Russia Crypto Custody Rules: Depositories and Safekeeping

Russia crypto custody rules place regulated crypto-asset safekeeping and record keeping within a new system of digital depositories overseen by the Bank of Russia. The framework matters to financial institutions, custodians, market participants and investors because control of digital assets, account records and cryptographic access now carries formal registration, capital and compliance requirements.

Key Takeaways

• Federal Law No. 282-FZ established Russia’s digital-depository framework; the law was signed on August 4, 2026, after State Duma adoption on July 21, and its main crypto-market provisions took effect on September 1, 2026.

• A digital depository must be entered in the Bank of Russia register before conducting regulated custody activities involving digital currencies or digital rights.

• Minimum capital ranges from RUB 50 million to RUB 250 million depending on the custodial services performed; settlement digital depositories require RUB 250 million.

• Digital depositories must protect confidential information, including access keys, client records, digital accounts and transaction information.

Current Russia Crypto Custody Rules

Under Federal Law No. 282-FZ, a digital depository provides services for recording and transferring digital currency and digital rights and may provide access to blockchain addresses where those assets are recorded. Only an eligible Russian company entered in the Bank of Russia digital-depository register framework may conduct this regulated activity.

This model brings crypto custody closer to regulated financial infrastructure rather than leaving crypto asset safekeeping solely with centralized exchanges or private wallet arrangements. The distinction between third-party custody and user-controlled private keys is also important when comparing custodial and non-custodial wallets.

The Bank of Russia’s September 11, 2026 Regulation No. 892-P sets further requirements for digital depositories and certain foreign organizations, although the regulation was still undergoing Ministry of Justice registration when last verified.

Capital, Safekeeping and Record-Keeping Requirements

The required capital depends on the services provided.

The Bank of Russia also requires eligible capital assets to be sufficiently liquid, with included financial assets meeting credit-quality standards.

Crypto custody creates specific risk management considerations because control of cryptographic keys can determine the practical ability to transfer assets. Russian law therefore requires digital depositories to preserve the confidentiality of access keys and records concerning clients, accounts, assets and transactions. Secure key generation, access controls, backup arrangements and contingency planning remain important operational safeguards because lost or compromised private keys can result in loss of access or unauthorized transactions.

Who Can Trade and Hold Crypto Assets?

The Bank of Russia’s cryptocurrency market framework allows qualified and non-qualified investors to trade through regulated intermediaries such as brokers, management companies and cryptocurrency exchanges.

Non-qualified individual investors face a RUB 300,000 annual purchase limit through each intermediary after testing. The Bank of Russia’s August 2026 draft implementing rules identified Bitcoin, Ethereum and Tether USDT as cryptocurrencies meeting its liquidity criteria for public exchange trading. Qualified investors may access a broader range of crypto assets without the same purchase limit.

Cryptocurrency remains prohibited as payment for domestic goods and services in Russia. Cross-border trade is different: exporters and importers may use crypto directly, while Russian residents holding cryptocurrency through foreign infrastructure face reporting requirements.

Russia also treats digital currency as property for tax purposes.

Transition Period and Regulatory Oversight

The regulated system took effect on September 1, 2026, but implementation is staged. The Bank of Russia states that existing market participants have a transition period through July 1, 2027 to obtain required licences and align their operations with the new rules.

The central bank maintains regulatory registers covering digital depositories and other financial-market entities and can set additional requirements concerning capital, governance, risk management, infrastructure and compliance.

Russia Rules vs. U.S. Crypto Custody Rules

Russia’s digital-depository framework should not be confused with U.S. custody regulation. In the United States, registered investment advisers generally must follow the Investment Advisers Act custody framework where applicable, while registered investment companies operate under separate Investment Company Act requirements.

The SEC withdrew its proposed Safeguarding Advisory Client Assets rule in June 2025, so that proposal did not become the broad new crypto custody rule originally contemplated. SEC registration generally becomes mandatory for an investment adviser once regulatory assets under management reach $110 million, subject to statutory exceptions.

For national banks, the Office of the Comptroller of the Currency says crypto custody must be performed in a safe and sound manner and under applicable laws; banks acting in a fiduciary capacity must comply with 12 CFR Part 9, while federal savings associations follow Part 150.

How Gate Can Help

Crypto custody involves a trade-off between relying on a custodian and controlling cryptographic credentials directly. Users comparing those models can examine how wallet infrastructure manages private keys and signing authority before transferring assets.

For an example of a different self-custody architecture, Gate Vault uses multi-party computation to distribute key material rather than keeping a complete private key in one location. Availability and legal access still depend on the user’s jurisdiction and applicable regulations.

Conclusion

Russia’s crypto custody framework creates a formal role for Bank of Russia-registered digital depositories, with capital, record-keeping, confidentiality and operational requirements designed around digital-asset safekeeping. The regime is already in force, but implementing regulations and transitional arrangements continue to develop, making current Bank of Russia rules and registers important when assessing a custodian’s legal status.

FAQ

Are cryptocurrencies legal to hold in Russia?

Yes. Russian law recognizes digital currency as property, although its use as payment for domestic goods and services remains prohibited.

What is the minimum capital for a Russian digital depository?

The minimum ranges from RUB 50 million to RUB 250 million depending on the activity. A settlement digital depository requires RUB 250 million, while certain custody or address-access models require RUB 100 million.

Can retail investors buy Bitcoin, Ethereum and USDT in Russia?

The Bank of Russia identified Bitcoin, Ethereum and Tether USDT under its liquidity criteria for non-qualified investors. Such investors face testing requirements and a RUB 300,000 annual purchase limit through each intermediary under the implementing framework.

Do Russian crypto custodians need to register with the Bank of Russia?

Yes. A company may conduct digital-depository activity only after obtaining the applicable right to operate and being entered in the Bank of Russia’s digital-depository register.

Was Russia’s crypto custody law passed on July 24, 2026?

No. The State Duma adopted the crypto-market law on July 21, 2026, while Federal Law No. 282-FZ is dated August 4, 2026. Its principal crypto-market framework took effect on September 1, 2026.