The recently enacted law "On Digital Currencies and Digital Rights" (282-FZ) classifies digital currency as property and establishes regulations for its circulation within Russia. This legislation creates a market with regulated intermediaries while maintaining a ban on using cryptocurrencies for transactions involving goods and services domestically. The new rules will be implemented gradually, with a transition period lasting until July 1, 2027.
In collaboration with SkyCapital, we explore what this means for everyday users and how the ecosystem operates: transactions via the Fast Payment System (FPS), the SkyPay card, and the launch of a proprietary exchange built on established infrastructure.
What Private Users Can Do
Store. The law does not require users to transfer all their existing cryptocurrency to a Russian custodian. Funds can remain in a non-custodial wallet, where the user retains control over the private keys.
Purchase through a regulated intermediary. This encompasses companies that the Bank of Russia will include in its registry, such as exchanges, brokers, or digital custodians. Legal cryptocurrency purchases will now occur through these intermediaries. An exchange sells coins in its own name, a broker buys them on behalf of a client, and a custodian manages the accounting.
To buy through an intermediary, residents must successfully complete a free test and be informed about associated risks. According to Article 31, these conditions also apply to qualified investors.
After the transition period ends on July 1, 2027, unqualified investors will only be able to access assets approved for public trading on Russian exchanges. They will also be subject to an annual purchase limit through a single intermediary, set by the Central Bank. In its guidance, the Central Bank indicates this limit will be 300,000 rubles per year (though the law itself does not specify this amount).
Article 1 maintains the prohibition on accepting cryptocurrency for payment of goods and services within the country, with some exceptions for foreign trade contracts, mining rewards, and network fees.
The main provisions of the law take effect on September 1, 2026, while the requirement to conduct transactions through authorized participants will be enforced starting July 1, 2027. These timelines are outlined in Article 56. Exceptions to the general rule are specified in Article 30, including those for foreign trade payments.
Who Will Be Considered a Regulated Intermediary After July 2027
The law defines several types of intermediaries: brokers, trust managers, trading organizers, digital custodians, and exchanges. Private users will most frequently interact with exchanges, which will be required to systematically buy and sell cryptocurrency in their own name and at their own expense off-exchange. "Systematic" means conducting two or more transactions a month with a total exceeding 3.5 million rubles.
A legal exchange must meet eight criteria:
- Russian legal entity. Only a business entity under Russian law (LLC or JSC) can operate as an exchange. Individual entrepreneurs and private persons will not qualify.
- Capital of at least 15 million rubles. This is the minimum amount of own funds required from exchanges that are not banks.
- Registration in the Central Bank's registry. According to Article 52, the right to operate begins on the day information is entered into the registry. Simply submitting an application does not grant this right.
- Membership in a self-regulatory organization (SRO). Violating this requirement can lead to removal from the registry.
- Servers located in Russia. Both primary and backup systems must be situated within the country, where the exchange also stores transaction data.
- Verified management and shareholders. Directors, board members, and stakeholders with over 10% ownership must meet specific business reputation criteria, with no criminal record for economic crimes allowed.
- Internal control. Exchanges must establish a robust internal control and risk management system.
- Publicly available data on their website. The company name, registration details, and inclusion in the Central Bank registry must be accessible to the public.
From July 1, 2027, clients will be able to distinguish a legal exchange by its procedures. It will conduct testing, provide risk notifications, and verify the cryptocurrency and addresses for any criminal activity before completing transactions.
Who Will Be Left Out
The law poses the most practical challenges for exchanges, many of which previously operated without a distinct legal framework, noted Andrey Tugarin, founder of GMT Legal, in a comment to ForkLog.
Until June 30, 2027, residents can continue to sell cryptocurrency systematically without being registered in the Central Bank. After this date, transactions with the following sellers will primarily pose risks to the user:
- Private P2P sellers. From July 1, 2027, residents must conduct cryptocurrency transactions through regulated intermediaries. Direct exchanges with other individuals will not meet this requirement.
- Exchanges not registered. A website, offer, and support via Telegram do not replace official status. After the transition period, the absence of a company in the Central Bank's directory will serve as a major warning sign.
- Services requesting transfers of rubles to individual bank cards. From July 1, 2027, banks will be required to refuse transfers to unauthorized recipients, meaning those facilitating cryptocurrency transactions without proper status. The Central Bank will maintain a list of such recipients.
- Foreign platforms lacking Russian status. Banks must reject cross-border transfers if the recipient's information indicates an illegal exchange. The Central Bank will include foreign payment services that residents use to transact with such platforms on this list.
- Entities on "stop lists." The Central Bank will deny registry inclusion for persons subject to blocking sanctions, foreign agents, organizations on terrorist lists, and those categorized as high risk by the regulator.
