Belarus: Overview of the New Edict on Cryptobanks

19.01.2026

On 16 January 2026, the President of the Republic of Belarus signed Edict No. 19 “On Cryptobanks and Certain Control Issues in the Sphere of Tokens”. Under this Edict, a new type of regulated activity will be introduced in Belarus at the intersection of the banking and digital economy sectors — cryptobanks.

The Edict will enter into force six months after its official publication. Accordingly, the first cryptobanks may appear in Belarus as early as the second half of 2026. During this period, secondary legislation is expected to be aligned with the Edict, including clarification of the requirements applicable to legal entities intending to obtain cryptobank status.

 

What Is a Cryptobank?

A cryptobank is a legal entity that simultaneously meets all of the following criteria:

• it is incorporated as a joint-stock company (closed or open);
• it is a resident of the Hi-Tech Park (HTP) and carries out exclusively the activity defined as “other activities using tokens”;
• it is included in the Register of Cryptobanks maintained by the National Bank of the Republic of Belarus;
• it qualifies as a financial organisation under the Law “On Payment Systems and Payment Services”;
• it is included in the Register of Payment Service Providers.

Note: Based on an analysis of these provisions, existing crypto platform operators, crypto brokers, crypto exchanges and ICO organisers that are HTP residents will not be able to combine their current business models with that of a cryptobank.
Accordingly, in order to obtain cryptobank status, such entities would likely need either to discontinue their existing activities or to establish a separate legal entity eligible to apply for cryptobank status.
 

What Activities Can a Cryptobank Perform?

The Edict conditionally divides cryptobank activities into two categories: banking operations and crypto operations.

Banking Operations

• placing funds in accounts and/or deposits with the National Bank;
• opening and maintaining bank accounts for individuals and legal entities (including non-residents and individual entrepreneurs);
• conducting foreign exchange operations;
• carrying out settlement operations and other operations approved on an individual basis upon inclusion in the Register of Cryptobanks;
• forming clients’ credit histories;
• opening and maintaining correspondent and other accounts related to cryptobank activities without a separate banking licence.

Crypto Operations
 

• receiving tokens from clients as remuneration for services rendered;
• receiving penalties (fines or late payment charges) for non-performance or improper performance of obligations;
• conducting intermediary settlements between individuals and/or legal entities using tokens;
• carrying out other token-related operations provided for by subordinate legislation and decisions of the HTP Supervisory Board.

In addition, cryptobanks are entitled to:

• use the word “cryptobank” in their name (while the use of “bank” or “non-bank credit and financial organisation” is prohibited);
• use foreign currency in settlements with residents and non-residents in token-related transactions conducted through or with the cryptobank;
• conduct remote client identification.

Tax Obligations of Cryptobanks

As a general rule, cryptobanks are subject to:

• corporate income tax (CIT) at a rate of 9%;
• contributions of 1% of gross revenue to the State Institution “Secretariat of HTP Supervisory Board”.

Use of Tokens for Settlements

Edict No. 19 allows the use of tokens as a means of settlement in certain cases:

• Individuals (including professional income taxpayers, artisans and persons engaged in agro-ecotourism may receive tokens to their cryptobank accounts as remuneration under cross-border civil law contracts with non-residents.
• Legal entities (both Belarusian residents and non-residents) may use tokens for settlements under foreign economic contracts only in cases approved by the Council of Ministers and the National Bank (to be specified in future regulations).

In such cases, cryptobanks must use specialised software developed by Belarusian residents, enabling the identification and exclusion of tokens previously involved in unlawful activities.

Note: Previously, regulators maintained a strictly prohibitive approach to settlements using digital tokens. Edict No. 19 therefore represents a significant shift, allowing limited use of crypto instruments in cross-border transactions.
 

Procedure for Obtaining Cryptobank Status

To obtain cryptobank status, an applicant must:

• incorporate a joint-stock company in Belarus;
• register as an HTP resident with the relevant declared activity;
• apply to the National Bank for inclusion in the Register of Cryptobanks.

Until inclusion in the Register, the company may not conduct cryptobank activities or use the term “cryptobank” in its name.

The application requires extensive documentation, including, among other things:

• constitutional documents;
• proof of a formation authorized capital of BYN 20 million (approximately USD 6.9 million);
• ownership, beneficial ownership and management disclosures;
• a business project, a five-year development strategy and a financial plan;
• confirmation of HTP residency;
• an approval letter from the HTP Supervisory Board.

Upon registration, the cryptobank must place an irrevocable deposit of BYN 10 million (approximately USD 3.45 million) with the National Bank within 10 business days.
 

Grounds for Refusal and Removal from the Register

The Edict sets out detailed grounds for refusal of registration and for removal from the Register, including:

• submission of false or misleading information;
• non-compliance with legal requirements;
• reputational or qualification issues affecting management or shareholders;
• failure to comply with capital requirements;
• AML/CFT violations;
• threats to national security or financial stability;
• loss of HTP resident status;
• inactivity or systematic regulatory breaches.

In certain cases, the National Bank may forfeit the mandatory deposit to the state budget.
 

Supervisory and Control Powers

Regulatory oversight is exercised by:

• the Secretariat of HTP Supervisory Board — in respect of token transactions not involving fiat funds;
• the National Bank — in respect of banking regulation, AML/CFT compliance and fiat-related operations.

Regulators may impose transaction bans, volume restrictions, corrective orders and other supervisory measures.
Certain supervisory actions must be coordinated between the National Bank and the Secretariat of HTP Supervisory Board.

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Authors: Gleb Yakushev, Stanislav Osmolovsky, Polina Filipcova.