20 January 2026

DFA Transactions and Digital Currency Regulation in Russia: 2026 Legal Framework

January 20, 2026

BRACE Law Firm ©

The use of DFAs in civil circulation expands investment and asset management opportunities while increasing the transparency and security of financial operations. The accounting and circulation of DFAs occur within specialized platforms that ensure interaction between issuers and investors.

Since DFAs and digital currencies are objects of civil rights, questions arise regarding the types of transactions possible with DFAs and digital currency. This article examines the specifics of conducting transactions with DFAs and digital currency, considering their digital nature.

DFAs and Digital Currency as Objects of Civil Rights and Civil Law Transactions

In accordance with the provisions of Articles 128 and 129 of the Civil Code of the Russian Federation (the "Civil Code"), property includes material and intangible objects of civil rights which, as a general rule, may be alienated and transferred from one person to another. Digital rights, which include DFAs and digital currency, are a variety of property characterized by their existence in a digital and intangible environment.

In accordance with Article 141.1 of the Civil Code, digital rights are recognized as obligatory and other rights designated as such by law, the content and conditions for the exercise of which are determined in accordance with the rules of an information system meeting the criteria established by law. The exercise, disposal (including transfer, pledge, or other encumbrance), or restriction of disposal of a digital right is possible only in the information system without recourse to a third party. We note that DFAs are recognized as digital rights, including monetary claims, the possibility of exercising rights under emissive securities, rights of participation in the capital of a non-public joint-stock company, and the right to demand the transfer of emissive securities provided for by the decision to issue digital financial assets, the accounting and circulation of which are possible only by making (changing) records in an information system based on a distributed ledger, as well as in other information systems (Article 1, Clause 2 of the Law on DFAs).

Digital currency is recognized as a set of electronic data (digital code or designation) contained in an information system that is offered and/or may be accepted as a means of payment that is not a monetary unit of the Russian Federation, a monetary unit of a foreign state, and/or an international monetary or settlement unit, and/or as an investment, and in relation to which there is no person obligated to every holder of such electronic data, with the exception of the operator and/or nodes of the information system obligated only to ensure that the procedure for issuing these electronic data and performing actions to make (change) records in such an information system complies with its rules (Article 1, Clause 3 of the Law on DFAs).

The Law on DFAs does not contain special provisions dedicated to the introduction of DFAs into civil circulation. Acts constituting the procedures for introducing DFAs into circulation may be the willful actions of participants in relationships, without which DFAs cannot exist or be alienated. [1] The sole condition for introducing any digital rights into civil circulation is the reflection of any actions involving them in the information system. The Civil Code, the Law on DFAs, and other legislative acts do not require any special certification or registration procedures for DFAs or transactions for the transfer of rights to DFAs with authorized bodies. At the same time, there are a number of restrictions on transactions with DFAs and digital currency, which are discussed below.

In general, the circulation of digital property, including DFAs, follows the general rules of civil circulation, taking into account two specific features:

Actions of participants in circulation are performed using a special information system; i.e., the circulation of objects is formalized in an electronic-digital form;
Objects of digital circulation are created, moved (alienated), and terminated in the information system as a digital software and hardware complex. [2]

Distinction Between the Concepts of Digital Financial Assets and Digital Currency

DFAs represent digital rights to financial instruments recorded in an information system based on a distributed ledger. Unlike digital currency, DFAs have an issuer who bears responsibility for the performance of obligations. Digital currencies, in turn, are electronic data used as a means of payment or investment and do not have an issuer.

Thus, the primary property of DFAs is the presence of a person who has obligations to the holder of such an asset, whereas the only obligation of the operator and nodes of a digital currency information system is to ensure that the procedure for its issuance and the records concerning it in that system comply with its rules. Digital currency operators are not obligated to redeem it or perform other obligations.

Subjects of Transactions with DFAs and Digital Currency

The Law on DFAs distinguishes the following types of subjects in the circulation of DFAs and digital currency:

The holder (owner) of rights certified by DFAs or digital currencies;
The nominal holder of rights certified by DFAs;
The person performing the issuance of DFAs;
The information system operator;
The DFA exchange operator.

The subjects of transactions with DFAs are issuers (who issue DFAs) and investors (buyers and sellers), as well as information system operators and DFA exchange operators who provide the infrastructure for such transactions. Only legal entities and individual entrepreneurs may serve as DFA issuers, whereas both individuals and legal entities may act as investors.

