Self-regulatory organizations (SROs) will appear in Russia for cryptocurrency exchangers. This is a requirement of the law "On Digital Currencies and Digital Rights," which is coming into force in stages from September 1.
The new rules establish requirements for exchangers. They are defined as individuals or legal entities conducting two or more transactions worth more than 3.5 million rubles per month. Such exchangers can only work if included in a special Central Bank register. Other conditions include an equity capital of at least 15 million rubles, strict requirements for personnel and management, maintaining records, and hosting primary and backup software on Russian territory.
Cryptocurrency exchangers will also be required to join a self-regulatory organization (SRO) of the financial market (Article 18, Clause 9 of Law No. 282-FZ). Such SROs do not yet exist, but industry participants are actively preparing for their emergence.
Experts told "RBC-Crypto" about which self-regulatory organizations will begin working in this sphere and what they will do. The Association of Organizations Conducting Digital Currency Exchange (AOCTV), which plans to become an SRO, described its goals and explained how they will help cryptocurrency exchangers.
When will SROs for crypto exchangers appear
For existing market participants in cryptocurrency exchange, a transition period until July 1, 2027, is provided, and participation in an SRO is not necessary during this period, says Nikita Zuborev, senior analyst at the largest online exchanger aggregator Bestchange.ru. Moreover, as of the end of August, the secondary regulatory framework is still being formed: the Central Bank is preparing rules for maintaining registers, admitting organizations, and requirements for managers and calculation of own funds, the expert clarified.
"In other words, there are only a few days left until September 1, and some practical mechanisms are not yet ready and will be fine-tuned over the next few months. The first full-fledged regulated operations may appear roughly no earlier than the end of 2026," believes Zuborev.
In his opinion, it is not yet clear who will ultimately become the basis of the new SRO. Right now, the right for this is being contested by the Association of Organizations Conducting Digital Currency Exchange (AOCTV), created a month ago, which is actively preparing and forming a membership registry, recommendations, standards, compliance, and a dispute resolution mechanism, and the Association of Russian Banks (ARB), which is forming a professional association of market participants with plans for subsequent transformation into an SRO, the analyst said.
According to Dmitry Machikhin, founder of the BitOK service, most likely there will be three different SROs. One organization will unite participants from the banking sector, the second may become an association of brokers, and the third – the aforementioned new AOCTV, which will include existing crypto exchangers.
What will SROs in cryptocurrency exchange do
The SRO model itself will be taken from Law No. 223-FZ, which already works in other segments of the financial market, said Zuborev. The Central Bank will set the framework and control the SRO, and the self-regulatory organization itself will establish detailed rules for the daily work of exchangers and monitor their implementation.
The SRO gets the opportunity to set professional standards and consolidate the market's position, explained Daria Petrukhina, consultant at IPN Partners. She noted that such a model has long been in place in the classic financial market, for example, in NAUFOR, which unites professional securities market participants, monitors compliance with standards, and represents the industry's interests.
In addition to control, an SRO can become a platform for developing unified approaches to practical issues, which will inevitably arise quite frequently in Russia's new crypto market, the expert said. As an additional example, she pointed out that NAUFOR also conducts training and certification of specialists, meaning an SRO can perform not only a regulatory but also an educational and methodological function for the industry.
However, the final working model of the crypto-SRO will only be clear after its creation, approval of internal documents, and registration of its status with the Bank of Russia, said Petrukhina.
Advantages and Disadvantages
Pros
The convenience lies in the fact that, by analogy with other financial spheres, in the future the SRO may have a compensation fund and liability insurance, noted Zuborev. He clarified that ultimately, the end user will receive clear financial guarantees.
It is also convenient that all issues, including those with law enforcement agencies, can be resolved in one place, "civilly" and by sending requests, says Machikhin. Of course, this does not concern illegal activities, but illegal exchangers will not be able to join an SRO anyway, the expert clarified, adding that the legitimization of the industry is now happening before our eyes.
