A comprehensive bill “On Digital Currency and Digital Rights” is being readied for submission to Russia’s State Duma. Among other things, it sets out licensing for crypto-market participants, investment caps for non‑qualified investors and de‑anonymisation procedures.
ForkLog spoke with lawyers and market participants about the contentious aspects of the coming regime. This article explains why bitcoin-wallet keys may have to be shared with a digital depository and how the state plans to monitor every crypto transaction inside the country.
What the bill contains
The text is still undergoing final inter‑agency clearance and has not yet been published.
Current discussions rely on official remarks and media leaks. It is also known to be based on the Central Bank’s concept unveiled in December 2025, which again stressed the high risks of cryptocurrencies and the danger of total loss of funds.
The bill proposes to recognise digital currencies as currency values. They could be bought and sold, but not used for payments within Russia.
Investor categories and caps
Different classes of investors would have to pass risk‑awareness tests, but would be admitted to trading on distinct terms.
Non‑qualified investors would be able to buy the most liquid cryptocurrencies up to 300,000 roubles a year through a single intermediary. The cap is indicative and remains under discussion.
Qualified investors would be allowed to buy any cryptocurrencies, except anonymous ones, without volume limits.
Licensing and infrastructure
Only licensed entities with Russian legal status—crypto exchanges, brokers and fiduciary managers—would be permitted to operate with cryptocurrency inside the country.
Separate requirements are planned for exchangers included in the Bank of Russia’s register and for specialised digital depositories. The latter would maintain records of rights to cryptoassets and register wallets.
Digital depositories would also face restrictions on the free disposition of coins. For example, they could not be lent to another user. The bill disclaims liability for client funds where a token’s issuer blocks assets, or where blockchains that do not operate in compliance with Russian law malfunction.
Rules for exchange operators would depend on turnover. If monthly turnover equals or exceeds 3.5m roubles, an exchanger may work with users directly. Below that threshold, the service must serve clients exclusively via licensed intermediaries—an exchange or a broker. External‑trade contracts do not count towards the cap.
The bill obliges crypto exchangers to compensate clients for losses from fraudulent operations, aligning them with traditional financial institutions in terms of liability.
The circulation of DFAs and other Russian digital rights would be permitted on public blockchains. Previously they were available only in closed banking systems.
De‑anonymisation and oversight
All legal platforms would be required to implement KYC/AML procedures. This would allow the regulator to track transaction chains in real time and identify links to suspicious addresses. The law does not mandate any single compliance tool (for example, “Transparent Blockchain”).
Information about users and their transactions would have to be provided to the FTS and law‑enforcement agencies both upon official request and automatically when risk filters are triggered.
The circulation of anonymous cryptocurrencies such as Monero or Zcash would be prohibited.
The Central Bank’s concept noted that residents could acquire cryptocurrencies abroad via foreign accounts, and that assets could be transferred overseas through Russian intermediaries, with tax authorities notified of such operations. However, these provisions have not made it into the bill’s current draft.
What would this change?
Under current rules, cryptocurrencies are recognised as property in Russia; the bill would add their definition as currency values for foreign‑trade purposes.
Russians would still be allowed to hold cryptocurrencies and mine them under the new rules. Businesses and sole proprietors could use them in experimental legal regimes for international trade.
The mechanisms for legal circulation and trading laid out in the bill amount to a full‑fledged yet ring‑fenced domestic market. The state intends to take control of every transaction, effectively blocking infrastructure for P2P deals inside the country.
The activities of any intermediary platforms without a Russian licence would be deemed illegal. For ordinary users this means they could not lawfully cash out into fiat via P2P services without risking bank‑account blocks.
One of the most contentious clauses states that assets outside identifier addresses would not be subject to judicial protection in Russia.
Yet under a ruling by the Constitutional Court on January 20th 2026, cryptocurrency is property regardless of where it is held and is subject to judicial protection even if it has not been declared.
In practice, however, protecting “grey” assets remains arduous: an owner must prove not only control over an address but also the lawful origin of funds. Declaring crypto income remains the main tool that simplifies this process and forestalls questions from banks when attempting to regularise assets.
Legal view
Andrey Tugarin, founder of GMT Legal, told ForkLog that the article precluding undeclared digital currency from being the subject of a court dispute has already been found unconstitutional and will not remain in the bill’s final text.
“The provision migrated into the new bill by copy‑paste. This suggests the drafters simply paid insufficient attention to this particular part, and nothing more. There is no talk in the new bill of stripping legal protection from cryptocurrency on custodial or non‑custodial wallets,” he explained.
Complicating transactions
In the lawyer’s view, the most contentious point concerns digital depositories administering crypto wallets. The bill proposes a quasi‑custodial model: half of the access keys to a wallet would be held by the depository and the other half by the owner. Thus any transaction would require both signatures.
“This approach breaks familiar market mechanics and makes the free disposal of one’s own cryptocurrency much more difficult. Because the mechanism is so inconvenient, the fiercest battles are now around the proposed storage methods,” the expert noted.
Breaching caps
There are no penalties for non‑qualified investors who exceed caps. According to Tugarin, only licensed Russian intermediaries that process transactions must track purchase volumes. Platforms must keep records, so technically a non‑qualified investor simply will not be able to buy more than 300,000 roubles’ worth of cryptocurrency a year.
“The buyer should not be liable for exceeding the cap, so no new sanctions under the Code of Administrative Offences or, still less, the Criminal Code are planned. Operations above the cap will be blocked automatically at the intermediary level. The only scenario where an investor may face questions is if he deceives a licensed platform into executing a trade above the set amount,” the lawyer added.