Subjects of transactions with digital currency include individuals, individual entrepreneurs, and legal entities. In addition, there are specialized subjects such as exchange operators, digital financial asset platform operators, and miners, who must comply with specific legislative requirements.

DFA Exchange Operator

In accordance with Article 10 of the Law on DFAs, purchase and sale transactions with DFAs and other transactions related to DFAs, including the exchange of one type of DFA for another type or for digital rights provided for by law, as well as transactions with digital rights simultaneously including DFAs and other digital rights, are conducted through a DFA exchange operator, which ensures the conclusion of transactions by collecting and matching opposing bids to perform such transactions or by participating in the DFA transaction for its own account as a party to such a transaction in the interests of third parties. This rule does not apply to transactions related to the use of DFAs as counter-performance under foreign trade contracts.

Credit institutions, trade organizers, and other legal entities that meet the requirements of the Law on DFAs and are included by the Bank of Russia in the register of DFA exchange operators upon their petition may serve as a DFA exchange operator. A DFA exchange operator is entitled to carry out its activities from the moment of its inclusion in the register.

To be included in the register of DFA exchange operators, commercial organizations must meet requirements for the size of their charter capital, which must be at least 50 million rubles, as well as for the size of net assets, which must be at least 50 million rubles. For non-profit organizations, the total annual amount of property contributions from founders (participants, members) to the property of the legal entity must be at least 50 million rubles (Article 10 of the Law on DFAs).

The register of digital financial asset exchange operators is published on the official website of the Bank of Russia. As of September 26, 2025, two organizations are listed in the register of DFA exchange operators. [3]

When conducting DFA transactions by collecting and matching opposing bids and/or participating in a DFA transaction for its own account as a party to such a transaction in the interests of third parties, the exchange operator may open a nominal account in a Russian credit institution. The beneficiaries of this account include the person issuing the DFAs, the DFA holder, the person intending to purchase the DFAs, and the nominal DFA holder.

A DFA exchange operator must ensure the storage of information regarding DFA transactions conducted through it, as well as information about the participants in such transactions, for at least 5 years from the date of the corresponding transactions.

A DFA exchange operator must refuse to facilitate the conclusion of DFA transactions that violate the prohibition on accepting DFAs as a means of payment or other counter-performance for transferred goods, performed work, or rendered services, or any other method suggesting payment for DFAs.

The Bank of Russia may establish additional requirements for the activities of DFA exchange operators and the information system used to conduct DFA transactions through a DFA exchange operator. [4] For instance, the allowable downtime and/or degradation of technological processes that enable DFA transactions and interaction with the information system operator must not exceed 12 hours.

If the Bank of Russia identifies a violation by the DFA exchange operator of the requirements of the Law on DFAs, Bank of Russia regulations, the rules of the DFA exchange operator, or the rights and legitimate interests of information system users, or if a threat to such rights exists, the Bank of Russia may:

Fully or partially restrict the activities of the DFA exchange operator in facilitating the conclusion of DFA transactions;
Require the DFA exchange operator to replace the person performing the functions of the sole executive body.

How to Conduct Transactions with DFAs and Digital Currency?

As a first step to conducting DFA transactions, a user must undergo identification with the information system operator and become a user of the information system. Each user has their own wallet, which they can fund. After funding the wallet, the user can accept the offers of issuers and participate in primary placements of DFAs in the information system. The user may also purchase DFAs on the secondary market if the trading and settlement services of the information system operator permit this.

In information systems, a user wallet is opened automatically upon completion of registration. A wallet is defined as a software and hardware tool that is part of the information system, designed for accounting for DFAs and displaying information about the amount of the user's funds held in a nominal account. Each wallet is assigned a unique identification number. It should be noted that a user may have only one wallet; opening additional wallets is not permitted.

A user may also conduct DFA transactions on the platform of a DFA exchange operator; in this case, the user must undergo identification not only with the information system operator but also with the DFA exchange operator.

According to Article 2 of the Law on DFAs, records of DFAs are entered or changed upon the instructions of the person issuing the DFAs, their holder, a nominal holder, or a foreign nominal DFA holder.

A DFA holder is defined as a person who simultaneously meets the following criteria (Article 4 of the Law on DFAs):

The person is included in the register of users of the relevant information system;
The person has access to the information system by possessing a unique code necessary for such access, which allows them to obtain information about the DFAs they hold and to dispose of those DFAs using the information system.

