A Debtor or No Debtor: What Actually Separates a Digital Financial Asset from Digital Currency

A digital financial asset (DFA) and a digital currency share a word in their names, and for a long stretch of time they shared a single statute as well. A DFA is a digital right: a claim against a specific person who has undertaken to pay money, to transfer rights under securities, or to grant a share in capital. Behind a digital currency — what everyday speech calls cryptocurrency — there is no obligated person at all, and its price is backed by nothing. Everything else grows out of that one difference: which rule applies, who keeps the record, who is allowed to buy, and how the tax is computed.

What follows is a structural comparison, not a verdict on which is better. Which intermediaries a resident may buy digital currency through, and under which rule, is covered in our reference piece on buying cryptocurrency legally. How a DFA issue is actually structured is covered in the piece on digital financial assets.

A claim on an issuer versus property with no debtor

The DFA is defined by Federal Law No. 259-FZ of 31 July 2020. It is a digital right — a monetary claim, rights under issue-grade securities, or a share in the capital of a non-public joint-stock company. Its terms are written into the decision on the issue, and that document names the issuer — that is, the party who owes. A DFA holder therefore carries the same credit risk as a bondholder: the question is whether one particular company will perform. What that looks like in practice is set out in the piece on DFA risks.

Digital currency, from 1 September 2026 onward, is governed by Federal Law No. 282-FZ of 4 August 2026 "On Digital Currencies and Digital Rights"; before that it was governed by the same Law No. 259-FZ. Digital currency is recognised as property: you may own it. Using it inside Russia as a means of payment, or as consideration for goods, work or services, is prohibited, and the new law preserves that prohibition. There is no decision on an issue naming a debtor. The price of a digital currency is not guaranteed, and no insurance scheme exists for it — the law does not change that. More detail sits in the piece on the legal status of cryptocurrency.

Reading the terms of a DFA, a buyer is appraising a debtor: its borrowings and its record of meeting obligations before. With a digital currency there is nobody to appraise. There is only the price the next buyer is willing to pay.

Who makes the record of your right

A DFA is issued through an operator of an information system drawn from the Bank of Russia register, and the record is kept inside that system on a distributed ledger. Trades after placement run through a DFA exchange operator, which likewise sits in the Bank of Russia register. A DFA is not a security, there is no depositary accounting for it, and the asset lives inside the platform where it was issued: it cannot be moved to another operator the way a security moves between depositaries.

For digital currency, Law No. 282-FZ names the parties through which a resident may transact: digital currency exchanges, brokers, asset managers, depositaries and exchange services. The Bank of Russia maintains the register. The requirement to transact only through such intermediaries takes effect for residents later than the baseline provisions — under the law, from 1 July 2027. Exactly how an intermediary accounts for a client's digital currency is set by the contract with that client and by the regulator's acts; the operative version has to be checked against the source.

A DFA operator is the place where the asset exists. An intermediary in digital currency transactions is the doorway to the asset; that status does not make it the obligated party on the digital currency itself, and its duties toward the client are defined by contract.

Who gets access, and what the cap is tied to

For DFAs the rules are set by Bank of Russia Regulation No. 7176-U of 23 September 2025, in force from 1 January 2026. A non-qualified investor may buy, with no cap on the amount, DFAs whose payout does not depend on variable indicators, provided the issuer carries a high credit rating; the rating levels are set by the Bank of Russia Board of Directors. DFAs whose return depends on inflation, the key rate, the price of a precious metal or of a share are available within RUB 600,000 per year, and the allowance is restored on redemption or sale. All other issues are reserved for qualified investors.

Access to digital currency opens for a non-qualified investor after testing, and only within a restricted list of the most liquid digital currencies; the list and the criteria are determined by the Bank of Russia. Purchases are capped at RUB 300,000 per year with a single intermediary. That figure comes from a draft Bank of Russia regulation published on 11 August 2026, not from an act in force, so the operative version has to be checked. A qualified investor faces no such cap. The steps are described in the piece on buying cryptocurrency as a non-qualified investor.

The logic of the filters follows from the first section. For a DFA, access is tied to the properties of the issue: the structure of the payout and the rating of the debtor. For a digital currency there is nobody to rate, so the filter attaches to the asset itself — whether it made the list — and to the amount. A category of "no cap on the amount" for a non-qualified investor is not named in the provisions and draft regulation we checked.

Tax: one scale, two sets of rules

The rates coincide: 13% within an annual base of RUB 2.4m, and 15% above that threshold. The procedure is where they part.

Transactions in DFAs are carved out into a separate tax base. The tax agent is the information system operator or the exchange operator through which the payment passed. Investment deductions — the individual investment account deduction and the long-term holding deduction — do not apply to DFAs, and a loss on a DFA does not reduce a profit on securities. That is how Article 214.11 of the Tax Code works, in force since 2023; the rules taxing digital currency are written in a different law. A step-by-step calculation is in the piece on DFA taxation.

Income from the sale of digital currency is taxed under Federal Law No. 418-FZ of 29 November 2024. Purchase costs reduce the base where they are documented, and transactions in digital currency are not subject to value added tax. The individual files the tax return themselves if no intermediary acting as agent withheld the tax. Purchase documents here become part of the computation: without them, the costs will not reduce the base. Details are in the piece on tax on cryptocurrency sales.

Whether a loss on digital currency can be offset against a profit on DFAs or on securities is not addressed in the provisions we checked, and we will not assert either answer.

What of this is visible in TradeAlmanac

We do not carry DFA issues. We do carry bonds, and that helps from the other side: a company that borrows through DFAs may also borrow through bonds. In that case its issues sit in the bond section, and payment failures show up in the feed of defaults and technical defaults. If the debtor has no bonds outstanding, there is nothing in our data to check it against.

On the digital currency side we have a coins section with prices, capitalisation and history. It is a reference section: no trades are executed through the site. It shows exactly what a digital currency has — a price and that price's past. The absence of information about a debtor there is not a gap in the data: under the law, a digital currency has no obligated person.

Where this comparison stops holding

The law is mid-transition. Law No. 282-FZ introduces a new regime for digital rights and replaces Law No. 259-FZ in stages. For DFAs, the operative version has to be checked as of the transaction date. The cap for digital currency is so far known only from a draft regulation.

This is about legal constructs, not about every asset with a similar-sounding name. Whether a given asset is a digital currency or a digital right is settled by the law and by Bank of Russia acts, not by the seller's description. If the asset's terms name a party obliged to pay, the first thing to establish is which provision it was issued under.

Having a debtor is not a guarantee of payment. The issuer of a DFA is someone you can make a claim against, not a promise that it will pay. Conversely, the absence of a debtor behind a digital currency says nothing about where its price will go; that is the subject of the piece on the risks of buying cryptocurrency.

One question is left for each reader to answer alone: what are you appraising — a debtor's ability to pay, or the next buyer's willingness to bid? The answer decides which documents you need to read.