one year that the bill promises to Russian crypto services — what does it cover and what should be done during this year?

— The transition period covers two key changes:

The obligation of an organization providing digital currency circulation services to obtain a license / enter state registries.

The ability of Russians to acquire cryptocurrency only using Russian infrastructure (except for miners and participants in foreign economic activity).

But here arises an interesting point: on the one hand, the obligation to conduct transactions exclusively through Russian infrastructure will come into force on July 1, 2027, but the list of foreign exchanges/exchanges in favor of which payments cannot be made by Russian banks may be created already on July 1, 2026 (it all depends on the Central Bank).

How this contradiction will work in practice will be shown by time. Perhaps, the Central Bank will observe throughout the year which foreign exchanges it clearly dislikes, and the list itself will also come into force on July 1, 2027.

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