Who is vying for SRO status in the cryptocurrency exchange market? Why are they needed?

In Russia, self-regulatory organizations (SROs) for cryptocurrency exchanges will be established. This requirement comes from the law "On Digital Currencies and Digital Rights," which will gradually come into effect starting September 1.

The new rules set requirements for exchanges. They are recognized as entities conducting two or more transactions totaling over 3.5 million rubles per month. Such exchanges can operate only if they are included in a special register maintained by the Central Bank. Among other conditions are a minimum capital of 15 million rubles, strict requirements for personnel and management, accounting practices, and the placement of primary and backup software within Russia.

Cryptocurrency exchanges will also be required to join a self-regulatory organization (SRO) in the financial market (Article 18, paragraph 9 of Federal Law 282-FZ). These SROs do not yet exist, but industry participants are actively preparing for their emergence.

Experts told RBC-Crypto about which self-regulatory organizations will start operating in this field and what they will do. The Association of Organizations Engaged in Digital Currency Exchange (AOCE) plans to become an SRO, outlining its goals and explaining how it will assist cryptocurrency exchanges.

When will SROs for cryptocurrency exchanges appear

For existing participants in the cryptocurrency exchange market, a transitional period until July 1, 2027, is provided, during which participation in an SRO is not mandatory, says Nikita Zuborev, a senior analyst at the largest online exchange aggregator Bestchange.ru. Moreover, as of the end of August, the regulatory framework is still being formed: the Central Bank is preparing rules for maintaining registers, admitting organizations, and requirements for managers and the calculation of own funds, the expert clarified.

In other words, there are only a few days left until September 1, and some practical mechanisms are still not ready and will be adjusted over the next few months. The first fully regulated operations may not appear until the end of 2026, Zuborev believes.

In his opinion, it is still unclear who will ultimately become the basis for the new SRO. Right now, the newly established Association of Organizations Engaged in Digital Currency Exchange (AOCE), which is actively preparing and forming a register of members, recommendations, standards, compliance, and dispute resolution mechanisms, is competing for this right against the Association of Banks of Russia (ABR), which is forming a professional association of market participants with plans for subsequent transformation into an SRO, said the analyst.

According to Dmitry Machikhin, founder of the BitOK service, there will likely be three different SROs. One organization will unite participants from the banking sector, the second may become an association of brokers, and the third will be the new AOCE mentioned above, which will include existing cryptocurrency exchanges.

What will SROs do in the cryptocurrency exchange sector

The SRO model will be based on Federal Law No. 223-FZ, which is already operational in other segments of the financial market, Zuborev said. The Central Bank will set the framework and oversee the SRO, while the self-regulatory organization will establish detailed rules for the daily operations of exchanges and monitor their compliance.

The SRO will have the opportunity to set professional standards and consolidate the market's position, explained Darja Petrukhina, a consultant at IPN Partners. She noted that this model has long been functioning in the classical financial market, for example, in NAUFOR, which unites professional participants in the securities market, monitors compliance with standards, and represents the interests of the industry.

In addition to oversight, the SRO can become a platform for developing unified approaches to practical issues that will inevitably arise quite frequently in the new cryptocurrency market in Russia, the expert said. As an additional example, she pointed out that NAUFOR also conducts training and certification of specialists, meaning the SRO can perform not only regulatory but also educational and methodological functions for the industry.

The final model of the crypto self-regulatory organization (SRO) will only be clear after its establishment, approval of internal documents, and registration with the Bank of Russia, said Perukhina.

Advantages and Disadvantages

Pros

The convenience lies in the fact that, similar to other financial sectors, in the future, SROs may have a compensation fund and liability insurance, noted Zuborev. He clarified that ultimately, the end user will receive clear financial guarantees.

It is also convenient that all issues, including those with law enforcement agencies, can be resolved in one place, "civilized" and through requests, says Machikhin. Of course, this does not apply to illegal activities, but illegal exchanges will not be able to join the SRO, the expert added, noting that the industry is now being legitimized before our eyes.

The main advantage of the SRO, according to Petrukhina, is the ability to establish unified operational rules and conduct a consolidated dialogue with the Bank of Russia, instead of each market participant separately trying to convey their practical problems to the regulator.