The transfer of rights to digital financial assets occurs based on the following grounds:

A contract between the parties, which may be concluded in electronic form using smart contracts;
Inheritance, as rights to DFAs may pass by inheritance in accordance with the procedure established by legislation;
Reorganization of a legal entity. In the event of the reorganization of a legal entity that is a DFA holder, the rights to them pass to the successor;
Execution of a court act. The transfer of rights to DFAs may be carried out as part of the execution of a court decision.

The Law on DFAs provides for the possibility of transferring rights to DFAs on other grounds provided for by Russian legislation. For example, experts believe that a condition regarding DFAs may be included in a prenuptial agreement.[5]

The transfer of digital financial assets from one user to another in the operator's information system is carried out based on purchase and sale transactions, exchanges, or other transactions related to DFAs.

Purchase and Sale of DFAs and Digital Currency

Purchase and sale include the purchase of DFAs from issuers or other holders, or the sale of DFAs to other market participants.

Please note that individuals who are not qualified investors may invest in DFAs subject to certain requirements established by the Bank of Russia.[6] Individuals who are not qualified investors may purchase DFAs through an information system operator only within a limit of 600,000 rubles during one year. Legal entities that are not qualified investors may purchase DFAs without adhering to the limit.

Both individuals and legal entities that are not qualified investors are prohibited from purchasing DFAs that meet the following criteria:

They are issued in information systems organized in accordance with foreign law;
They certify the possibility of exercising rights under emissive securities, the acquisition of which may be carried out exclusively by persons who are qualified investors, or the right to demand the transfer of such securities;
The decision to issue DFAs involving monetary claims does not specify the period within which the person issuing the DFAs is obligated to fully perform the obligation;
The right to receive payments or the amount of payments under DFAs involving monetary claims is contingent upon the occurrence, non-occurrence, or change in the values of indicators and circumstances provided for by Article 2 of the Federal Law On the Securities Market. For example, depending on changes in the prices of goods, securities, the exchange rate of the relevant currency, and other circumstances.

In addition, individuals who are non-qualified investors are prohibited from purchasing DFAs that meet the following criteria:

They certify the possibility of exercising rights under emissive securities included in the quotation lists of a stock exchange, with the exception of bonds, or the right to demand the transfer of such securities;
They certify the possibility of exercising rights under federal loan bonds or the right to demand the transfer of such bonds;
They certify the possibility of exercising rights or the right to demand the transfer of a bond if its issuer or the person who provided security for the bonds has a credit rating lower than the level established by the Board of Directors of the Bank of Russia [7] (for example, "ruAAA" according to the national rating scale for the Russian Federation of the credit rating agency JSC Expert RA);
They include monetary claims the amount of which is equivalent to the value of a precious metal, the name and mass of which are specified in the decision to issue such digital financial assets;
They include monetary claims the amount of which is equal to the value of shares or the value of shares and the amount of dividends on them.

Available assets can be found in the relevant information system. Before purchasing, it is important to study the decision to issue DFAs, which specifies all conditions: the rights the asset provides, its term, the redemption procedure, etc. Next, a bid to purchase or sell the DFA must be submitted. The bid specifies the number of DFAs or the amount planned to be spent/received, and the account for the operation. For sales, it is important to consider that not all DFAs can be sold on the secondary market, as indicated in the issuance decision. The information system operator records the transaction and automatically initiates settlements via a smart contract. When purchasing on the primary market, the operator blocks an amount equal to the cost of the DFA in the client's account after the bid is submitted. When the issuance is deemed successful, the money is transferred to the issuer, and the DFAs are transferred to the buyer. On the secondary market, transactions are executed instantly: after the bid is submitted, the buyer immediately receives the DFAs, and the seller receives the funds.

Regarding digital currency, since it is considered property, purchase and sale transactions are also possible. Legislation does not prohibit transactions where the object is virtual means of payment, including their purchase and sale.

The specific nature of the purchase and sale of digital currency lies in its subject matter. Thus, it is necessary to specify which digital currency is being transferred under the agreement between the parties and in what volume. The method of transferring such property will also be specific, as it does not exist on a material carrier. Therefore, it is important to specify the wallet details to which the electronic funds will be transferred, as well as the timeframe for their crediting.

Exchange of DFAs and Digital Currency

The exchange of digital financial assets is an operation aimed at converting one type of DFA into another type or into traditional financial instruments (e.g., shares, bonds).

