What Is a Digital Depositary, and Who Is in the Bank of Russia Register?

Since September 1, 2026, the digital currencies law has been in force: only organizations from a special Bank of Russia list may provide services for recording clients’ cryptocurrency. They are called digital depositaries. For some existing market participants the law left a transition period until September 1, 2027.

If you want to keep cryptocurrency with such an organization, first check it against the Bank of Russia list.

We studied Law No. 282-FZ “On Digital Currencies and Digital Rights” and the Bank of Russia register. Below we explain what a digital depositary is, who is in the register and how to check an organization.

The main points:

• a digital depositary records clients’ cryptocurrency and helps them dispose of it, and only an organization from the Bank of Russia register may carry on a depositary’s activity (Art. 17(1) and (2) of Law No. 282-FZ);
• a depositary can be a Russian business company, and the Bank of Russia may set capital requirements and other conditions (Art. 43);
• the register listed nine organizations on November 8, 2026, among them Sberbank and VTB Bank;
• organizations that exchange digital currencies are entered in a separate register (Art. 52 and 54);
• existing market participants have a transition period: they can file documents with the Bank of Russia and bring their activity into line with the law until September 1, 2027 (Art. 55);
• if your cryptocurrency is held at a depositary, it can be arrested on a bailiff’s ruling, while the depositary must keep access keys secret and does not provide them on requests from state bodies (Art. 29(1) and (6)).

The provisions of Law No. 282-FZ are given from its official text on the legal information portal as of November 9, 2026, and the Bank of Russia register as of November 8, 2026 (00:00 Moscow time). We found no practice applying these provisions.

What Is a Digital Depositary?

Under Law No. 282-FZ, a digital depositary provides services of two kinds: it records and transfers digital currencies and digital rights, and it gives access to the identifier addresses where they are recorded (Art. 17(1)).

Put simply, it is an organization that keeps records of your cryptocurrency and carries out your instructions, that is, orders for operations with it, the way a bank keeps records of the money in your account.

The law uses the term “digital currency”, and below we write “cryptocurrency”. A depositary also records digital rights, including digital financial assets (DFAs): that is a different object, and here we speak only about cryptocurrency. The register does not show which services an organization from the register already provides to clients.

Terms from the law:

• depositor and access recipient: the depositary provides the first with recording services and gives the second access to an identifier address (Art. 17(3));
• digital account: an entry about cryptocurrency in the depositary’s system (Art. 22);
• identifier address: a sequence of characters, like a number, used to record credits and debits of cryptocurrency in an information system (Art. 2).

Who Can Be a Digital Depositary?

Only an organization included in the register of digital depositaries (Art. 17(2)). The Bank of Russia decides on entry into the register and keeps it (Art. 52(1) and Art. 54(1)).

It set the procedure for keeping the register in Instruction of August 27, 2026 No. 7429-U: it lists the data about an organization, including its name, principal state registration number (OGRN), taxpayer identification number (TIN), address, website, and the dates when the right to operate arose and ended.

What Does the Law Require From a Digital Depositary?

Main conditions:

• it is a Russian business company, for example a joint-stock company or a limited liability company (Art. 43(1));
• the main and backup hardware and software are located in Russia, and there is a backup system (Art. 43(6));
• the depositary identifies conflicts of interest and tells the client if it cannot prevent them (Art. 43(8) and (9));
• the Bank of Russia may set additional requirements, including the amount of own funds (Art. 43(3) and (4));
• the law sets requirements for the depositary’s governing bodies, employees and founders (Art. 49 and 50), and the depositary must join a self-regulatory organization (Art. 17(11));
• capital size and adequacy requirements do not apply to a depositary that is a credit organization (Art. 43(16)).

Capital. The Bank of Russia adopted Instruction of September 11, 2026 No. 7442-U on the own funds (capital) of a digital depositary. Under it a depositary’s minimum capital is 50 million rubles multiplied by a coefficient (para. 1.2):

• coefficient 5 for a settlement depositary;
• coefficient 2 for a depositary that gives access to identifier addresses, records cryptocurrency on addresses it administers itself, or opened an account with a foreign organization;
• coefficient 1 for the rest.

