Bank of Russia simplifies separate accounting of securities
Depositories should move securities subject to separate accounting to non-trading accounts on or before 18 December 2025. This applies to Russian shares, if such shares and the relevant depositary receipts were purchased after 1 March 2022, as well as Eurobonds and substitute bonds acquired after 3 March 2023.
The requirement to maintain separate accounting records for the said securities is set out in Executive Order of the President of the Russian Federation No. 138, dated 3 March 2023. It may be lifted only after examining the documents and data confirming the absence of unfriendly investors in the ownership chain.
Now, only clean securities may be held in trading depository accounts and freely traded on the stock exchange, including in negotiated deals mode. The Bank of Russia decision also provides for a minimum set of documents that customers should submit to the depository (registrar) for the latter to discontinue separate accounting. When transferring the securities to another depository (registrar), it is obliged to share all available data, if so requested. It is no longer mandatory for each accounting infrastructure participant to collect the entire set of documents concerning the security ownership history. Instead, one participant can do it once and then pass the information down the chain. This will reduce the workload for market participants and simplify the customer journey.
Furthermore, a cooling-off period will apply. It will be possible to terminate separate accounting of securities or execute an instruction to transfer them to another depository (registrar) six business days after a notice is submitted to the Bank of Russia.
On 12 January 2026, new requirements for separate accounting will become effective. Starting from the said date, depositories will no longer have to maintain separate accounting records for securities purchased on the stock exchange and check all their owners. As for over-the-counter transactions, separate accounting still applies to securities involved in them. Depositories and registrars are obliged to submit daily reports on transactions with securities subject to separate accounting to the Bank of Russia.
The regulator closely monitors market participants’ compliance with Executive Order of the President of the Russian Federation No. 138 and will take strict supervisory measures in case of violations.