It should be noted that Russian legislation uses the term "exchange" rather than "barter". The structure of a barter contract, regulated by Chapter 31 of the Civil Code, does not provide for anything other than things to be used as the exchanged goods. The specific feature of DFAs is that they represent a specific object of civil legal relations that does not fall under the category of things. DFAs are the result of technological development and possess unique characteristics that distinguish them from traditional objects of property rights. They exist exclusively in a virtual environment and have no physical form.

Furthermore, Russian legislation does not yet provide a separate legal regime for barter contracts as applied to DFAs. Accordingly, the application of a barter contract could create legal conflicts and complicate the resolution of disputes.

The exchange of DFAs can be called their primary operation, as it may involve a range of legally significant actions. Unlike the issuance of DFAs, the exchange — and, consequently, the circulation — of digital financial assets is possible only on the secondary market, where investors (owners) act as sellers (donors, testators) rather than issuers.[8]

To exchange DFAs, it is necessary to:

Select a DFA exchange operator included in the Bank of Russia register;
Register on the operator's platform and undergo identification in accordance with the operator's rules;
Open a wallet for DFA accounting;
Submit an exchange bid through the operator's information system;
Wait for the matching of opposing bids (if required) and the execution of the transaction.

Not all DFA issuances allow circulation on the secondary market — this must be provided for in the DFA issuance decision. Furthermore, a counter-offer from another investor is required for the transaction to take place.

Pledge of DFAs and Digital Currency

A pledge is the most sought-after method of securing the performance of obligations in banking. The provision of liquid collateral is often a condition for lending and the issuance of bank guarantees. The question of accepting certain property as collateral is decided by banks primarily based on whether it is possible to foreclose on such collateral and its quick liquidation; these requirements also apply to digital rights.

The subject of a pledge is one of the essential conditions of a pledge agreement (Article 339 of the Civil Code); therefore, it must comply with the requirements established by civil legislation. Any property, including things and property rights, may be the subject of a pledge, with the exception of property on which foreclosure is not permitted, claims inextricably linked to the personality of the creditor (in particular, claims for alimony, for compensation for harm caused to life or health), and other rights the assignment of which to another person is prohibited by law (Article 336, Clause 1 of the Civil Code).

At the end of 2024, the Alfa-Bank platform introduced DFAs with a pledge to secure obligations under a contract. The mechanism works as follows: the information system user in whose favor the obligation is performed acts as the pledgee, and the investor — the DFA holder — transfers them into pledge until the full performance of obligations under the main contract. DFAs with a pledge to secure contract obligations allow for the establishment of clear conditions for the performance of obligations, which helps to better manage risks and avoid disputed situations. Upon violation of the terms of the main contract, ownership of the DFA automatically passes to the pledgee, and the assets themselves are transferred to their wallet via a smart contract. [9]

However, although the transfer of digital rights into pledge has become legally possible, the conclusion of such a pledge agreement seems risky for banks in practice.

Current legislation provides that property rights (claims) arising from an obligation of the pledgor may be the subject of a pledge (Article 358.1 of the Civil Code). Not all rules regarding the pledge of property rights can be implemented in relation to the pledge of digital rights.

For instance, a digital right may not be obligatory, such as digital currency. The rule of Article 368.3 of the Civil Code — requiring that a pledge agreement specify the obligation from which the pledged right arises and information about the pledgor's debtor — cannot always be applied. If the issuer of a digital currency is unknown, it will be impossible to specify the pledgor's debtor when pledging such digital currency.

One of the key principles of a pledge is publicity, i.e., the accessibility of information regarding the encumbrance of the pledged item to third parties. To implement the publicity of a DFA pledge, public accounting of the pledge is necessary. The issue of accounting for the pledge of digital rights is important because, in relation to movable property, a pledge arises for third parties only when they could learn about it from publicly available sources; otherwise, as a general rule, the pledge may terminate by virtue of Article 352 of the Civil Code (if the pledged property is acquired for value by a person who did not know and should not have known that the property was subject to a pledge).

Importantly, the Bank of Russia held discussions during the development of DFA circulation regulations regarding the inclusion of a section in the Law on DFAs governing the rules for formalizing a pledge or the transfer of rights of claim without a change of owner for the purpose of formalizing security for credit transactions, factoring transactions, and other types of obligations, and ensuring the access of creditors and potential creditors of DFA issuers/owners to information about existing restrictions in the form of pledge rights on DFAs. [10]

Inheritance of DFAs and Digital Currency

In accordance with Article 1112 of the Civil Code, the inheritance includes things and other property, including property rights and obligations, belonging to the testator on the day the inheritance opens. Inheritance opens upon the death of a citizen (Article 1113 of the Civil Code).