The main advantage of an SRO, according to Petrukhina, is the opportunity to form unified working rules and conduct a consolidated dialogue with the Bank of Russia, instead of each market participant separately trying to convey their practical problems to the regulator.
For the business itself, this could also simplify adaptation to new requirements, the lawyer believes. She explained that as practice develops, the SRO will be able to provide clearer professional guidance on compliance issues, process organization, and client interaction.
Cons
Among the disadvantages, Zuborev noted that an SRO could cause serious market consolidation. This is not necessarily bad from the state's or large businesses' point of view, but for competition, and therefore the final price for users, this is a potentially very serious minus, the analyst said.
He also drew attention to the fact that the cons from a business perspective will be determined in the future. In Zuborev's opinion, this will depend on what specific standards the SRO introduces for exchangers and how expensive it will be to follow them. Such standards could include AML (Anti-Money Laundering) and KYC (Know Your Customer) norms, as well as limits, reserves, rules for storing cryptocurrency, working with cash and bank accounts, rules for handling complaints, processing refunds, and liability for stuck/erroneous transactions.
Membership means additional regulatory and financial burden, clarified Petrukhina. She explained that the company will have to comply with SRO standards, undergo control procedures, and bear associated membership costs.
Machikhin agreed that difficulties are possible at the first stage, as it is not yet entirely clear how the SROs themselves will function and what the conditions for being in them will be. But the expert believes that within the first year of operation, "everything will settle down."
Are exchangers ready
It is important to note that the number of exchanger websites today is not equal to the number of potential legal participants in an SRO, said Zuborev. One brand can have several websites with separate teams or have several legal entities.
The expert pointed out that the announced threshold of 15 million rubles in equity capital is only a small part of the requirements. He stated that the real cost of preparing a business will be significantly higher both in monetary terms and in management resources: there will be a need for in-house lawyers, compliance policies and AML systems, information security at the level of leading banks, regular audits, stricter reporting, improvement of information infrastructure, and ensuring integration with government services, and finally, membership and servicing in the SRO.
"Requirements will even be imposed on the management of exchangers, by analogy with other financial organizations. The entry ticket to this market will cost an order of magnitude more than the announced 15 million, and the work that will have to be done this year is staggering in its scale," said Zuborev.
But the market is unlikely to empty, the expert believes. He expressed confidence that against the backdrop of the departure of several dozen small exchangers, a whole pool of services from banks will appear. The analyst recalled that in the case of banks, a universal license allows opening "exchange points" as part of the infrastructure almost in a notification-based manner, without long and complicated paths to obtaining new licenses.
According to Machikhin, cryptocurrency exchangers will mostly join the SRO that the AOCTV plans to become. The expert estimates the number of participants at 150-200.
What is AOCTV and what are its goals
The Association of Organizations Conducting Digital Currency Exchange (AOCTV) was created at the end of July 2026, its General Director is Andrey Tugarin, founder of the legal company GMT Legal. He said that AOCTV will certainly obtain SRO status.
He explained that without these regulatory acts, it is not legally possible to submit an application for SRO status. Also, according to the head of the association, it is necessary to wait for a number of resolutions and instructions from the Central Bank, after which the association will immediately submit all necessary documents.
Tugarin said that the main goal of AOCTV is to give the cryptocurrency exchange market the most legal status possible, so that the Bank of Russia sees it and so that the regulator develops proper communication with legal market participants.
Furthermore, since joining an SRO will become mandatory for exchangers, AOCTV will offer a mechanism for implementing this requirement.
"We are creating for the market not only the opportunity to unite, to ask the most inconvenient and pressing questions about the new regulation, but we are creating and giving the market a mechanism for them to be legal, because joining an SRO for legal exchangers is not a choice, but a direct obligation," said Tugarin.
He added that for those who wish to be legal crypto exchangers in Russia, the association intends to provide all possible tools for this.
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