In March 2026, the first version of the draft law "On Digital Currency and Digital Rights" leaked online, causing a wave of panic: a complete ban on personal wallets, an annual limit of 300 thousand rubles for unqualified investors, a whitelist of five to ten coins, and increased costs for foreign economic activity. However, on July 16, the State Duma Committee on the Financial Market approved the text for the second reading, and the document underwent radical changes. I analyzed the final version, two tables of amendments, the committee's decision, and the conclusion of the Legal Department. The results show that the regulator compromised but embedded new mechanisms of strict control into the law.
Personal Wallets: Not Banned, but Subject to Conditions
The main fear of the March version — criminal liability for using MetaMask or Ledger — has disappeared. Article 31 directly allows the transfer of digital currency from a depository to a non-custodial address. However, this is not a "free withdrawal": the transfer requires that the receiving address be administered by a foreign organization authorized to manage third-party addresses under its legislation. Additionally, the Bank of Russia has the right to set a maximum limit for such transfers. The depository infrastructure remains a central element but is no longer the only permitted storage location.
Limit for Unqualified Investors: No Fixed Amount, Set by the Central Bank
The leaked version featured a limit of 300 thousand rubles for unqualified investors. The text for the second reading does not contain this figure. Paragraph 3 of Part 1 of Article 31 refers to a regulatory act: "the total value of digital currencies acquired through a broker during a calendar year does not exceed the maximum amount established by the Bank of Russia." An amendment by Deputy Gartung to set a lower limit of 600 thousand rubles was rejected. This gives the Central Bank flexibility but reduces predictability for market participants. In discussions, a benchmark of 600 thousand rubles was mentioned but not legally fixed.
Whitelist Transformed into a Formula: Only Bitcoin Qualifies
Instead of a list of 5-10 coins, there is strict mathematics. A trading organizer can admit a digital currency to public circulation only if the Central Bank includes it in a special list. Inclusion conditions (Part 13 of Article 31): market capitalization above 5 trillion rubles for two years, average daily trading volume above 1 trillion rubles, and price disclosure for at least five years on a licensed foreign exchange with a trading volume of no less than 100 billion rubles. Today, only Bitcoin confidently meets these criteria. Ethereum is on the borderline. Everything else for unqualified investors is excluded from public trading. Gartung's amendment to lower the capitalization threshold to 1 trillion rubles was rejected.
Stablecoins and Foreign Economic Activity: Direct Payments Remain Legal
The March version did not differentiate between stablecoins and cryptocurrencies, threatening to increase the cost of foreign economic activity by 4-5% through a chain of intermediaries. The text for the second reading changes this logic. The foreign trade regime is written as a cross-cutting exception in almost all key articles. The ban on accepting digital currency as a means of payment (Part 6 of Article 1) does not apply to settlements under foreign trade contracts between residents and non-residents. Moreover, the regime extends to agents, commissionaires, and attorneys servicing foreign trade contracts. For importers and exporters, this means that a direct contract for payment in USDT remains a legal channel. The law still does not introduce a separate definition of stablecoins — they remain a specific case of digital currency. Their regulation, as Aksakov previously stated, is planned to be addressed separately in the fall session.
P2P via Cards: Ban Postponed Until July 2027
The mechanism to combat gray P2P exists in the text but is delayed. Article 21 obliges banks to refuse transfers if there are suspicions that the recipient is engaged in organizing the circulation of digital currencies without a license. The Central Bank will send banks information about such foreign payment services, and banks will block transfers to them. A key detail: Article 21 and Part 1 of Article 30 come into force only on July 1, 2027. Until this date, a transitional norm (Part 28 of Article 55) applies, which directly permits systematic trading on one's own behalf and at one's own expense. This gives the P2P market almost a year of legal operation.
Testing as a New Mandatory Barrier
The system includes a separate institution — individual testing (Article 32). Without a positive test result, an unqualified investor cannot buy digital currency through a broker or withdraw it to an external address. The test is conducted by a broker, manager, depository, or exchange according to the SRO's basic standard, free of charge and in electronic form. The result is valid for one year from the date of the last transaction. This is a familiar structure from the stock market, applied to crypto: access to a risky instrument through qualification and knowledge testing, rather than a direct ban.
State Will Gain Access to Digital Accounts
Part 2 of Article 33 obliges the depository, upon request from federal authorities, the prosecutor's office, inquiry and preliminary investigation bodies, as well as bodies conducting operational-search activities, to open digital accounts and provide access to identifier addresses. This is a direct consequence of recognizing digital currency as property for the purposes of the criminal code — the asset can now be seized at the infrastructure level.
Fines Placed Outside the Scope
An important point that alleviates part of the March panic: Law No. 1194918-8 itself does not contain articles on fines and criminal liability. The three blocks of sanctions (domestic payments, illegal intermediation, illegal mining) discussed in the spring belong to a separate accompanying bill with amendments to the Administrative Code and Criminal Code. The discussed text only specifies the civil liability of circulation organizers: if transaction conditions are violated or a client is wrongfully recognized as a qualified investor, the organizer must buy back the digital currency from the client, compensate for losses, and cover all expenses.
When the Law Will Take Effect
The timelines are fragmented. The main part of the law comes into force on September 1, 2026. The P2P-blocking Article 21 and Part 1 of Article 30 — on July 1, 2027. A number of norms on confidentiality and exchange activities — on September 1, 2027. Existing digital financial asset operators are given a transition period until September 1, 2028, to bring their activities into compliance.
Conclusion: Compromise with Elements of Strictness
The regulator abandoned outright bans where they threatened to drive the market into the shadows (personal wallets, direct foreign economic activity, fixed limits) but embedded strictness into other mechanisms: a barrier formula for coin admission, mandatory testing, bank blocking of gray P2P, and direct law enforcement access to depository accounts. Key quantitative parameters are delegated to acts of the Bank of Russia, giving the regulator freedom to adjust thresholds without amending federal law.
My analysis: For retail investors, entry becomes legal but narrow — a test, a limit from the Central Bank, and practically one asset admitted to public trading (Bitcoin). For professionals and foreign economic activity players, working channels remain but with mandatory depository infrastructure. The law creates a two-tier system: a public market for Bitcoin and a "gray zone" for everything else, which will gradually shrink through bank control and testing requirements. Watch for the second reading on July 21 and the accompanying package of amendments to the Administrative Code and Criminal Code — that is where the real fines and prison terms will be specified.