Tax
The bill does not impose strict tax requirements on operations in foreign jurisdictions. However, any licensed intermediary in Russia will inevitably take on the function of automatically exchanging data with the FTS.
“Submitting reports to government bodies—on a scheduled basis or upon direct request—will be arranged absolutely seamlessly, sparing the user from having to declare every transaction manually,” the lawyer explained.
Tax liabilities for Russians may arise even without cashing out to fiat. A likely scenario is that profitable crypto‑to‑crypto trades executed solely on a Russian exchange would be treated as taxable income.
According to Tugarin, a similar approach is currently applied to miners. They record initial income at the moment a coin is mined, net of operating costs, and upon subsequent sale of an appreciated asset they also pay tax on the exchange‑rate gain.
“The regulator can apply an analogous approach to ordinary investors. If a trader actively trades digital assets without converting into roubles and at year‑end the portfolio shows a net profit relative to initial investment, that delta will have to be reflected in tax filings. Once comprehensive market regulation is fully launched, this form of fiscal control looks the most realistic,” he concluded.
Liquidity
Russian crypto platforms will have to source liquidity on their own. A legal solution, in Tugarin’s view, would be to bring in licensed exchangers as market makers:
“The scheme can work by creating unified cross‑border structures. For example, a company with a valid foreign licence opens a legal branch inside Russia and pumps liquidity from the foreign perimeter into the local one.”
The lawyer stressed that the inability to work directly with most global venues due to sanctions does not mean an inevitable drift into the grey zone—legal linkages do exist.
“Moreover, the market expects gradual easing of restrictions, which over time will only broaden options for sourcing liquidity. That is precisely the scenario being bet on—and it is quite realistic,” he said.
What does the market think?
Among the challenges is the potential imposition of digital depositories as custodians. That would isolate non‑custodial wallets and force Russian exchanges to auto‑flag any transactions involving them as high‑risk.
Even so, BitOK CEO Dmitry Machikhin considers such fears premature and doubts the regulator will go that far. In his view, how assets are stored should remain the user’s choice; otherwise the state risks the opposite effect.
“If crypto users are tightly constrained, there is a risk they will abandon legal infrastructure altogether in favour of workarounds,” the expert warned.
Fears of isolation from global compliance systems are also overdone, according to the BitOK chief. For full‑fledged AML checks, existing localised tools from specialist analytics firms—analogous to his company’s own service—are already sufficient.
The mooted 300,000‑rouble cap for non‑qualified investors remains a hot topic. Given high costs for compliance, data storage and reporting, it would weigh on the profitability of retail exchange businesses.
Commenting on the point, Exved CEO Sergey Mendeleev urged against drawing conclusions before the final text is published. In the working versions he has seen, that hard threshold has already been removed.
“Of course, the cap is insane and would simply destroy the legal market. I don’t even see any point in discussing it seriously,” the expert says flatly.
For crypto‑exchange aggregators such as BestChange, a key risk is potential Roskomnadzor blocks for advertising illegal services. Platforms must decide whether to hide shadow services from Russian users and how to retain audiences amid tight P2P restrictions.
BestChange analyst Nikita Zuborev confirmed readiness to act within the law and, if necessary, to restrict results for Russian IP addresses. The company has done this before—its aggregator previously applied such measures to resolve extrajudicial claims from the Central Bank. A total ban, however, is technically hard to implement.
“Neither we nor the regulators can reliably determine a user’s location if he connects via protected networks or foreign corporate gateways,” the expert notes.
The scale of market disruption will depend directly on how the law is implemented, Zuborev believes. If most existing exchangers are allowed to operate as legal agents, the business structure will not change much—platforms will simply switch brokers for holding liquidity.
The aggregator plans to retain its Russian audience with a built‑in crypto‑risk assessment tool and the growth of its own education portal.
What about elsewhere?
Unlike the ring‑fenced domestic market forming in Russia, other jurisdictions are integrating digital assets into the broader financial system and creating incentives for the industry.
European Union
The EU chose systematic standardisation with the MiCA regulation. It set unified rules for service providers, allowing a licence in one country to passport across all 27 member states.
Regulators do not cap purchases by citizens, and non‑custodial wallets have legal status, though transactions involving them are subject to AML monitoring.
United States
American authorities opted for access. In particular, the launch of crypto ETFs helped integrate digital assets into traditional finance.
The GENIUS Act, passed in summer 2025, legalised stablecoins as a means of payment, while the pending Clarity Act in the Senate aims to set unified rules for exchanges.
These measures are designed not to restrict citizens’ trading but to create a secure legal environment for capital.
UAE
The Emirates’ strategy aims to build global infrastructure for international crypto firms.
The country levies no personal income tax on residents’ individual investments in digital assets. Licensed operators, like other legal entities, pay a 9% corporate tax if annual income exceeds 1m dirhams (about $270,000).
Since November 2024 any token transactions have been fully exempt from VAT.
The jurisdiction also offers tax residency to owners of crypto companies, making it one of the most attractive in the world for large capital and professional market participants.
Conclusion
The State Duma plans to prepare the core legislative framework by July 1st 2026, after which the Bank of Russia will issue clarifying regulations. According to the Central Bank and Finance Ministry’s roadmap, the transition period will last exactly one year.
The next step, in 2027, is expected to introduce administrative and criminal liability for unlicensed intermediaries on the crypto market, mirroring the banking sector.
Regulation will finally turn cryptocurrencies from a tool of free exchange into a transparent investment asset comparable to shares or bonds.
A likely direction is the creation of “whitelists” of crypto addresses and legal gateways for external settlements.
Ordinary users will have to choose between working with licensed brokers under state protection and moving into the grey zone. Using P2P and non‑custodial wallets may bypass caps, but will make it harder to recover assets in the event of theft or blocking.