Rules for Purchasing Digital Financial Assets — Bank of Russia 2026

Starting January 1, 2026, new regulations for the digital financial assets (DFA) market will come into force in Russia, affecting unqualified investors, issuers, and platform operators. The key changes are aimed at protecting retail investors and increasing sector transparency.

What you need to know:

• For unqualified investors, a revolving annual limit on DFA purchases of 600,000 rubles is being introduced.
• Access to instruments will be restricted: unqualified investors will only be able to purchase low-risk DFAs, such as those with full capital protection or those linked to public indicators.
• Control is being tightened through the mandatory integration of operators with the Bank of Russia's "Know Your Customer" (KYC) platform to combat money laundering (AML/CFT).
• What to do now: Investors should assess their status and study the new restrictions; issuers and operators should prepare for new compliance requirements and technical integration.

Legal Basis and Implementation Schedule

The new rules are based on data analysis collected by the Bank of Russia in 2024, including information from reporting form 0420723 "Information on transactions with digital financial assets".

Regulatory Framework:

• Federal Law No. 259-FZ dated July 31, 2020, "On Digital Financial Assets..." — the primary law defining the legal status of DFAs.
• Federal Law No. 115-FZ dated August 7, 2001, "On Countering the Legalization (Laundering) of Proceeds..." — the basis for AML/CFT procedures.
• Bank of Russia Ordinance No. 3629-U dated April 29, 2015 — establishes the criteria for recognizing a person as a qualified investor.
• Bank of Russia Draft Bylaws. In 2025, the regulator is expected to present draft documents for public discussion specifying the DFA risk assessment methodology, the list of available instruments, and the limit restoration mechanism. You can track their publication in the "Discussion of Draft Regulations" section on the CBR website.

Estimated Implementation Schedule for New Rules

Period	Stage	Content
2024–2025	Preparatory	Development and public discussion of draft regulations.
Q1–Q2 2026	KYC Integration	Gradual connection of operators to the "Know Your Customer" platform.
Q2–Q4 2026	Implementation of Restrictions	Entry into force of requirements for instruments available to unqualified investors.
From 2027	Full Transition	Final transition to the updated regulatory model.

Restrictions for Unqualified Investors

1. Revolving Limit of 600,000 Rubles

The DFA purchase limit is restored by the amount of the initial investment after the sale or redemption of the asset.

• Moment of Restoration: The operator is obliged to restore the limit no later than the next business day after the actual credit of funds to the investor.
• Partial Sale: When selling part of a DFA issue, the limit is restored proportionally — by the amount of the initial purchase of the sold part.
• Profit/Loss: The restoration amount equals the initial investment amount, regardless of the transaction's financial outcome.

Examples of how the limit works:

1. Purchase-Sale: An investor bought DFAs for 400,000 ₽ (remaining limit — 200,000 ₽). A month later, they sold these DFAs. After the money was credited to the account, their limit was restored by 400,000 ₽ and is again 600,000 ₽.
2. Partial Sale: An investor bought DFAs for 500,000 ₽ (remaining limit — 100,000 ₽). Later, they sold half of these assets, which originally cost 250,000 ₽. The limit will be restored by 250,000 ₽ and will amount to 350,000 ₽ (100,000 + 250,000).

2. Available and Unavailable Instruments

Unqualified investors will only have access to low-risk DFAs. Although exact criteria will be defined in Bank of Russia bylaws, the main requirements are already known.

Available Instruments:

• DFAs with full capital protection. These are assets with an obligation from the issuer or their guarantor to return 100% of the invested funds.
• Guarantee mechanisms: irrevocable bank guarantee, a suretyship agreement with a company having a high credit rating, or a pledge of highly liquid property.
• How to check guarantee reliability: ensure that the term, amount, and currency of the guarantee match the DFA terms; check the credit rating of the guarantor (bank or surety) on the websites of accredited agencies (ACRA, Expert RA); review their financial statements.
• DFAs linked to public indicators. The yield of such assets depends on transparent indicators: the Bank of Russia key rate, the official consumer price index (Rosstat), or exchange-traded commodity prices (gold, oil).
• Debt DFAs from reliable issuers. Digital equivalents of bonds from companies with a credit rating no lower than the level established by the Bank of Russia (expected benchmark — no lower than ruA- on the national scale).