The text of the Instruction is posted on the Bank of Russia website, and we did not check its registration with the Ministry of Justice or its publication. Bank of Russia Regulation of September 11, 2026 No. 892-P sets requirements for a depositary’s activity and information system, and we did not go through it.

Transition period. Organizations that worked under the experimental legal regime, and information system operators entered in the register under the former digital financial assets law:

• may file documents with the Bank of Russia until September 1, 2027 to be entered in the register of depositaries (Art. 55(3) and (7));
• must bring their activity into line with the law no later than September 1, 2027;
• follow the requirements for transactions and operations from the day of entry in the register (Art. 55(4) and (8)).

The experimental regime programme stays in effect until the dates stated in it (Art. 55(1)). Other organizations, including new companies, may carry on a depositary’s activity only after entry in the register (Art. 17(2)).

Which Organizations Are in the Register of Digital Depositaries Now?

On November 8, 2026, the register listed nine organizations. In the Bank of Russia table this is the “date the right to carry on a digital depositary’s activity arose”.

The register on November 8, 2026:

• October 6, 2026: VTB Bank, Sberbank, JSC “Vaultary”, LLC “Atomyze”, LLC “Cloud Infrastructure”;
• October 12, 2026: LLC “TT”;
• October 14, 2026: LLC “Madrigal OIS” and LLC “Tokens”;
• November 5, 2026: JSC “Galoodin”.

The list is growing, with the latest entry dated November 5, 2026, so check the current table on the Bank of Russia website. Being in the register is not a recommendation: it only confirms that an organization may carry on this activity.

How Do You Check That an Organization Is in the Register?

Steps in order:

1. Open the register of digital depositaries on the Bank of Russia website.
2. Look at the date in the table heading: it shows the day the list was compiled.
3. Compare the full name, TIN and OGRN of the organization from your contract with the table.
4. Make sure the website address where you are offered an account matches the address in the register.
5. Check the depositary’s website: its terms of activity and tariffs must be posted there (Art. 23(5)).

If an organization is not in the table, it may not be a digital depositary (Art. 17(2)).

What Does a Depositary Do for a Client?

A depositary concludes a written digital recording agreement with a client (Art. 23(1)). The agreement may include the services listed in Art. 17(7): recording and transfer of cryptocurrency, opening accounts, carrying out your instructions, statements and reports, and access to identifier addresses.

What a client should know:

• the right to cryptocurrency is confirmed by a depositary statement for a stated day and time (Art. 22(8));
• the holder is the person on whose holder’s digital account the cryptocurrency is recorded (Art. 22(6));
• a change in tariffs takes effect no earlier than 15 days after it is posted on the website, except a tariff reduction (Art. 23(6));
• the depositary must keep access keys and client data confidential, and it gives the client and state bodies information without access keys (Art. 29(1), (2) and (6)).

How Is a Depositary Different From an Exchange Office and From Your Own Wallet?

By an exchange office we mean what the law calls an “organization exchanging digital currencies”.

Three options:

• A digital depositary. It keeps records of clients’ cryptocurrency and provides access to identifier addresses. Only a depositary may provide the access services (Art. 24(1));
• An organization exchanging digital currencies. The law treats such organizations as a separate type, and the Bank of Russia keeps a separate register for them (Art. 52 and 54);
• Your own wallet. If a depositary does not administer the identifier address, the holder is the person who has the access key and disposes of the cryptocurrency in their own name (Art. 24(3)).

If a depositary gave you access to an address, operations from it are possible only with the depositary’s consent (Art. 24(5)).

How Is a Depositary Connected With Debts and Arrest?

Cryptocurrency on your own holder’s digital account at a depositary is within a bailiff’s reach. The bailiff may request information from the depositary and impose an arrest (Art. 69(8.1) and Art. 82.1 of Law No. 229-FZ “On Enforcement Proceedings”).

What to know:

• Information. A depositary answers requests of enforcement bodies in cases provided by law, but does not hand over access keys (Art. 29(6));
• Nominee holder’s account. This is an organization that records other people’s cryptocurrency on its own account. The law does not allow arrest on such an account (Art. 82.1(1)). We do not see this as a loophole: the law prohibits only such an arrest and does not say how bailiffs will act otherwise.

