DFA risks: whose obligation you are buying and where you cannot sell it

The buyer of a DFA receives a digital right against a specific issuer, and if that right is a monetary claim, the main risk is the same as with a bond: the debtor may not pay. Everything else is different. The record of the right exists only in the information system of the operator where the asset was issued, the asset has no exchange order book, and the law under which it was created is being replaced by a new statute in stages. Hence the list: issuer risk, platform risk, liquidity risk, payout-formula risk and legal-transition risk.

The foundation is Federal Law No. 259-FZ of 31 July 2020: a DFA is issued and recorded in an information system built on a distributed ledger, and its terms are set out in the issuance decision. The instrument as a whole is covered in the article on what digital financial assets are. Here we deal only with what can go wrong, and with the signs by which it can be seen before the trade.

There is one debtor, and the form of the asset does not change that

A DFA with a monetary claim is an obligation of the issuer named in the issuance decision. The platform keeps the record of the right, but it is the issuer that has to pay on it. So the first question is the same as for a bond. This is credit risk — the probability that the debtor will delay a payment or not make it at all.

The access rules themselves point to this risk. Under Bank of Russia Directive No. 7176-U of 23 September 2025, in force since 1 January 2026, a non-qualified investor may buy without any limit on the amount only DFAs whose payout does not depend on variable indicators, and only where the issuer has a high credit rating. The rating levels are set by the Bank of Russia's board of directors. Even so, a rating remains an assessment of the debtor, not a promise of payment — the distinction is explained in the article "Credit rating: what it measures and why it is not a guarantee".

Our data contain no DFA issues — neither prices nor issuance decisions. We do, however, cover bonds, and if the same issuer also borrows in the bond market, it can be checked: missed payments show up in the feed of defaults and technical defaults, the issues themselves in the bonds section, and events affecting its securities in the corporate events calendar.

A missed bond payment does not turn into non-payment on a DFA by itself: the link between debts is set by the terms of each issue, and whether an issue contains a cross-default clause is something to be read in the issuance decision. But a debtor that has missed a payment on one debt is still the same debtor. And if the issuer has no bonds, our feed is silent about it, and that silence is an absence of data, not a sign of reliability.

What does not come with the obligation

A DFA is not a security, and with that status the familiar surroundings of a bond disappear. The issue has no prospectus. Rights to it are not recorded with a depository. There is no issuer disclosure under securities-market rules either: in its place is the issuance decision on the operator's website.

There is, then, one core document, and that is where the answers have to be found. Whether there is collateral or a guarantee. What counts as a breach by the issuer. What actions are open to the holder if a payment is overdue. For bonds, our glossary describes the bondholders' representative for this situation; whether anything similar is provided for in a particular DFA issue is determined by its terms and by the law, and it is the version currently in force that needs to be checked.

Record-keeping, disclosure and holder protection for the two instruments are compared in the article on how a DFA differs from a bond.

The platform is the only place where the asset exists

An issue is carried out through an information system operator listed in the Bank of Russia's register, and the asset lives inside the system in which it was issued. It cannot be moved to another operator the way a security is moved between depositories. A bondholder has a fallback — to change intermediary and take the securities along; the holder of a DFA has no such route.

The glossary calls this infrastructure risk: the trouble comes not from the debtor but from the link through which record-keeping and settlement pass. The first check is simple in form — the operator must appear in the register that the Bank of Russia publishes on its website. What happens to the records of rights if the operator ceases its activity, this article does not claim to say: the procedure is determined by the law and by the rules of the information system.

Exit before maturity: a narrow door

A DFA does not trade on an exchange in a conventional order book. Secondary-market trades go through a DFA exchange operator, likewise included in the Bank of Russia's register, and a counterparty has to be found inside the same platform. Liquidity risk here is made up of two unknowns together: whether a buyer will turn up and what price that buyer will name.

Hence the question the buyer has to answer before the trade: are they prepared to hold the asset to maturity if it proves impossible to sell it earlier? For bonds, market depth is assessed in advance — exactly how is described in the article "Portfolio liquidity risk: how long the exit will take". For DFAs we have no such measurement: we do not see trades in them. Secondary trades themselves are covered in the article on the secondary market for DFAs.

Formula-based income: a risk the regulator has singled out

If the payout depends on inflation, the key rate, the price of a precious metal or a share, the risk of the formula itself is added to the risk of the debtor. The issuer may perform its obligation in full, and the amount may still turn out smaller than the buyer was counting on.

Directive No. 7176-U draws the line exactly here. Such DFAs are available to a non-qualified investor within a limit of RUB 600,000 a year, and the limit is restored on redemption or sale. Everything that falls outside the categories named is for qualified investors only; what that status gives is described in the article "Qualified investor status: what it opens up and what it costs". The cap restricts the amount of the purchase, not the risk of the issue.

The rules change while the issue is still outstanding

Federal Law No. 282-FZ of 4 August 2026 "On Digital Currencies and Digital Rights" introduces new regulation of digital rights and replaces Law No. 259-FZ in stages. For the holder this is regulatory risk in the literal sense: an asset bought under one version of the law may be redeemed under another. Which provisions change for DFAs, and at which stage, this article does not specify — the transition is phased, and the version to check is the one in force on the date of the trade.

The tax side of the risk is already known. Under Article 214.11 of the Russian Tax Code, transactions in DFAs form a separate tax base: a loss on them is not offset against gains on securities, and investment tax deductions do not apply to DFAs. The calculation, and the operator's role as tax agent, are covered in the article on the taxation of DFAs.

When this list is incomplete or does not apply

Everything said above relates to DFAs that certify a monetary claim. The law also classes as DFAs rights under issue-grade securities and participation in the capital of a non-public joint-stock company. A description in terms of "the debtor will not pay" does not fit such assets, and their risk is not analysed here.

The access rules are set out according to the directive in force since 1 January 2026; the limit is shown together with its source and the date it was verified, and after that date it is the current text that should be read.

Checking the debtor through its bonds works only where bonds exist. An issuer that borrows exclusively through DFAs is not visible in our data at all, and it has to be judged by the issuance decision.

Finally, the instrument is a poor fit for a goal in which the money may be needed ahead of schedule: the exit depends on whether a buyer can be found within one platform.

That leaves the questions only the buyer can answer. Who is the debtor, and what is known about it beyond the issuance decision? Is the operator listed in the Bank of Russia's register? What does the size of the payout depend on?