As of September 1, cryptocurrency regulation in Russia has officially come into force. However, I would not rush to call this date the moment of the actual launch of the new market. In my assessment, based on an analysis of the current situation and the opinions of leading industry experts, the adopted law has only formed a legal framework. Within this framework, full-fledged exchanges, digital depositories, settlement infrastructure, and ready-made products from financial companies still need to be built.
Market participants have been given a transition period until July 1, 2027. That is why, in the coming months, it is far more interesting to watch not the loud statements from brokers about their readiness to work with digital assets, but how the infrastructure itself will be assembled. This will serve as a litmus test for the viability of the entire project.
Custody and separation of functions
The first and perhaps most problematic area is asset custody. The Russian model envisions the emergence of digital depositories that will record rights to cryptocurrency in much the same way securities are recorded today. This is no longer a side option but a separate regulated business.
The Central Bank has set capital requirements for such organizations ranging from 50 to 250 million rubles, depending on the functions performed. This significantly raises the entry threshold and turns custody into an independent line of business rather than an add-on to a trading platform. The key difference from the classic crypto market, where an exchange often simultaneously accepts client funds, executes trades, and holds assets, is that the Russian architecture gradually separates these functions among different participants.
For an investor, such a scheme potentially reduces infrastructure risks. However, for businesses, it makes launching a product more complex and expensive. This is a deliberate price paid for security.
Liquidity and asset range
The second critical issue is liquidity. The law permits organized cryptocurrency trading, and exchanges will be able to independently define trading modes and calculate market prices. But the mere existence of a trading platform does not yet create a liquid market.
This requires large participants, market makers, and access to a sufficient volume of cryptocurrency. Otherwise, the Russian price may diverge from the global one, and spreads may prove too wide for the mass client. The third constraint I see is the asset range. For non-qualified investors, the regulator proposes allowing only the most liquid cryptocurrencies with sufficient capitalization, trading volume, and a pricing history of at least five years. Therefore, at the initial stage, we are likely talking about a small set of major assets rather than the hundreds of coins familiar to users of crypto exchanges.
Product economics and the second stage
Finally, there remains the economics of the product itself. Financial companies will have to pay for custody infrastructure, compliance, trade execution, and meeting new regulatory requirements. The Bank of Russia has already proposed incorporating cryptocurrency risks into the financial stability ratios of market participants.
As a result, the main question for an intermediary will not be whether it can technically add BTC to its app, but whether it can do so at a commission the client deems competitive compared to a familiar crypto exchange. For this reason, September 1 should be viewed as the beginning of the second stage in the development of the Russian crypto market. The first stage was legislative: it defined who is entitled to work with cryptocurrency and under what conditions. Now begins a more complex period, when these rules must be turned into a functioning market infrastructure.
It is this stage that will reveal what the Russian regulated cryptocurrency market will look like. The law has already allowed it to exist, and participants must now prove that trading on it can be convenient, liquid, and economically sensible.
My conclusion: do not expect full-fledged crypto exchanges to appear in Russia overnight. The real test of strength will begin when the first depositories and trading platforms confront the issues of pricing and liquidity. Until 2027, we face a period of "gray zone," where traditional finance will slowly but steadily adapt to the new reality.