The Central Bank of Russia adjusted the way individuals qualify as “qualified investors” before the regulated encrypted market was launched. The new regulation introduces a new localized test path whereby an individual can be recognized as a qualified investor by a voucher or institution, provided that he has passed an accredited financial knowledge examination and submitted a designated certificate. This means that in the future more Russian investors will receive higher levels of access to encrypted assets.

New indigenous test path from August 31

According to the Russian Central Bank, the new arrangement will enter into force on 31 August. Applicants can apply for eligibility on the basis of a Russian local certificate obtained after the examination and no longer rely solely on international gold financing.

  • Qualifin Certificate issued by the National Finance Institute
  • MOEX investor certificates issued by the Moscow Exchange
  • Certificate of Financial Analyst, National Finance Institute, etc.

The Central Bank indicated that it was in possession of either of the above-mentioned certificates, on which the voucher or management company could identify the individual as a qualified investor.

Continuation of the criterion of original determination

The adjustment did not eliminate the existing criteria, but rather added a new designation to the original one. Previously, investors who applied for qualifications based on educational or professional background were usually required to submit international certification covering areas such as financial analysis, investment advisers, asset management or risk management, and the CFA was one of the previously acceptable qualifications.

In addition to the new examination path, individuals can still apply for qualified investors based on income over the past two years, minimum asset size, relevant experience in the securities market, independent investment experience, relevant academic qualifications, or combinations of conditions.

Mikhail Mamuta, Vice-President of the Russian Central Bank, stated that the regulators did not pursue an increase in the number of qualified investors on paper, placing greater emphasis on whether investors really understood the risks of complex financial instruments.

Encryption purchase amount by investor status

This adjustment is close to Russia's newly adopted encryption market time frame. In accordance with the rules previously disclosed, the Russian Federation has incorporated encrypted asset transactions into the regulated system, with the central bank of Russia being responsible for market supervision.

  • Unqualified investors have an annual purchase cap of 300,000 roubles
  • Qualified retail investors have an annual purchase cap of 3 million roubles
  • The difference is 10 times.

When the Russian Parliament considered the bill in July, it retained a ceiling of 300,000 roubles for ordinary investors, while eliminating the proposal to require the holder to declare the address of the encrypted wallet. The revised version shifts the focus of the declaration to information such as balances and volume of transactions.

In addition, the Act allows for the use of encrypted assets for the purchase of Russian securities and digital financial assets, but some large transfers abroad or to third parties may be delayed by up to two days.

The bank is preparing for a compliance encryption operation.

As the legal framework approaches its implementation, large Russian banks have begun to prepare the services. The Savings Bank of the Russian Federation plans to introduce, by 1 December, a secure trade infrastructure and digital hosting services covering transactions, hosting, settlement and storage.

Alpha Bank has also tested encryption transactions with a small number of qualified investors in its Alfa-Investments voucher application. The bank indicated that wider access remains dependent on the completion of accompanying regulatory documents by the Russian Central Bank.

Additional information:As previously reported, the new encryption framework in Russia is expected to be launched on 1 September and market participants are required to meet licence requirements by 1 July 2027. Alpha Bank expects that, if regulation goes well, the official start-up time for a wider retail customer may be close to the fourth quarter of 2026, while Russia’s regulated encrypted market creates greater liquidity or waits until the end of 2027.