The inheritance of digital financial assets is carried out in the same manner as any other property, with the subsequent issuance of a certificate of the right to inheritance. If DFAs are present in the estate, which they enter from the moment the inheritance opens, the notary requests information regarding the DFAs from the information system operator. Rights to DFAs are confirmed by a corresponding entry in the information system.

In the event of the transfer of rights to digital financial assets by inheritance, the heir applies to the information system operator and provides the following documents:

The original or a notarially certified copy of the certificate of the right to inheritance (remains with the operator);
The original identity document of the heir;
The original or a notarially certified copy of a document confirming the rights of an authorized representative (if the heir acts through a representative);
The original or a notarially certified copy of an agreement on the division of inherited property (if any, remains with the operator).

If an agreement on the division of inherited property is provided, the operator makes a record of the transfer in accordance with the number of DFAs due to the heirs as specified in the agreement.

After receiving the certificate of the right to inheritance, the information system operator makes an entry in the register confirming the heir's right to access the information system and the DFAs.

Certain difficulties arise with the inheritance of digital currency. At present, the inheritance of cryptocurrency as a whole is not legally possible because it is impossible to reliably establish that the digital asset belonged to the testator. In other words, it is impossible to include cryptocurrency in the estate of the deceased until its ownership by the testator during their lifetime is proven. At the same time, the conditional transfer of cryptocurrency by a testator to their heirs is permissible by providing the relevant access rights through the inclusion of logins and passwords in a will or an inheritance contract. [11]

Thus, in order to leave property in the form of digital currency as an inheritance, the testator must write a will that contains all the necessary information about access to the account where the digital currency is held. This raises the question of whether it is possible to receive digital currency as an inheritance by operation of law. This is possible if the testator entrusted information about access codes and private keys to the heirs. [12]

Is the Gifting of DFAs and Digital Currency Possible?

DFAs are property rights, the gifting of which is not prohibited, provided the restrictions of Article 575 of the Civil Code (Prohibition of Gifting) are observed. The transfer of rights under a gift agreement must necessarily be conducted in the information system; otherwise, the obligation under the gift transaction is not considered performed, and the rights to the DFA do not pass from the donor to the donee.

How gifting is carried out:

Conclusion of a gift agreement in writing between the donor and the donee in accordance with the rules of Chapter 32 of the Civil Code;
The parties to the transaction (donor and donee) must be users of the information system;
The agreement is presented to the information system operator;
The operator accounts for the rights from the donor to the donee's wallet.

When gifting digital currency, the gift agreement must specify the wallet details to which the digital currency is to be transferred.

Circulation of Digital Currency

The legislator defines digital currency as a set of electronic data (digital code or designation) contained in an information system that is offered and/or may be accepted as a means of payment that is not a monetary unit of the Russian Federation, a monetary unit of a foreign state, and/or an international monetary or settlement unit, and/or as an investment, and in relation to which there is no person obligated to every holder of such electronic data, with the exception of the operator and/or nodes of the information system obligated only to ensure that the procedure for issuing these electronic data and performing actions to make (change) records in such an information system complies with its rules.

Thus, the legislator allows the use of digital currency as a means of payment or investment, but subject to established restrictions.

Mining of digital currency is its acquisition using special equipment and software. To engage in mining, Russian legal entities and individual entrepreneurs must be included in a specialized register of persons engaged in digital currency mining; [13] for individuals, energy consumption limits must be observed (no more than 6,000 kilowatt-hours per month). [14]

The Government of the Russian Federation, in cases and in accordance with the procedure established by it, is entitled to establish a ban on the mining of digital currency in individual subjects of the Russian Federation or in their specific territories (Article 14 of the Law on DFAs). For example, Government Decree No. 1869 dated December 23, 2024, established a ban on digital currency mining in specific Russian subjects and territories, specifying the subjects, territories, and timeframes.

