Digital Financial Assets: A Claim Recorded on an Operator's Platform, Not a Security

A digital financial asset (DFA) is a digital right that is issued and recorded not in a depository but in an information system built on a distributed ledger. In the form most comprehensible to a retail investor, it is a monetary claim: a company has taken money and undertaken to return it with a return, on the terms written into the decision to issue. The legal foundation is Federal Law No. 259-FZ of 31 July 2020 "On Digital Financial Assets, Digital Currency…". A DFA is not a security, and almost every difference between it and a familiar bond follows from that single circumstance.

A word at once about the limits of this text. TradeAlmanac does not carry DFA issues: we cover bonds, and through them you can check the same debtor if it also borrows on the exchange. Where to look for the issues themselves, and how our sections help while you do, is set out below. The particular questions — the comparison with a bond, buying, tax, risks, selling before redemption — are handled separately, and the links sit where the question arises.

What right stands behind the ledger entry

The law names the rights that may be structured as a DFA: a monetary claim, rights under issue-grade securities, and participation in the capital of a non-public joint-stock company. The label "digital financial asset" itself tells you nothing about which of these you are looking at. That is told by the decision to issue — the document in which the issuer writes down the terms: what it undertakes to do, when, and what the payment depends on.

From this follows the first distinction worth holding on to. The distributed ledger is a method of recordkeeping: an entry in it confirms that the right belongs to you. What pays under that right is neither the ledger nor the operator, but whoever issued it. The technology answers the question "whose is this"; the question "will I be paid" is answered only by the debtor's financial position. This is also what separates a DFA from digital currency, with which it is often confused because of the similar wording: a digital financial asset has an obligated person behind it, digital currency has none.

That is why reading a DFA begins with the same questions as reading any debt. Who is obliged? What exactly has been promised? Does the payment depend on an external indicator? What backs the obligation? The answers are in the decision to issue, and they may well be absent from the marketing description of the offering.

The system operator and the exchange operator: who holds the record

A DFA is issued through an information system operator — an organisation entered in the Bank of Russia's register. Transactions between investors after placement pass through a DFA exchange operator, which is likewise entered in a Bank of Russia register. The regulator publishes both registers on its website, so the first check requires no trust in anyone's word: is the platform offering you the asset actually in the register?

This design has a consequence that securities do not have. A security is recorded by a depository, and it can be transferred from one depository to another by changing intermediary. A DFA lives inside the platform where it was issued: it cannot be moved to another operator. It does not trade in the common order book, so the question "who will I sell this to before redemption" is resolved by the rules of the specific platform and by whether a matching buyer turns up on it. How a sale works and why it may fail to happen is covered in the piece on the secondary market in DFAs.

The same debt, a different shell

If a monetary claim stands behind a DFA, then economically it is close to a bond: you lend money and wait for it to come back with a return. The credit risk is the same — it is an obligation of a specific issuer, and the shell neither reduces nor increases it. What differs is everything around the obligation.

• Legal nature. A bond is a security, a DFA is a digital right. The rules familiar from the securities market cannot be assumed to apply by default: each one has to be checked.
• Documents. A DFA has no prospectus. The terms are written in the decision to issue, which is posted on the operator's website.
• Disclosure. A DFA issuer does not disclose information under securities-market rules: the mandatory stream of announcements that accompanies an exchange-traded issue does not exist for a digital right.
• Recordkeeping. Instead of depository accounting — an entry in the operator's system.
• Trading. Instead of an exchange order book — transactions inside the platform.

Taken one at a time, each line looks like a technical detail. Taken together, they mean that the supports a bondholder is used to — public announcements from the issuer and an exchange price that shows how the market regards its debt — are either arranged differently for a DFA or absent altogether. A detailed comparison across recordkeeping, disclosure, liquidity, holder protection and tax is in the piece on choosing between a DFA and a bond.

Which issues are open without qualified investor status

Access is set by Bank of Russia Directive No. 7176-U of 23 September 2025. It has applied since 1 January 2026 and replaced Directive No. 5635-U of 25 November 2020, so texts written before that date describe the former regime. The dividing line runs along how the payment is structured, and for issues without a cap on the amount, also along the issuer's credit rating.

1. Without any cap on the amount, a non-qualified investor may buy DFAs whose payment does not depend on variable indicators — provided the issuer holds a high credit rating. Which rating levels count as sufficient is established by the Bank of Russia Board of Directors.
2. Within an annual limit — DFAs whose return depends on inflation, the key rate, the price of a precious metal or of a share. The ceiling is RUB 600,000 per year; once an asset is redeemed or sold, the limit is restored.
3. For qualified investors only — every other issue.

