On September 1, a law regulating the circulation of cryptocurrencies formally came into force in Russia. However, it would be premature to consider this date as the moment of the actual launch of the new market. In my assessment, which coincides with the opinion of leading industry experts, for example, Kirill Pistsov from the Finam Financial Group, legislators have created only a legal framework. Within this framework, it is still necessary to build working exchanges, digital depositories, settlement infrastructure, and prepare ready-made products for financial companies.
Participants have been given a transition period until July 1, 2027, to form this entire system. Therefore, in the coming months, it is far more interesting to observe not the loud statements of brokers about their readiness to work with digital assets, but how the infrastructure itself will be assembled.
Storage and Separation of Functions
The first problem area is the custodial model. The Russian approach envisions the emergence of digital depositories that will record rights to cryptocurrency in much the same way as is done today with securities. This is a separate regulated business, and the Bank of Russia imposes serious requirements on such organizations — capital from 50 to 250 million rubles depending on the functions performed. This entry threshold significantly raises the bar and turns asset storage into an independent direction rather than a side option of a trading platform.
This is an important difference from the classic crypto market, where an exchange often simultaneously accepts client money, executes trades, and stores assets. The Russian architecture gradually separates these functions among different participants. For an investor, such a scheme potentially reduces infrastructure risks, but for businesses, it makes launching a product more complex and expensive.
Liquidity and Range of Assets
The second issue is liquidity. The law permits organized cryptocurrency trading, and exchanges will be able to independently prescribe trading modes and calculate market prices. However, the presence of a trading platform does not yet create a liquid market. This requires large participants, market makers, and access to a sufficient volume of cryptocurrency. Otherwise, the Russian price may differ significantly from the global one, and spreads may prove too wide for the mass client.
The third limitation is the range of assets. For the non-qualified investor, the regulator proposes allowing only the most liquid cryptocurrencies with sufficient capitalization, trading volume, and a pricing history of at least five years. Therefore, in the first version of the regulated market, we will most likely be talking about a small set of large assets rather than the hundreds of coins familiar to users of crypto exchanges.
Product Economics and the Second Stage
Finally, there remains the economics of the product itself. Financial companies will have to pay for storage infrastructure, compliance, trade execution, and meeting new regulatory requirements. The Bank of Russia has already proposed taking cryptocurrency risks into account in the financial stability ratios of market participants. As a result, 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 the client considers competitive compared to the familiar crypto exchange.
For this reason, I propose viewing September 1 as the beginning of the second stage of development of the Russian crypto market. The first stage was legislative: it determined who has the right to work with cryptocurrency and under what conditions. Now begins a more complex period when these norms will have to be turned into a functioning market infrastructure.
It is this stage that will show what the Russian regulated market will look like. The law has already permitted it to exist, and participants now have to prove that trading on it can be convenient, liquid, and economically sensible.
My view: the separation of functions between exchanges and depositories is a step toward maturity, but it will inevitably slow down adoption. In the short term, Russian investors will continue to use foreign platforms, while domestic platforms will fight for their first volumes. Success will depend on whether the regulator and business can find a balance between protecting rights and economic attractiveness for the end user.