Unavailable Instruments (provisional list):

• DFAs certifying rights to shares of foreign companies or units of foreign funds.
• Structural products with complex, non-transparent income payout conditions (e.g., linked to cryptocurrency rates).
• DFAs from issuers without a credit rating or with a rating below the level established by the Bank of Russia.

Qualified Investor Status: How to Remove Restrictions

Obtaining qualified investor status removes the 600,000 ₽ limit and opens access to all types of DFAs. To achieve this, one must meet one of the criteria according to Ordinance No. 3629-U:

• Assets: Owning financial assets worth at least 6 million ₽.
• Work Experience: At least 2 years in an organization with qualified investor status, or at least 3 years in another organization that worked with securities.
• Transaction Volume: Conducting securities transactions worth at least 6 million ₽ over the last 4 quarters (at least 10 transactions per year and 1 per quarter).
• Education or Qualification: Higher economic education from a specialized university, a financial market specialist certificate, or CFA, CIIA, or FRM certificates.

An application is submitted to the information system operator along with supporting documents.

Strengthening Control: KYC Platform and AML/CFT

The DFA market is being integrated into the Bank of Russia's "Know Your Customer" (KYC) platform. Each participant is assigned a risk level based on an analysis of their operations.

Risk Levels and Their Consequences:

• "Green" (low risk): Operations are conducted without restrictions.
• "Yellow" (medium risk): The operator has the right to request documents confirming the economic sense of the transaction.
• "Red" (high risk): Operations are blocked.

Procedure for Appealing a Block ("red" level):

1. Contact the Operator: The investor provides documents explaining the operation. The operator is obliged to consider them within 7 business days.
2. Appeal to the Interagency Commission at the Bank of Russia: In case of refusal, a complaint can be filed via the Bank of Russia online reception.

Consequences for Platform Operators

The new rules impose additional obligations on Information System Operators (ISOs):

• Technical Integration with KYC. Operators will need to configure their systems for data exchange with the regulator via secure APIs. Detailed technical documentation is expected in 2025.
• Monitoring and Reporting. It is necessary to ensure compliance with restrictions for unqualified investors and submit reports in a timely manner.
• Liability. For violation of KYC/AML/CFT procedures and allowing unqualified investors access to prohibited instruments, operators face sanctions. Liability is regulated by the Code of Administrative Offenses of the Russian Federation (e.g., Art. 15.27 for violation of AML/CFT legislation) and Law No. 259-FZ. Possible measures: fines up to 1 million ₽, injunctions, suspension of activities, or license revocation.

Market Impact and Conclusions

The implementation of new rules will make the DFA market more mature and secure, which aligns with the global trend of crypto-asset regulation (similar to the MiCA approach in the EU). In the short term, this may lead to a decrease in liquidity for high-risk DFAs and an increase in operational costs for operators. However, in the long term, increased transparency and investor protection will strengthen trust in the market and attract institutional capital.

Practical Cases and Recommendations

Case: An unqualified investor sold a DFA, the money was credited to the account, but the operator did not restore the limit within the established timeframe (1 business day).

Recommendations:

1. Send an official request to the operator. Use the following template:

   Subject: Restoration of annual limit for DFA transactions

   Dear [Operator Name], on [Date] I sold DFA [Asset ID], the initial purchase amount was [Amount] ₽. The funds were credited to my account on [Date]. I request that you restore my annual limit in accordance with the legislation.

2. Document the request. Save the ticket number and screenshots of the correspondence. If the operator does not resolve the issue within 5 business days, proceed to the next step.

3. File a complaint with the Central Bank. Contact the Bank of Russia online reception, attaching the correspondence with the operator.

Checklists for Market Participants

For Private Investors

• Determine your status. Check if you meet the criteria for a qualified investor. If so, apply to the operator to remove restrictions.
• Verify the issuer and guarantees. Before buying a DFA, study the credit rating of the issuer and guarantor, and request the text of the suretyship agreement or bank guarantee from the operator.
• Plan transactions with the limit in mind. Remember that the 600,000 ₽ limit is only restored after the sale or redemption of an asset.
• Keep documents. Have contracts and statements ready that may be required to confirm the economic sense of transactions upon request by the KYC system.

For Corporate Clients

• Update Internal Control Rules (ICR). Align procedures with the new requirements for DFA operations.
• Verify counterparties. Use AML services to analyze the origin of digital assets and assess counterparty risks before a transaction.
• Prepare transaction justifications. Proactively form a package of documents (contracts, invoices, certificates of completion) confirming the economic sense of large or unusual DFA transactions.