Column authors - Andrey Tugarin, founder of GMT Legal, and Denis Polyakov, head of the Digital Economy practice at GMT Legal.
Entering 2026, Russia remains one of the few CIS countries lacking comprehensive regulation for cryptocurrency circulation. On one hand, conducting cryptocurrency transactions is not prohibited in the country; on the other, the activities of crypto exchanges and platforms are not regulated, there is no legal status for stablecoins and a number of other crypto assets, and taxation is not fully developed.
2025, in turn, revealed a number of reasons why further delay in regulating cryptocurrency circulation became impossible.
The first reason is the significant growth of the gray exchange market. Most buy-sell transactions are conducted through P2P exchange without supervision, using accounts of proxy individuals - droppers. This has caused a surge in fraudulent schemes and an influx of dirty money into the P2P segment, which, in turn, has led to mass blocking of bank accounts under the requirements of anti-money laundering legislation (Federal Laws 115-FZ and 161-FZ).
The second reason is the lack of a legal opportunity for miners, who are the only fully legal participants in cryptocurrency circulation in the country, to sell their mined cryptocurrency domestically. The absence of official exchanges and exchangers forces Russian miners to sell their mined assets abroad - for example, through infrastructure in Belarus and other jurisdictions - or resort to the gray exchange market.
The third reason is the lack of legal status for stablecoins. This legal uncertainty deprives stablecoin holders of guarantees of judicial protection and clear tax rules. Also, due to the lack of status for stablecoins, tax questions arise: for example, whether transactions with them should be subject to VAT or not.
The fourth reason is the FATF (Financial Action Task Force) assessment regarding compliance with high standards for combating money laundering and terrorist financing (AML/CFT). Recall that the lack of regulation for crypto exchangers, exchanges, and custodians contradicts FATF recommendations.
Obviously, the regulator needs to take all possible measures to create comprehensive and transparent regulation of cryptocurrency circulation; otherwise, the consequence will be placement on the gray list.
Why are these reasons so important and what are the real consequences of the lack of cryptocurrency circulation regulation in Russia.
Gray crypto exchange: risks, mass blockings, and the fight against drops
Crypto exchanges and exchangers in Russia do not have legal status. Therefore, public demand for cryptocurrency transactions is met through informal channels: exchanger websites without a legal entity, chats, and bots for P2P trading.
The main method of transactions is P2P with settlements through banks. For this, third-party accounts - drops - are widely used, who provide their bank cards for a commission. As a result, banks record suspicious transactions and apply blocking measures under 115-FZ. Both the accounts of drops and ordinary citizens accidentally involved in "triangle" schemes (where payment passes through a third party) are blocked.
Moreover, for persons accidentally involved in a triangle, a second reason for blocking appears - due to the presence of signs of fraudulent operations under 161-FZ. Further, the details of the cryptocurrency seller end up in the Central Bank's database of cases and attempts to conduct operations without the client's voluntary consent.
Mass bank blockings have become an inevitable process in cryptocurrency transactions due to the total lack of control over the "P2P market".
In addition to blockings, 2025 was marked by increased criminal prosecution. Previously, drops often got off with administrative measures, but since this summer, criminal punishment under Art. 187 of the Criminal Code of the Russian Federation "Illegal circulation of means of payment" has been introduced. For example, in Surgut, a fraudulent group converted criminal proceeds into cryptocurrency through a network of drops and withdrew them abroad; as a result, three accused were arrested, and a case was initiated under Part 5 of Art. 187 of the Criminal Code.
The Bank of Russia, in its Financial Market Development Strategy for 2026-2028, outlined the creation of an "Antidrop" information system by 2027. The system will allow banks to exchange information about individuals involved in shadow operations and promptly block their access to financial services.
Simply put, there will be a unified database of drops, where the Central Bank will oblige banks to enter data (for this, as it became known, it is planned to link all citizens' bank accounts to their TIN for more accurate client identification).
Legalization of mining: first results and unresolved issues
On November 1, 2024, the law legalizing cryptocurrency mining came into force. 2025 became a test year for the operation of miner registries and mining infrastructure operators (MIO). The results were encouraging - by October 2025, the registry included 1364 miners and about a hundred infrastructure operators.
Also, through the registry's functionality, monthly reporting on the amount of mined cryptocurrency can be submitted. The exact amounts of taxes received from miners have not yet been disclosed, but the value of cryptocurrency mined in the first three quarters of 2025 amounted to about 32 billion rubles.
However, a number of issues remained unresolved in 2025.
The possibility of foreign entities mining on equipment located in Russia: the law does not explicitly define whether foreign companies can mine in Russia or obtain resident-miner status, for example by creating a permanent tax representation.
Cloud mining is not regulated - when Russian citizens rent capacity abroad or, conversely, foreigners use Russian farms remotely. Such services fall outside the legal framework: it is unclear how to account for income from cloud mining and who is obliged to report to the Federal Tax Service (FTS).
"Gray" equipment. A significant portion of ASIC devices were imported into the country through gray schemes without full payment of customs duties at a time when mining was not regulated. As a result, the devices are operational but formally illegal, and their owners are afraid to declare them to avoid fines for violating customs rules. According to market participants, thousands of miners remain in the shadows. The state recognized this problem in 2025: the Ministry of Finance announced its readiness for a one-time amnesty for previously imported mining equipment.
