The Bank of Russia has expanded its official clarifications on how the legal digital currency market should function. The new set of answers in the "Clarifications" subsection of the "Launch of the Cryptocurrency Market" section covers qualified investors, testing, settlements in crypto exchanges, the operation of digital depositories, accounting of digital currency, and requirements for company management. Most provisions rely on Law No. 282-FZ on digital currencies and the regulator's normative acts.
Investors and Testing
An investor already recognized as qualified does not need to obtain the status again for transactions with digital currencies. Since October 1, 2021, paragraph 9 of Article 51.2 of the securities market law (No. 39-FZ) allows a person to be recognized as a qualified investor in respect of transactions intended for this category. If a person received the status "in respect of all types of transactions intended for qualified investors" before September 1, 2026, they are considered qualified for digital currency operations as well — provided that the status extends to all types of such transactions.
A company combining several types of activity (for example, a broker and a crypto exchange) may conduct testing once. The result is taken into account regardless of the status in which the company conducted the check — broker, manager, digital depository, or digital currency exchange organization.
Testing is not required to transfer cryptocurrency from one's own wallet to one's own account in a digital depository: acquisition implies a change in the holder of the coins, whereas upon crediting the owner does not change.
Crypto Exchanges and Depositories
An exchange cannot defer settlements on a transaction until the end of the operating day — obligations are fulfilled simultaneously or in the order of immediate counter-performance, on the "delivery versus payment" principle. The depository independently determines the list of documents to verify that a foreign wallet is administered by an organization entitled to do so under its national law. The absence of a Central Bank normative act on digital analysis does not prevent the depository from operating, but transactions must be checked according to its own rules and submitted to the Bank of Russia within five business days after adoption.
Accounting and Admission
A statement or screenshot from a blockchain explorer may become a primary document in accounting — the bank approves the form itself, guided by Regulation No. 809-P. To value coins, it is permissible to use quotations from foreign exchanges, including crypto exchanges, if the organization has access to transactions on them; otherwise the valuation must take this circumstance into account. The requirements for business reputation and qualifications of management apply as of the day of submission of documents, and for work experience — from September 1, 2028.
Cryptalist Analysis: The expansion of the FAQ signals the transition of Russian regulation from framework norms to operational procedures — the regulator is closing practical issues arising for infrastructure. For the market, this reduces regulatory uncertainty and forms predictable rules for institutional participants, although the ban on P2P transactions from July 1, 2027 and mandatory operation through licensed intermediaries will significantly reshape the competitive environment.