For businesses, this can also simplify adaptation to new requirements, believes the lawyer. She explained that as practices develop, the SRO will be able to provide clearer professional guidelines on compliance issues, process organization, and client interaction.

Cons

Among the disadvantages, Zuborev noted that the SRO could lead to significant market consolidation. This is not necessarily bad from the perspective of the state or large businesses, but it could be a very serious drawback for competition, and thus for the final price for users, said the analyst.

He also pointed out that the downsides from a business perspective will be determined in the future. According to Zuborev, this will depend on what specific standards the SRO introduces for exchanges and how costly it will be to comply with them. Such standards may include AML (Anti-Money Laundering regulations), KYC (Know Your Customer procedures), as well as limits, reserves, cryptocurrency storage rules, cash and bank account operations, complaint handling rules, return processes, and liability for stalled/error transactions.

Membership entails additional regulatory and financial burdens, clarified Petrukhina. She explained that companies will have to comply with SRO standards, undergo control procedures, and bear the costs associated with membership. "For exchanges that have operated in a relatively free legal environment for many years, this will be a significant change in the business model. Therefore, the effectiveness of the SRO will largely depend on whether it can simultaneously perform a control function and genuinely represent the interests of the professional community before the regulator," said Petrukhina.

Machikhin agreed that there may be difficulties at the initial stage, as it is still unclear how the SROs themselves will function and what the conditions for being part of them will be. However, the expert believes that within the first year of operation, "everything will settle down."

Are Exchanges Ready?

It is important to note that the number of exchange websites today does not equal the number of potential legal participants in the SRO, said Zuborev. One brand may have several websites with separate teams or have multiple legal entities. "As of today, potentially only a few are ready for licensing, but in the coming months of the transition period, it will become clear how many more businesses will be able to pass through the filters," believes Zuborev.

An expert pointed out that the announced threshold of 15 million rubles in own funds is just a small part of the requirements. He explained that the actual cost of preparing a business will be significantly higher, both in monetary terms and in management resources: in-house lawyers will be needed, compliance policies and AML systems, information security at the level of advanced banks, regular audits, stricter reporting, improvement of information infrastructure, and integration with government services, and finally, membership and servicing in self-regulatory organizations (SROs).

<<Requirements will also be imposed on the management of exchange points, similar to other financial organizations. The entry ticket to this market will cost significantly more than the announced 15 million, and the work that will need to be done this year is staggering in its scale>>, said Zuborev.

However, the expert believes that the market is unlikely to empty. He expressed confidence that against the backdrop of the departure of several dozen small exchanges, a whole pool of services from banks will emerge. The analyst reminded that in the case of banks, a universal license allows opening <> as part of the infrastructure literally in a notification manner, without long and complicated paths to obtain new licenses.

According to Machikhin, cryptocurrency exchanges will mainly join the SRO, which the Association of Organizations Engaged in Digital Currency Exchange (AOЦB) plans to become. The expert estimates the number of participants at 150-200.

What is AOЦB and what are its goals

The Association of Organizations Engaged in Digital Currency Exchange (AOЦB) was established in late July 2026, and its general director became the founder of the legal company GMT Legal, Andrey Tugarin. He stated that AOЦB will undoubtedly receive SRO status.
<<For this purpose, the association was registered with the Ministry of Justice. The association will be able to submit the entire necessary list of documents to the Central Bank of Russia to obtain SRO status when all the necessary regulatory framework is ready>>, said Tugarin.

He explained that without these regulatory acts, it is legally impossible to submit an application for SRO status. Also, according to the head of the association, it is necessary to wait for a number of resolutions and instructions from the Central Bank, after which the association will promptly submit all necessary documents.

Tugarin stated that the main goal of AOЦB is to give the cryptocurrency exchange market the most legitimate status possible, so that the Bank of Russia sees this and so that the regulator has proper communication with the legal participants in the market.

Moreover, since joining the SRO will become mandatory for exchanges, AOЦB will also offer a mechanism for implementing this requirement.

<<We are creating for the market not only the opportunity to unite, to ask the most inconvenient and pressing questions about the new regulation, but we are also creating and providing the market with a mechanism for them to be legal, because joining the SRO for legal exchanges is not a choice, but a direct obligation>>, said Tugarin.

He added that for those who wish to be a legal cryptocurrency exchange in Russia, the association intends to provide all possible tools for this.

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