On September 1, the founding congress of the "Association of Organizations Engaged in Digital Currency Exchange" (AOCDE) was held in Moscow. This event marks an important stage in structuring the Russian crypto exchange market, which is preparing to transition into the legal sphere under the supervision of the Central Bank.

Ambitions and Preparation for SRO Status

Judging by official materials, AOCDE already positions itself as a future self-regulatory organization (SRO). The stated mission is to consolidate the positions of exchangers to develop unified standards and establish constructive dialogue with the Bank of Russia. The organization plans to maintain a register of members, develop industry recommendations, and build the foundation for a future quality control system.

At the congress, the key topic was discussion of the transition period and regulator requirements. A significant portion of participants expressed concern that the new rules could significantly impact the profitability of the exchange business, especially under stringent financial regulations.

The Price of Legality: Requirements and Reality

To operate under the new status, crypto exchangers are subject to the following conditions:

  • availability of own capital of at least 15 million rubles;
  • inclusion in the official register of the Bank of Russia;
  • mandatory membership in a specialized SRO.

Although the 15 million ruble threshold seems inflated to many domestic players, a comparative analysis reveals a different picture. In the European Union, MiCA requirements stipulate a minimum capital of €125,000, and the full cost of launching a legal platform often reaches half a million euros. In Kyrgyzstan, the analogous figure is about 42 million rubles. Thus, Russian conditions appear quite competitive and even more lenient compared to other regulated jurisdictions.

Wait-and-See Strategy and the Role of Major Players

The transition period will last until June 30, 2027. In my estimation, a significant portion of the market will not rush things, preferring to take a wait-and-see stance. Many systemically important banks are already actively testing cryptocurrency operations and are at the starting line. Other participants will likely observe the first legalization cases before making final decisions.

The creation of an SRO is a standard and logical step for the financial industry. The success of this structure will directly depend on its ability to effectively advocate for business interests before the regulator, rather than merely formally performing supervisory functions.

Parallel Initiatives

Notably, NAUFOR, traditionally strong in the securities sector, has also announced its intention to obtain SRO status for operators of information systems, digital depositories, and crypto exchangers. The organization plans to submit documents as early as the first half of September, indicating high competition for the right to regulate this new segment.

Let me remind you that on August 31, the Bank of Russia announced the launch of the digital ruble, adding another layer of complexity to the country's emerging digital finance ecosystem.

My expert view: the crypto exchange market in Russia is entering a phase of maturity, and the emergence of two contenders for SRO status at once is a positive signal. However, the key test will not be formal compliance with requirements, but the ability of these organizations to create working mechanisms for protecting the interests of bona fide participants and to build transparent relations with the Central Bank. This will determine how quickly the industry can adapt to new realities and attract institutional investors.