Currently, a ban on digital currency mining (including participation in a mining pool) is established in the following subjects and territories:

In specific districts of the Irkutsk Region from April 7, 2025, to March 15, 2031;
In specific districts of the Republic of Buryatia and the Trans-Baikal Territory from January 1, 2025, to March 15, 2025; from November 15, 2025, to March 15, 2026; from November 15, 2026, to March 15, 2027; from November 15, 2027, to March 15, 2028; from November 15, 2028, to March 15, 2029; from November 15, 2029, to March 15, 2030; and from November 15, 2030, to March 15, 2031;
In the Republic of Dagestan, the Donetsk People's Republic, the Republic of Ingushetia, the Kabardino-Balkarian Republic, the Karachay-Cherkess Republic, the Luhansk People's Republic, the Republic of North Ossetia-Alania, the Chechen Republic, the Zaporozhye Region, and the Kherson Region from January 1, 2025, to March 15, 2031. [15]

Organizing the issuance of digital currency is defined as the activity of providing services aimed at ensuring the issuance of digital currency using domain names and network addresses located in the Russian national domain zone, and/or information systems whose technical means are located in the territory of the Russian Federation, and/or software and hardware complexes located in Russia (the "Russian Information Infrastructure Objects").

The issuance of digital currency is defined as actions using Russian information infrastructure objects and/or user equipment located in Russia aimed at providing third parties with the possibility of using digital currency.

Activities involving the provision of services aimed at ensuring the conclusion of civil law transactions and/or operations resulting in the transfer of digital currency from one holder to another using Russian information infrastructure objects constitute the organization of digital currency circulation.

Russian legal entities, as well as individuals who have actually been in Russia for at least 183 days during the year, are prohibited from accepting digital currency as payment for goods, work, and services. Such persons are entitled to judicial protection for any claims related to the possession of digital currency only if they have reported their possession of such currency and their performance of transactions and operations involving it.

The distribution of information regarding the offer and/or acceptance of digital currency as counter-performance for transferred goods, performed work, rendered services, or any other method suggesting payment with digital currency for goods (work, services) is prohibited in the Russian Federation.

Importantly, the Law on DFAs lacks a mechanism for the alienation and further circulation of digital currency; there is only an indication of the possibility of using cryptocurrency as a means of payment and investment, and the absence of a debtor under such an obligation. Currently, a legal framework has been created for the legal issuance of digital currency as a monetary instrument alternative to the national currency, and state control over its issuance and related activities has been established. However, further legal regulation specifically for the circulation of digital currency is required.[16]

In 2026, the Bank of Russia plans to develop and adopt legal acts regulating investment in cryptocurrencies, as well as to introduce administrative and criminal liability for the illegal circulation of cryptocurrency that falls outside the supervision of the Bank of Russia. [17]

According to the Bank of Russia's plan, investment in cryptocurrencies will not be available to everyone; furthermore, intermediaries in such operations must hold licenses. The Bank of Russia plans to grant investment access to so-called "super-qualified investors", defined as persons with assets of 100 million rubles or more or an annual income of 50 million rubles or more. Cryptocurrency transactions must be carried out through financial intermediaries who will receive special licenses for this purpose. Accordingly, activities falling outside the parameters designated by the Bank of Russia will be considered illegal, with corresponding consequences. [18]

Taxes on DFA Transactions and Digital Currency Circulation in Russia

The income of individuals from transactions with DFAs and digital currency is subject to PIT at a rate of 13% for income up to 2.4 million rubles or 15% for income exceeding 2.4 million rubles. Tax agents, which may include the information system operator or DFA exchange operator, perform the withholding and payment of PIT.

Digital currency is recognized as property for tax purposes. Digital currency mining constitutes a tax event and is recognized as the receipt of income in kind; the date of actual receipt is recognized as the date on which the person acquires the right to dispose of the digital currency (Articles 271 and 282.3 of the Tax Code). The amount of income is determined based on the market quotation of the digital currency on the date the income is recognized.

Mining income may be reduced by the expenses related to its performance. The resulting tax base is subject to PIT at rates ranging from 13% to 22% depending on the amount of income. For non-residents, PIT is paid at a rate of 30%.

Regarding legal entities, income from DFA transactions is included in the tax base at a rate of 20%. The sale of DFAs is not subject to VAT, but VAT may apply to transactions with hybrid digital rights.

Operations of legal entities related to mining are not included in the tax base for VAT (Article 146 of the Tax Code). For corporate profit tax purposes, the tax base for cryptocurrency operations is determined separately (Article 282.3 of the Tax Code). Digital currency obtained through mining is included in non-operating income (Article 250 of the Tax Code).