From the moment it receives a copy of the arrest ruling, the depositary does not follow the debtor’s instructions and suspends operations with the debtor’s cryptocurrency within the amount of the debt (Art. 82.1(11)). The bailiff does not need the keys for this: the depositary suspends operations itself.

Arrested cryptocurrency is sold through a broker on an exchange (Art. 89 of Law No. 229-FZ).

We covered this in more detail in the articles Can Bailiffs Take Your Cryptocurrency? and How to Find and Collect a Debtor’s Cryptocurrency.

What Does the Law Leave Unregulated, and Which Questions Have No Answer?

The rules have been in force for two months, and some cases are not described in them:

• What happens to your cryptocurrency if the depositary is removed from the register? It must end its obligations under the contracts by the date the Bank of Russia sets (Art. 53(10)). For arrested cryptocurrency there is a procedure: it is transferred to a new depositary on the bailiff’s ruling (Art. 82.1(7));
• How much do a depositary’s services cost? The law refers to the depositary’s own tariffs (Art. 23(4)): each has its own, and we did not go through them. Of the Bank of Russia acts we read Instruction No. 7429-U on keeping the registers and Instruction No. 7442-U on capital;
• Must a depositary open an account for any client? The text of Law No. 282-FZ contains no duty to open an account for every client.

Is There Any Court Practice?

There is no practice to report yet under the new provisions: court acts from September 1 to November 9, 2026 do not mention a digital depositary under Law No. 282-FZ, but courts publish decisions with a delay. We found no position of the Supreme Court or explanation from the Bank of Russia on the articles about depositaries in open sources as of November 9, 2026.

How Can We Help?

We work in four steps:

1. You write to us in a messenger or leave a request on the site and briefly describe what happened.
2. We ask clarifying questions and request documents: the digital recording agreement, the depositary’s statement, the bailiff’s rulings.
3. After studying the documents we name the price, and we start work after payment.
4. You receive a written opinion signed by a lawyer. It sets out the legal position, an assessment of prospects and risks, the steps to take and a calculation of costs.

Next we can prepare a complaint and documents for court, and represent you in court. We name the terms and the price in advance. The consultation is written, so you do not need to come in: we work with clients from different regions.

We cannot promise a 100% result: the court, the bailiff or the depositary makes the decision, and we speak plainly about the prospects of the case.

Frequently Asked Questions

What is a digital depositary in simple terms? An organization from the Bank of Russia register that records clients’ cryptocurrency and carries out their instructions (Art. 17(1) and (2) of Law No. 282-FZ).

Where can I see the register of digital depositaries? On the Bank of Russia website, in the “Register of Digital Depositaries” table. On November 8, 2026, it listed nine organizations (Art. 54(1)).

Are Sberbank and VTB digital depositaries? Yes, Sberbank and VTB Bank are in the register of digital depositaries, and their right to operate arose on October 6, 2026.

Can a depositary give my keys to a bailiff? No. A depositary must keep keys confidential, and at the request of enforcement bodies it provides information “except for access keys” (Art. 29(1) and (6)). This does not cancel an arrest: the depositary suspends operations itself (Art. 82.1(11)).

Can cryptocurrency at a depositary be arrested? Yes, an arrest is imposed on the holder’s digital account on the bailiff’s ruling (Art. 82.1(1) and (2) of Law No. 229-FZ).

Read Also

• Can Bailiffs Take Your Cryptocurrency? What Changed on September 1, 2026: arrest, sale and the debtor’s protection;
• How to Find and Collect a Debtor’s Cryptocurrency: A Creditor’s Steps: where to take the document, what to ask the bailiff, deadlines;
• Someone Else’s Debts at the Bailiffs: What to Do If They Are Recorded Against You or Your Child: the order of action and how to contest someone else’s debts.

Is your cryptocurrency held at a depositary and you face an arrest, or do you want to collect it? Write to us on Telegram, WhatsApp or KakaoTalk at +7 (902) 899-07-58 or leave a request on the site. We will study the documents and name the price of the work.