As of September 1, a law regulating cryptocurrencies formally came into force in Russia. However, it would be premature to view this date as the actual launch of a new market. Only a legal framework has been created, within which operational exchanges, digital depositories, settlement infrastructure, and ready-made products for financial companies still need to be built. This is merely the first step on a long journey.
Transition period: time for building
Market participants have been given a transition period until July 1, 2027. In the coming months, it will be far more interesting to watch not the loud statements from brokers about their readiness to work with cryptocurrency, but how the ecosystem itself takes shape. The legislation has defined the rules of the game, but the game itself will begin when real tools and liquidity emerge.
Custody and separation of functions
One of the key challenges will be asset custody. The Russian model envisions the emergence of digital depositories that will record rights to cryptocurrency in a manner similar to how securities are recorded today. This is a separate, strictly regulated business. The Bank of Russia has set capital requirements for such organizations ranging from 50 to 250 million rubles, depending on the functions performed. This significantly raises the entry barrier and turns custody into an independent line of business rather than a side option for a trading platform.
This architecture is an important distinction from the classic crypto market, where an exchange often simultaneously accepts client funds, executes trades, and holds assets. The Russian approach gradually separates these functions among different participants. For investors, this potentially reduces infrastructure risks, but for businesses, it makes launching a product more complex and expensive.
Liquidity and asset assortment
The second critical issue is liquidity. The law permits organized trading, and exchanges will be able to independently determine trading modes and calculate market prices. However, the existence of a platform alone does not create a liquid market. This requires major participants, market makers, and access to a sufficient volume of cryptocurrency. Otherwise, the Russian price will diverge from the global one, and spreads will be too wide for the mass client.
The third constraint is the assortment. For non-qualified investors, the regulator proposes allowing only the most liquid cryptocurrencies with sufficient market capitalization, trading volume, and a pricing history of at least five years. Therefore, at the initial stage, we will be talking about a small set of major assets, not the hundreds of coins familiar to crypto exchange users.
Product economics and the second stage
Finally, there is the economics of the product itself. Financial companies will have to pay for custody infrastructure, compliance, trade execution, and meeting new regulatory requirements. The Bank of Russia has already proposed incorporating cryptocurrency risks into the financial stability ratios of market participants. Ultimately, the main question for an intermediary will not be whether it can technically add BTC to its app, but whether it can do so at a commission that clients find competitive compared to their usual crypto exchange.
Therefore, September 1 should be viewed as the beginning of the second stage in the development of the Russian crypto market. The first stage was legislative: it defined who has the right to work with cryptocurrency and under what conditions. Now begins a more complex period—turning these norms into functioning market infrastructure. It is this stage that will reveal what the Russian regulated market will look like. The law has already allowed it to exist, and participants must now prove that trading on it can be convenient, liquid, and economically sensible.
My view: separating custody and trading functions is a step toward institutional maturity, but it will inevitably raise costs. In the short term, this could make Russian platforms less attractive to retail traders accustomed to the low fees of global exchanges. The success of the new model will depend on whether local players can offer real value rather than merely meeting formal requirements.