DFA or bond: one debtor, but different record-keeping, exit and tax

A DFA and a bond can be debt of one and the same issuer, and in that case they share the credit risk: it is the same company that either pays or does not pay. Everything else differs: where your right is recorded, what the debtor is obliged to tell about itself, how you get out of the asset before maturity and how the tax is calculated. A bond is a security, a digital financial asset is not a security, and almost every difference below grows out of that line.

What DFAs are and who issues them is covered in the core guide to digital financial assets. Here we only compare the two by how they are built: record-keeping, disclosure, liquidity, holder protection, tax. Yields are left out of this text on purpose; the last section deals with them.

Where it is recorded that the asset belongs to you

The right to a bond is recorded by a depository. The record of the security is not tied to whoever it was bought through: the security can be transferred from one depository to another, and the intermediary can be changed without selling it.

A DFA is built differently. Under Federal Law No. 259-FZ of 31 July 2020 it is a digital right that is issued and recorded in an information system based on a distributed ledger. The system is run by an operator from the Bank of Russia register, the terms are set out in the issue decision, and there is no depository record-keeping. The asset lives inside the platform where it was issued: it cannot be moved to another operator the way a security is moved between depositories.

This gives the first practical difference. When you buy a bond, you choose the issuer. When you buy a DFA, you choose the issuer and, together with it, the platform, for the entire holding period.

What the debtor is obliged to tell about itself

A bond is surrounded by a layer of documents and obligations that are read before the purchase and after it: the prospectus, where it is required, and information disclosure under the rules of the securities market. A DFA has no prospectus, and there is no issuer disclosure under those rules either. There is the issue decision, published on the operator's website. What to read in it is shown in the guide to how DFAs are bought.

Here we should be frank about ourselves: TradeAlmanac does not carry DFA issues. We cover bonds, and this can be put to use from the other side. A company that borrows through DFAs may also borrow through bonds, and then its public footprint is already in the bonds section: you can see which of its issues are outstanding. Issuer events are collected in the corporate events calendar.

If the debtor has no bonds at all, there is nothing in our data to check it against. The issue decision then remains the only document, and the question of credit quality is left without an answer from the market.

How to exit ahead of maturity

A bond trades on the exchange, and the orders for it are gathered in the order book: the seller sees at what price and in what size others are ready to buy. This is not a promise of an easy exit: a rarely traded issue can have an empty order book, and the liquidity risk of the issue does not go away. But the place where a buyer is sought is common to all trading participants.

A DFA does not trade in an ordinary exchange order book. Trades after the placement go through a DFA exchange operator, which is also on the Bank of Russia register, and only inside its own platform. The circle of possible buyers is limited to the platform's users. Why it is arranged this way and what it means for the exit price is covered in the guide to the secondary market for DFAs.

What the holder is left with when the payment has not arrived

In both cases the obligation rests with a specific issuer, and no form of issue makes the debtor more reliable. The difference lies in how visible a failure is and what the holders can do together.

We collect missed bond payments in the feed of defaults and technical defaults, and it shows whether the issuer has had delays before. Bondholders also have collective mechanisms, the bondholders' representative and the general meeting; how they work is described in the glossary.

Which of these mechanisms a particular DFA issue has does not follow from the name of the instrument. It is determined by the issue decision and the operator's rules, and they have to be read before the purchase, not after a delay. More on whose obligation you are getting is in the guide to the risks of DFAs.

There is protection of another kind as well: restricted access. Under Bank of Russia Directive No. 7176-U of 23 September 2025, in force since 1 January 2026, a non-qualified investor may buy, with no limit on the amount, DFAs whose payout does not depend on variable indicators, provided the issuer has a high credit rating. DFAs whose income is linked to inflation, the key rate, the price of a precious metal or of a share are available within RUB 600,000 a year. The remaining issues are intended for qualified investors only. Bonds have access rules of their own, and they are not compared in this text.

Tax: the rates are shared, the bases are separate

The rates are the same: 13% within an annual base of RUB 2.4m and 15% above that threshold. The rest diverges.

Transactions in DFAs are placed in a separate tax base, and this leads to differences that cannot be made out in the headline rate. The provision that establishes this has been in force since 2023: Article 214.11 of the Russian Tax Code.

A loss on DFAs does not reduce a profit on securities: netting between these bases does not work. Investment deductions, the individual investment account deduction and the long-term holding relief, do not apply to DFAs; for securities they exist, on their own conditions, which are set out in the article on the long-term holding relief. The tax agent is the information system operator or the exchange operator through which the payment was made.

Who withholds the tax and what happens to a loss is covered in the guide to the taxation of DFAs.

When this comparison stops working

The law is changing. Federal Law No. 282-FZ of 4 August 2026 "On Digital Currencies and Digital Rights" introduces new regulation of digital rights and replaces Law No. 259-FZ in stages. The transition is phased, and the wording in force has to be checked as of the purchase date. The same goes for the access rules: Directive No. 7176-U replaced the previous directive, and the rating levels on which access depends are set by the Bank of Russia board of directors.

Only the yields are compared. The rate on a DFA and the yield on a bond of the same issuer are figures that come from different conditions. Behind the bond yield stand an exit through the exchange and the deductions; behind the DFA rate, an exit inside the platform and a separate tax base. A bond's yield can be worked out with the calculator; the payment terms of a DFA are written in the issue decision. It makes sense to set them side by side only after the difference in how the instruments are built has been taken into account.

The money may be needed before maturity. Then the question of exit matters more than the question of the rate, and it is answered not by the issuer but by the platform.

The plan is built on a tax relief. If the idea relies on an individual investment account, on the long-term holding relief or on offsetting losses between instruments, a DFA does not fit into it, under the current wording of Article 214.11 of the Russian Tax Code.

That leaves a question each investor answers for themselves: what exactly are you being offered the difference in rate for — the term, the absence of an exchange, or the fact that less is known about the debtor?