The Central Bank of Russia has published measures to simplify the separate accounting regime for certain securities under Presidential Executive Order No. 138, including requiring depositories to move securities subject to separate accounting to non-trading accounts on or before 18 December 2025. The changes also tighten the operational rule that only “clean” securities may be held in trading depository accounts and traded on the stock exchange, including in negotiated deals mode. The move to non-trading accounts applies to Russian shares (and relevant depositary receipts) purchased after 1 March 2022, and to Eurobonds and substitute bonds acquired after 3 March 2023. Separate accounting may be lifted only after review of documents and data confirming the absence of “unfriendly investors” in the ownership chain; the Bank of Russia decision sets a minimum list of customer documents for a depository (or registrar) to discontinue separate accounting. When securities are transferred to another depository (or registrar), available data must be shared on request, and it is no longer required for every participant in the accounting infrastructure to collect the full set of historical ownership documents if one participant has already done so. A six-business-day cooling-off period will apply, with termination of separate accounting or execution of a transfer instruction permitted only after that period following submission of a notice to the Bank of Russia. New separate accounting requirements take effect on 12 January 2026. From that date, depositories will no longer need to maintain separate accounting for securities purchased on the stock exchange or check all their owners, while over-the-counter transactions will remain subject to separate accounting. Depositories and registrars must submit daily reports to the Bank of Russia on transactions involving securities subject to separate accounting, and the regulator signalled strict supervisory measures for violations.

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