GFAs throw of shackles

Five years after the adoption of the law on digital financial assets (DFA), it seems that in 2026, the institution of digital rights and digital currencies in Russia will undergo major changes. In the last week of last year, the Bank of Russia issued a statement that the regulator had prepared a Concept for the regulation of cryptocurrencies on the Russian market. The text of the Concept itself is not publicly available, but there is a description of the document on the Central Bank of Russia's website.

The document mainly focuses on regulating crypto exchanges in Russia. This issue has been awaiting resolution since discussions about the crypto asset market began in 2017. In particular, it is assumed that cryptocurrency trading will be carried out through the existing infrastructure—brokers and exchanges. The document does not say whether other market participants that do not have a broker or exchange license will be able to provide services after obtaining a different special license. It should be noted that most of the world's largest crypto exchanges today were created by new companies in the market, rather than existing financial organizations. Restricting new companies could lead to a decline in innovation and reduce the ability of Russian crypto exchanges to enter international markets. The document also proposes limiting the

went up the number of DFAs placements over first 9 months

2025 and hit Rb 972 bn purchase of cryptocurrencies by unqualified investors to Rb300,000 per year on a single platform. However, given that users from the Russian Federation can purchase cryptocurrencies for other amounts on other foreign platforms, the ban will not reduce the investment risks of citizens but may limit the inflow of funds to Russian crypto exchanges.

As for DFAs, as well as utility and hybrid digital rights, the Bank of Russia has prepared a “quiet revolution” for them: their circulation will be permitted in open networks. What does this mean for companies and investors? It means, for example, that a Russian company can issue a DFA bond not on Russian platforms—the organizers of the issue and exchange, where the buyers are exclusively Russian users—but, in particular, on the Ethereum network. In the future, such DFA may be available for purchase on the largest crypto exchanges, as well as in DeFi protocols. Basically, after the sanctions were put in place, Russian companies will once again have access to international liquidity traded in cryptocurrencies, which means they'll be able to raise funds on more favorable terms than they could domestically. This innovation raises the question: will Russian companies be able to accept payment for DFA, for example, in Bitcoin, and pay coupon income in cryptocurrency?

The development of DFA regulation and the emergence of new legal constructs involving digital rights will be a trend in H2 2025.

In December, a law was signed that introduced regulation for debt DFA (essentially bonds). In the same month, another bill was proposed that would allow investment funds to buy DFA on the same terms as ordinary shares or bonds. Previously, funds were virtually unable to do so because there was no convenient system for accounting for such assets.

And in the same month, another step was taken to develop the DFA market: a bill was submitted to the State Duma allowing real estate to be used as collateral for obligations issued in the form of DFA. Simply put, if a debt is issued in the form of DFA, it can be collateralized with real estate (e.g., an apartment, house, or land plot). The bill also establishes the procedure for registering such collateral with Rosreestr: it will be specified which real estate secures a particular issue of DFA, and its owners will be recognized as collateral recipients. To this end, the following rules are introduced:

▪ Each DFA issue will be assigned a unique number.

▪ This number will be indicated when registering collateral with Rosreestr.

▪ Such DFA can only be bought and sold after the collateral has been officially registered in the form of real estate.

From the monitoring issue No. 12 (24), December 2025. Download the full issue (PDF) · issue page at the Gaidar Institute