The Bank of Russia is introducing a significant reform to investor qualification standards, focusing on knowledge and experience rather than formal criteria. As explained by Mikhail Mamuta, head of the Consumer Protection Service at the central bank, the new approach seeks to eliminate qualifications based solely on formal metrics. The State Duma has already approved the corresponding legislation in its second and third readings this week, fundamentally altering the system. Alongside these changes, the opportunities for non-qualified investors will narrow significantly: starting January 1, 2025, foreign securities will be accessible only to qualified investors.
The legislation still requires approval by the Federation Council and the President. Once signed into law, the changes will take effect six months after official publication. Until then, the current rules remain in place, and we’ve prepared a step-by-step guide for obtaining qualified investor status.
The Reform: Key Changes
Under the new law, a simplified pathway to qualified investor status will be introduced—a specialized exam. Investors who pass this exam will no longer need to meet other criteria. The Bank of Russia will establish a list of certifications required to qualify.
Another route to qualification will involve a combination of criteria. For instance, educational credentials or an academic degree can be paired with experience in trading, work in the financial sector, income level, or ownership of significant assets. Notably, academic degrees and income are being introduced as new criteria under the updated procedure. In 2023, Mamuta mentioned that the Bank of Russia was considering setting the annual income threshold for qualification at RUB 6 million.
Currently, the main criterion is the ownership of assets worth at least RUB 6 million. The Bank of Russia had previously proposed raising this threshold to RUB 12 million in 2025 and to RUB 24 million in 2026.
Additionally, the new law removes the restriction tying qualified investor status to specific financial instruments or lists of instruments.
Mamuta explained that the reform aims to reduce the risks associated with qualifying investors based solely on formal metrics.
“Qualification implies a level of expertise. At present, one can qualify as an investor simply by having over RUB 6 million in their account. But possessing that amount and having financial expertise are not necessarily related. When complaints or issues arise among qualified investors, they primarily involve those who qualified through asset ownership. The essence of this reform is to prioritize knowledge and experience while mitigating the risks of formal asset-based qualification.
“We’re introducing a completely new concept—a qualification exam. Anyone, even a beginner with a strong understanding of financial instruments, can pass this exam and qualify. This allows individuals to trade in any instruments. The aim is to ensure investors are better informed about the risks associated with complex products,” Mamuta told InvestFuture.
On the issue of qualification based on trading turnover, Mamuta stated that the central bank monitors attempts to artificially inflate turnover. “This is usually evident, and if a complaint is filed and we confirm that the turnover was artificially generated, sanctions may apply. However, genuine turnover reflects real trades, trades reflect experience, and experience reflects skills. Real trades qualify as experience-based qualification. It takes several years of active trading for this criterion to hold.”
What Changes for Non-Qualified Investors in 2025
For non-qualified investors, access to foreign securities will be significantly restricted starting January 1, 2025. Only securities from Eurasian Economic Union (EAEU) countries and international financial organizations operating within EAEU infrastructure will remain available. Under current rules, non-qualified investors can purchase securities from friendly countries not listed through unfriendly infrastructures, as well as foreign securities issued by companies predominantly operating in Russia or the EAEU.
The law also introduces new options for non-qualified investors. They will be able to purchase shares of closed-end mutual funds (ZPIFs) without testing, provided the funds meet criteria set by the central bank.
Certain instruments will remain accessible only after passing a test. The new law adds secured bonds backed by monetary claims (with some exceptions) to the list of instruments requiring testing.
Mamuta clarified that testing serves to educate investors and help brokers ensure products are suitable for clients.
“If an individual understands what they’re buying, they can easily pass the test, which involves just a few questions. Once passed, access to the instrument is granted without limits. However, if someone cannot pass the test, they might reconsider their investment strategy. That said, testing doesn’t outright prohibit transactions. Investors retain the ‘last word’ and can proceed despite failing the test. However, if they lose money, they won’t be able to claim they were misled into purchasing an unsuitable product,” Mamuta explained.
The new law also raises the threshold for transactions requiring testing from RUB 100,000 to RUB 300,000 for non-qualified investors, even if they fail the test.
