Russia Presidential Decree No. 778: Digital Asset Disclosure Measures

The decree was issued under Federal Law No. 273-FZ on combating corruption following the adoption of Federal Law No. 259-FZ. It did not establish a general disclosure requirement for every Russian cryptocurrency holder. Its direct filing rule focused on applicants for specified Russian state positions and federal civil-service posts, together with certain federal civil servants applying for posts covered by the existing income and property disclosure system.

Decree No. 778 also updated presidential anti-corruption instruments so that digital financial assets and digital currency could be addressed alongside more traditional property, financial interests and expenditure information. This distinction matters: the decree is primarily a public-integrity and officeholder-disclosure measure, not a comprehensive licensing, trading, payments or tax regime for the wider digital-asset market.

During the 2021 notification window, covered applicants were required to submit a prescribed notice together with the relevant income, property and liability statement. The notice extended beyond the applicant’s own holdings to assets belonging to a spouse and minor children. It covered four related categories:

• digital financial assets;
• digital rights combining digital financial assets with other digital rights;
• utility digital rights; and
• digital currency.

Appendix No. 1 supplied the notification form. For digital financial assets, the form sought the asset name or designation, acquisition date, total quantity and information about the system operator. For utility digital rights, it sought a unique designation, acquisition date, investment amount and investment-platform operator information. For digital currency, it requested the currency name, acquisition date and total quantity.

The decree specified that the notification was to reflect holdings as of the first day of the month preceding the month in which the application documents were filed. The special filing period in paragraph 1 ended on June 30, 2021. The decree also recommended that federal state bodies, the Bank of Russia, regional and local authorities, state extra-budgetary funds and state corporations use its approach when exercising powers connected with income and property disclosure procedures.

Most provisions took effect on January 1, 2021. Point 6 of Appendix No. 2, which revised the standard income, expenditure, property and liability certificate, took effect on July 1, 2021. That phase-in allowed the broader declaration form to incorporate dedicated treatment of digital financial assets, digital rights and digital currency.

Appendix No. 2 made changes across several presidential anti-corruption acts. Among other things, it brought operators of information systems used to issue digital financial assets within certain verification-request procedures and added digital financial assets and digital currency to expenditure-control language. These amendments embedded digital-asset information into the established public-official disclosure and verification architecture.

The end of the 2021 notice window should not be treated as a wholesale repeal of Decree No. 778. A current consolidated version records an amendment by Presidential Decree No. 1009 of December 31, 2025. Effective January 1, 2026, that later decree repealed point 5 of Appendix No. 2, an amendment concerning publication of certain disclosure information, while leaving the decree otherwise listed in force. The most accurate profile status is therefore In force, qualified by noting that its one-time notification window has closed.

Decree No. 778 should be read with Federal Law No. 259-FZ and the current Russian anti-corruption disclosure rules. It does not, by itself, describe every present obligation affecting public officials or digital-asset holders, and it should not be used as a substitute for the current official text or professional legal advice.