SkyCapital Ecosystem: Exchange, Trading, and Payments in One Place
SkyCapital is developing a comprehensive ecosystem for engaging with digital currencies, focused on the Russian market. It encompasses several interconnected areas:
- exchange with documentation for each transaction;
- cryptocurrency trading;
- payment products and interaction with external wallets (a non-custodial wallet can be linked to a card for payments in jurisdictions where permitted);
- business exchange services;
- fund inflow and outflow;
- international payment services.
Clients can manage all digital currency-related tasks in one place. According to the company, the platform has over 50,000 users and hosts 25 exchange services on its payment infrastructure.
One Company in the Statement: How Exchange Works via FPS
The core of the ecosystem is an online exchange tailored for those wishing to conduct transactions legally and without unnecessary risks:
- miners;
- travelers;
- professionals receiving salaries in cryptocurrency from foreign organizations;
- businesses;
- traders seeking the best rates for USDT, Bitcoin, and other popular coins.
The ruble portion of the transaction is processed through FPS acquiring by the platform's legal entity, eliminating transfers between individuals. The banking history reflects payments made to the company, and documentation links the payment to the exchange request. The platform provides these for the Federal Tax Service.
Abandoning P2P does not make exchanges more expensive. According to the company, in the "white" segment, the exchange consistently ranks among the leaders for USDT, Bitcoin, Ethereum, and other popular coins on BestChange and Exnode monitors.
This model is described by the team in their blog. ForkLog also analyzed it in a separate article regarding the SkyCapital exchange infrastructure.
To get started, users need to register and complete KYC. They can then fund their balance through FPS or bank details.
The exchange operates on a market-based model. In the "Markets" section, there is an order book: users can purchase at the market rate or place a limit order at their desired price and wait for a counter-offer. Instant exchanges of rubles for USDT up to 2000 USDT are available around the clock. The platform also supports ruble pairs with Bitcoin, Ethereum, and USDC.
For AML control, the company employs the BitOK service. The platform does not accept high-risk cryptocurrency for exchange. Each transaction provides the client with a request, report, and banking document.
SkyPay: How Cryptocurrency Becomes a Ruble Payment
In light of the ban on using cryptocurrency for payments within the country, SkyPay employs conversion before payment. Users connect their non-custodial wallets on the Solana network: Phantom, Solflare, Trust Wallet, or Ledger. According to SkyPay's description, coins remain in the user's wallet until purchase, and private keys and seed phrases are not shared with the service. The exchange is conducted by an agent outside Russia, and the seller receives rubles. The SkyPay website offers a "Mir" card and payments via FPS QR codes.
The spending limit is determined by the level of identification. For simplified identification, an email or phone number, full name, series and number of the passport are required.
Cash withdrawals, transfers to cards, or by phone number through SkyPay are not allowed. Deductions occur within the authorized spending limit, which users set and confirm themselves. They can reset this limit at any time.
Build Your Own Exchange in 7-14 Days
Another aspect of the ecosystem is designed for entrepreneurs. Using a white-label model, SkyCapital can set up a ready-to-use exchange infrastructure under a partner's brand. This includes a customer storefront, back office, FPS acquiring, and mandatory KYC and AML procedures. The partner is responsible for the legal aspects of launching, including obtaining status in the Central Bank registry.
The launch takes 7-14 days and costs $4000, with ongoing support costing $600 per month. According to the company, developing a custom solution from scratch would require at least 10 million rubles and several months of work.
For existing platforms with a ready website and team, the company offers API integration. This connection is free, and partners can set their own fees for their clients. Terms can be discussed with a manager via Telegram.
Five Questions to Ask Before Transferring Funds
This checklist is useful when choosing any platform:
- Who receives the rubles? Verify the legal entity name, TIN, and payment details in the offer with the payment recipient. Check the Russian company in EGRUL.
- What are the fees and final amounts? Clarify the exchange rate, service fees, and banking/network charges. Compare the total amounts deducted and credited.
- What documents will remain after the transaction? Ensure availability of the request, executor's report, bank statement, and transaction hash for blockchain transfers.
- What happens during additional AML checks? Find out in advance what documents may be requested, how long the verification takes, and how funds are returned if the exchange fails.
- Where can the coins be withdrawn? Confirm supported networks, recipient wallet requirements, and withdrawal restrictions.
Until July 1, 2027, these five points serve as a substitute for the registry. Currently, no one has formal approval, so users must rely on documentation, fees, and what appears in bank statements.
After this date, the choice will narrow automatically. Only companies from the registry that meet capital, infrastructure, and SRO membership requirements will retain the right to conduct transactions. The SkyCapital ecosystem responds to this with three products: exchange via FPS with a banking trail for each transaction, payments through SkyPay without using cryptocurrency domestically, and white-label technical infrastructure for those wishing to launch an exchange under their brand.
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