Organizations and individual entrepreneurs engaged in digital currency mining are prohibited from applying special tax regimes:

UAT – Unified Agricultural Tax;
STS – Simplified Taxation System;
ASTS – Automated Simplified Taxation System;
PTS – Patent Taxation System;
PITP – Professional Income Tax.

Thus, any actions provided for by the Civil Code may be performed with DFAs: buying, selling, exchanging, pledging, and transferring by inheritance. These transactions are conducted considering their digital nature, i.e., only within the relevant information system. Regarding digital currency, there is no legislative procedure for its circulation, and it cannot be used as a means of payment in Russia.

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References

Tumakov A.V. Digital Financial Assets as an Object of Digital Civil Circulation. Civil Law Journal, 2024, No. 6.
Ibid.
Bank of Russia Website. URL: https://cbr.ru/admissionfinmarket/register/.
Bank of Russia Regulation No. 779-P dated November 15, 2021, On Establishing Operational Reliability Requirements for Non-Credit Financial Organizations when Carrying Out Activities Provided for by the First Part of Article 76.1 of Federal Law No. 86-FZ dated July 10, 2002, On the Central Bank of the Russian Federation (Bank of Russia), in Order to Ensure the Continuity of Financial Services (Except for Banking Services).
Pavlova D.A. Legal Facts in the Implementation of Digital Rights. Civilist, 2024, No. 3.
Bank of Russia Ordinance No. 5635-U dated November 25, 2020, On the Characteristics of Digital Financial Assets, the Acquisition of Which May Only Be Carried Out by a Person Who Is a Qualified Investor, on the Characteristics of Digital Financial Assets, the Acquisition of Which by a Person Who Is Not a Qualified Investor May Only Be Carried Out within the Limits of the Amount of Funds Established by the Bank of Russia for Their Payment, and the Total Value of Other Digital Financial Assets Transferred as Counter-Performance, on the Specified Amount of Funds and the Total Value of Digital Financial Assets.
Decision of the Board of Directors of the Bank of Russia dated October 28, 2022, On the Levels of Credit Ratings Established in Accordance with Bank of Russia Ordinance No. 5635-U dated November 25, 2020.
Tatoyan A.A. Operations with Digital Financial Assets in Russia and Abroad: Concept, Essence and Features for Taxation Purposes. Education and Law Journal, 2022, No. 12.
Alfa-Bank Launched DFAs with a Pledge to Secure Obligations under a Contract. Press Release December 26, 2024. Official Website of ALFA-BANK. URL: https://alfabank.ru/news/t/release/alfa-bank-zapustil-tsfa-s-zalogom-dlya-obespecheniya-obyazatelstv-po-kontraktu.
Bank of Russia Answers to Questions (Proposals) from Banks Received within the Framework of the Annual Meeting of Credit Organizations with the Regulator's Management (Appendix to Bank of Russia Letter No. 03-23-16/6611 dated July 24, 2023). Association "Russia": Official Website. 2023. URL: https://asros.ru.
Ochirova P.I., Stepanenko A.S. Inheritance of Cryptocurrency: Features and Problems. Humanities, Social-Economic and Social Sciences Journal, 2022, No. 10.
Kirillova E.A. The Role of the Notary in the Inheritance of Digital Currency in the Russian Federation. Notary Journal, 2021, No. 7.
Government Decree of the Russian Federation No. 1464 dated October 31, 2024, On Approving the Rules for Maintaining the Register of Persons Engaged in Digital Currency Mining, and the Rules for Maintaining the Register of Mining Infrastructure Operators.
Government Decree of the Russian Federation No. 1469 dated November 1, 2024, On Establishing an Energy Consumption Limit during Digital Currency Mining (including Participation in a Mining Pool) without Inclusion in the Register of Persons Engaged in Digital Currency Mining by Individuals — Citizens of the Russian Federation who are not Individual Entrepreneurs, and on Amending Government Decree of the Russian Federation No. 117 dated December 29, 2011.
Government Decree of the Russian Federation No. 1869 dated December 23, 2024, On Establishing a Ban on Digital Currency Mining (including Participation in a Mining Pool) in Specific Subjects of the Russian Federation and in Specific Territories of Subjects of the Russian Federation.
Kamyshanova A.E. Digital Currency: Legal Regulation Novelties of 2024. Jurist Journal, 2025, No. 6.
The Central Bank Planned to Legalize Cryptocurrency Trading in 2026. October 9, 2025. RBC Portal.
Ibid.