The secondary market for DFAs: why the asset never leaves its own platform

The secondary market for DFAs consists of trades between holders of an asset that has already been issued, and these trades take place only inside the information system where the asset was issued. A digital financial asset cannot be moved to another operator the way a security is transferred between depositories. That is why it can be sold before redemption only to someone admitted to the same platform, and it has no market-wide queue of orders like the one a bond has on the exchange. An early sale is possible, but neither a buyer nor a price is secured in advance.

What a digital financial asset is, who issues it and what right it certifies is covered in the piece on how DFAs are structured. The question here is narrower: what happens between purchase and redemption if the money is needed ahead of schedule. The reason to return to it is Bank of Russia Directive No. 7176-U of 23 September 2025, in force since 1 January 2026: it redefined which issues are available to a non-qualified investor. The rules of entry are set by the regulation. The regulation does not promise an early exit: that depends on whether a buyer turns up.

An entry in the operator's system instead of a custody account

The foundation is Federal Law No. 259-FZ of 31 July 2020 on digital financial assets. Under it, a DFA is a digital right that is issued and recorded in an information system built on a distributed ledger, with its terms written into the issuance decision. The system is run by an operator included in the Bank of Russia register. A DFA is not a security, and it has no depository record-keeping: the holder's right is confirmed by an entry in the operator's system, not by a line in a custody account.

A bond works differently. The rights to it are recorded by a depository, and the holder can move the security to another intermediary by a depository transfer without selling it. It trades on the exchange, where orders arrive from the clients of different brokers. For a bond, the place of record-keeping and the place of trading are separate, and neither is tied to the firm through which the security was bought.

For a DFA, the place of record-keeping also sets the boundaries of circulation. Changing intermediary while keeping the asset, something a holder of securities takes for granted, is not available here: the only ways to leave the platform are to sell the asset on it or to wait for redemption.

The exchange operator: who handles a trade between holders

Operators have two roles. The issuer issues the asset through the operator of the information system, and the asset is recorded in that system. Trades on the secondary market are carried out through a DFA exchange operator, which must also be in the Bank of Russia register. The Bank of Russia publishes both registers on its website, and checking against them separates a lawful venue from a firm with no right to deal in DFAs.

Beyond that point the regulation gives way to documents. Exactly how a seller finds a buyer, whether the venue displays counter-offers, how much it charges per trade and during which hours it operates is determined by the operator's rules and the issuance decision, and the current version has to be checked on the operator's website. These are the questions whose answers lie in those documents, not in the law:

• whether trades between holders are carried out in this issue, and through which exchange operator;
• how an offer to sell is posted and who sees it;
• whether the issuance decision provides for early redemption or a buyback by the issuer, and on what terms;
• what fee the operator withholds on a sale.

If the documents are silent on trades between holders, counting on a sale before maturity rests on an assumption, not on a term of the issue.

What is missing compared with a bond's order book

The exchange order book is a common queue of buy and sell orders visible to all trading participants. It shows the price at which the security can be sold right now, how far the bid stands from the ask, and what volume can be sold without moving the price. Where an issue has a market maker, counter-orders are maintained under a contract with it.

A DFA does not trade on the exchange in a conventional order book. Several differences follow, and all of them concern the exit, not the return:

• The pool of buyers. A bond can be bought by a client of any broker with access to trading. A DFA can be bought only by a user of the same platform, and only if the issue is available to that user under the rules of Directive No. 7176-U.
• The price. A bond has a public quote against which a position can be valued, as long as there are orders and trades in the issue. A DFA has no market-wide quote: the price of an earlier trade, if the platform shows it, speaks of the past and does not promise that anyone will buy at it again.
• The time. Selling a liquid bond takes as long as it takes the order to be filled. Selling a DFA takes as long as it takes to find a buyer, and that period is not known in advance.

In the glossary, the price of this uncertainty is called the illiquidity discount: the concession a seller makes so that the trade goes through within the time they need. The remaining differences — record-keeping, disclosure, holder protection — are gathered in the piece on how a DFA differs from a bond.

What a sale changes in the limit and in the tax

A sale before redemption has consequences that are set by regulation.

The purchase limit. For a non-qualified investor, DFAs whose return depends on inflation, the key rate, the price of a precious metal or a share are available within an annual limit — RUB 600,000. Under Directive No. 7176-U, the limit is restored on a sale or a redemption: an asset that has been sold frees up room for a new purchase. How the cap is calculated and how the groups of issues differ is explained in the piece on buying DFAs.

The tax. Transactions in DFAs form a separate tax base. The tax agent is the operator of the information system or the exchange operator through which the payment passed. A loss on DFAs is not netted against a gain on securities — this is what Article 214.11 of the Russian Tax Code says. For a forced sale, it means the following: the loss from a price concession will not reduce the tax on gains from shares and bonds. The details are in the piece on the taxation of DFAs.

What the same issuer's bonds reveal

TradeAlmanac carries no DFA issues, and we keep no data on trades between their holders — neither prices nor volumes. But a company that borrows through DFAs may also borrow through bonds, and the credit risk is the same in either case: it is the obligation of a specific issuer.

Bonds show what a DFA platform does not. The bonds section shows at what price and at what yield the issuer's bonds trade. The feed of defaults and technical defaults shows whether it has delayed payments. The corporate events calendar shows what it has scheduled. If the issuer's bonds themselves trade rarely, a question arises: who will buy its DFA in a place where the pool of buyers is confined to one platform? How illiquidity compounds credit risk is examined in the piece on the risks of DFAs, and how to estimate the time needed to exit a position is covered in the piece on portfolio liquidity risk.

When none of this matters, and when it will change

Someone who holds the asset to redemption has no need of a secondary market: the issuer returns the money on the date written into the issuance decision. The restrictions concern only an exit ahead of schedule — and they bite harder the longer the issue and the less predictable the holder's need for money.

What has been said also ceases to hold for a particular issue if its documents are drawn up differently: the issuance decision may provide for its own procedure for returning the money early.

The regulation itself is changing too. 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 procedure for DFAs changing hands between holders may change, so the current version has to be checked.

That leaves a question only the holder can answer: might this money be needed before the redemption date — and if so, what happens when there is no buyer on the platform?