Problems with selling mined assets: miners were given legal rights, but no mechanism for selling mined assets domestically was provided. Miners are forced to use foreign exchanges and exchangers. Moreover, the FTS, in its methodologies for determining the exchange rate of cryptocurrency, refers only to foreign platforms since there is no domestic market.
In practice, many miners open companies or accounts in friendly jurisdictions (Belarus, Kazakhstan, etc.), where the sale of cryptocurrency is permitted. A strange paradox emerges: mining crypto is possible, but selling it domestically is practically impossible.
Legal vacuum around stablecoins
The situation with stablecoins deserves special attention. 2025 showed how ambiguous their status is in Russian law, and before 2024, stablecoins had no status at all in legislation.
In 2024, legislators introduced the concept of "foreign digital rights" (FDR), which indirectly covers stablecoins backed by foreign currency or other property. Within the country, such FDRs can circulate only if qualified as digital financial assets (DFA). Which, given the nature of stablecoins, is quite possible.
However, according to the Central Bank's Directive 7036-U, FDRs admitted into Russian circulation must have an issuer only from a "friendly" state, which effectively makes it impossible for 99% of the most in-demand stablecoins to enter the domestic market.
The consequence of the legal vacuum manifested itself in judicial practice. Due to the lack of legal status for a stablecoin, a simple debt recovery case for 1000 USDT reached the level of the Constitutional Court. The essence of the problem is that the creditor was denied satisfaction of his claims against the debtor due to incorrect classification of the legal status of USDT by lower instances, equating it to digital currency. During the Constitutional Court hearings in November, it was directly stated: USDT is not a digital currency. However, a final court decision indicating what USDT actually is has not yet been made.
The lack of recognition of stablecoins also complicates tax accounting. Only digital currency is exempt from VAT; there are no special rules for FDRs. Accordingly, transactions with USDT, if conducted between two Russian tax residents, could theoretically be taxed as with ordinary goods, creating a risk of additional tax assessments for market participants.
Forecasts for 2026: what will change in regulation
All signs indicate that 2026 will be a turning point for the Russian crypto market in terms of its regulation. For the first time, all government agencies have reached a compromise - regulation is needed.
Licensing of crypto exchanges and exchangers
Already in the first half of 2026, a bill establishing the procedure for licensing organizations providing cryptocurrency exchange and trading services is likely to be submitted for discussion. It is assumed that the Bank of Russia will issue licenses for crypto platforms.
At the same time, the requirements for license applicants can be predicted now:
- Mandatory presence of a Russian legal entity, with the required authorized capital;
- Appointment of a compliance officer;
- Implementation of AML/CFT measures, including mandatory identification and verification of users with mandatory storage of their data within the Russian Federation;
- Implementation of digital compliance measures, including mandatory checking of the risk level of cryptocurrency transactions and their prevention;
- Meeting technical requirements for platforms conducting cryptocurrency transactions regarding resistance and information security.
It can also be predicted that at the first stage of the new law's operation, a full-fledged independent license for a crypto exchanger will not be activated, and the opportunity to conduct activities with cryptocurrency will be given to participants with an existing license, such as banks or professional securities market participants. This at least does not contradict the Central Bank's concept for regulating cryptocurrencies on the Russian market dated December 23, 2025.
"Transition period"
By analogy with how the licensing introduction process took place in neighboring countries, the legislator will provide time for current participants in the gray cryptocurrency exchange market - they will have to either obtain a license or cease their activities without sanctions.
At the same time, by 2027, a complete ban on any cryptocurrency activity outside the licensed perimeter and the introduction of liability (administrative and criminal) for operating without a license can logically be expected.
Restrictions for retail investors
Separately, the Central Bank intends to limit the size of investments in cryptocurrency. The regulator proposes to allow both qualified and non-qualified investors to invest, but with mandatory passing of all risk understanding tests. It is important to note that from January 1, 2026, the minimum asset size that a qualified investor must own will increase from 12 million to 24 million rubles.
At the same time, according to the regulator's proposal, non-qualified investors will be able to buy only the most liquid cryptocurrency within a limit - no more than 300 thousand rubles per year through one intermediary.
The final decision on this issue will be made during the development of the bill.
Regulation of stablecoins
In 2026, new legislation should close the gap and recognize stablecoins as a separate asset with a separate legal status and establish circulation rules.
For business, the emergence of a stablecoin status is an opportunity to launch their own projects (for example, the issuance of ruble or commodity stablecoins by Russian companies, which is possible even now but with great limitations).
At the same time, there are not many regulatory options in this case, and the following can be predicted:
- "Correcting" the definition of digital currency by removing the part related to the "absence of an obligated person";
- Establishing special regulation for FDR-stablecoins and granting licensed crypto exchangers the right to admit them to trading on par with digital currency.
In summary, it can be noted that 2025 finally solidified the prerequisites for regulation - delaying the process further is no longer possible from either a legal or economic point of view. 2026, in turn, will allow, based on these prerequisites, to develop the first version of full-fledged market regulation.
If the announced plans are implemented, by the end of 2026, a legal segment of cryptocurrency circulation with licensed participants, reporting, and supervision will appear in Russia.
Thus, the cryptocurrency market in Russia expects a transition from a multi-year gray zone to an era of strict but fair regulation. How effective this model will be, time will tell, but one thing is clear already: legislation will no longer stand still, and 2026 will go down in history as a turning point for the Russian crypto industry.