It follows from this ladder that a single issuer may have both an issue open to everyone and an issue closed to a non-qualified investor: the payment formula decides. And one more thing: admission is not an assessment of soundness. The regulator caps the asset's complexity and the amount, but does not promise that the issuer will pay. What the purchase route looks like, how the ceiling is counted and what to read in the decision to issue before the deal is covered in the piece on how to buy a DFA.

Tax is calculated separately from securities

Transactions in DFAs have their own tax base: the result on digital rights is counted on its own, not together with shares and bonds. The rates are the same as for investment income generally: 13% while the annual base does not exceed RUB 2.4m, and 15% above that threshold. The tax is withheld by the tax agent — the information system operator or the exchange operator through which the payment passed. This whole regime is written into a separate provision that has applied since 2023: Article 214.11 of the Tax Code.

A separate base is not a formality; it has practical consequences. A loss on DFAs does not reduce a profit on securities: netting, familiar within a brokerage account, does not cross that boundary. Nor do investment deductions apply to DFAs — neither individual investment account deductions nor the long-term ownership relief. So a DFA cannot be compared with a bond on the headline rate alone: for a security held in a tax-advantaged account, or held long enough, the after-tax outcome is computed under different rules. How the base works, who withholds the tax and what this regime lacks is in the piece on tax on DFAs.

Where to look for issues, and what we show about the debtor

DFA issues are viewed where they were issued. The list of information system operators and exchange operators is in the registers on the Bank of Russia website. The issues themselves, and the decisions behind them, are on the operators' websites.

TradeAlmanac does not carry DFA issues — no terms, no prices, no payment history, and we do not pretend otherwise. We cover bonds, and that is useful for one reason: the debtor on a DFA and the debtor on a bond are one and the same person. If an issuer also borrows on the exchange, its public footprint sits with us in several places.

• The bonds section — exchange-traded issues, among which you can find paper from the same issuer. The yield the market demands on its bonds is an independent assessment of the same credit risk; comparing a DFA rate against it makes sense only with an adjustment for the difference in exit and tax.
• The feed of defaults and technical defaults — disclosed cases of failure to meet bond obligations. An issuer that has missed a payment on a security remains the same debtor on its digital rights.
• The events calendar — coupon, redemption and put dates on bonds, and reporting publication dates. This is a general list of upcoming dates across the whole market with a choice of event type, not a page for a single issuer.

Such a check has limits, and it is better to know them in advance. It speaks about the debtor, not about the issue: the collateral, the ranking and the payment formula of a particular DFA are written only in its decision to issue. And it is not always possible: an issuer that has never come to the exchange with bonds leaves no trace in our sections. What remains to lean on then is the decision to issue and whatever the issuer says about itself. The absence of such an issuer from the defaults feed proves nothing — it could never have appeared there in the first place.

What the holder risks besides the rate

The risks of a DFA are assembled from what has already been named, and it is useful to see them side by side.

Credit risk is the principal one and nothing new: the issuer pays, and if it cannot, the ledger entry remains an entry about an unperformed right. Liquidity risk is harsher for a DFA than for exchange-traded paper: the asset is locked inside its platform, and you may not be able to get out of it at all before redemption. Information risk follows from the absence of disclosure under securities-market rules: if the issuer has no exchange-traded securities either, there may be no mandatory public stream of announcements about it whatsoever. Finally, there is the risk of the platform itself: the record of your right is maintained by the operator, and what happens to it in the event of a failure or of the operator leaving the market is determined by the law and by the rules of the system — which are read before the purchase, not after.

The rating that opens an issue to a non-qualified investor does not remove these risks: a credit rating is an opinion, not a guarantee. How each of the risks shows up, and by what sign it is visible before the deal, is covered in the piece on the risks of DFAs.

When this stops being true, and whom DFAs do not suit

The legal foundation of DFAs is currently in motion. 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. The transition is phased, so the question of which provision is in force on the day of your transaction is answered by the current wording of the law, not by this text. The same applies to access: the rating levels for issues without a cap on the amount are established by the Bank of Russia Board of Directors, and they are to be verified as at the purchase date. The size of the annual ceiling is given as at the date this material was prepared. And the rules of a particular platform — fees, the order of transactions, the terms for withdrawing money — are determined by the contract with the operator, and there is no general answer to them.

There are situations in which a DFA fits an investor's task badly.

• The money may be needed before redemption. The exit depends on a buyer on the same platform, and there may not be one.
• The calculation rests on tax relief. DFAs have no individual investment account deductions and no long-term ownership relief.
• Losses and profits need to come together in one result. A loss on a DFA will not reduce a profit on securities.
• A public footprint for the debtor is required. Without exchange-traded bonds from the issuer, it cannot be checked through our sections.
• The payment formula is unclear. Tying the return to inflation, the rate, a metal or a share changes both the outcome and the access category.

Everything said here comes down to a question that does not depend on the technology: who exactly are you lending to, and what do you know about them beyond the promised rate?