Currency control in 2026: what is changing for foreign trade participants

Currency control in 2026: what is changing for foreign trade participants
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In 2026, foreign exchange control for participants in foreign economic activity will undergo a number of important changes. The regulator clarifies the rules for accounting for intermediary contracts, introduces new transaction codes for digital rights, reviews the requirements for loan agreements and expands the acceptable ways to fulfill obligations under foreign trade contracts. At the same time, control over compliance with special economic measures remains in full.

In 2026, the currency control system for participants in foreign economic activity will continue to transform towards greater flexibility, but at the same time it will maintain strict supervision over compliance with special economic measures. The new rules affect settlements with digital assets, intermediary schemes, loan agreements, and ways to fulfill obligations under foreign trade contracts.

Marina Degtyarenko, Deputy Head of the Currency Control Department of the Bank of Saint Petersburg, Bank of Saint Petersburg, provided explanations on key changes as part of an online event at the Center for Foreign Economic Activity 360 dedicated to the planned changes in currency legislation in 2026.

One of the innovations was the expansion of the list of codes for types of currency transactions. New codes have been added to the 99th group, which are used in settlements between residents in the case of the acquisition of digital rights and digital financial assets. This reflects the regulator's desire to adapt currency control to the development of the digital economy and new forms of payments.

Significant changes relate to mediation agreements. Starting in 2026, the criteria for registration of agency agreements, commission agreements, orders and brokerage services are being reviewed. The contract is subject to currency control based solely on the amount of the intermediary's remuneration, and not on the total value of the obligations under the contract, as was previously applied. The calculation of thresholds is also changing in the same way. They will be determined only by the amount of the commission, which reduces the administrative burden on businesses using agency schemes.

The requirements for documents confirming tax registration are also being adjusted. From January 1, 2026, instead of the registration certificate, an extract from the Unified State Register of Legal Entities is used, which unifies the document flow and simplifies checks by banks.

A separate block of changes affects the currency control of credit agreements. The LIBOR rate is excluded from the statement of banking control due to the entry into force of Federal Law No. 452-FZ. When making loan agreements, banks will be required to specify a fixed interest rate or a method of calculating it, if the rate is floating, as well as the amount of a surcharge or margin to the base rate for specific obligations.

A significant factor for participants in foreign economic activity remains the relaxation of the rules for fulfilling obligations under foreign trade contracts. In accordance with Decree No. 529, it is allowed to use any means of fulfilling obligations provided for by law, and not just direct transfer of funds. Mandatory repatriation of foreign exchange earnings has been abolished, and mandatory sales standards for the largest exporters previously subject to special control have been reduced to zero. At the same time, experts emphasize the need to monitor possible changes in these standards in the future.

In practice, this means that participants in foreign economic activity can transfer foreign currency earnings to foreign accounts, use it to settle accounts with non-residents, make cash settlements, offset claims and obligations, and replace obligations with new forms of fulfillment.

At the same time, all operations continue to be checked for compliance with prohibitions and restrictions in force under special economic measures. Thus, 2026 will be a period of a combination of expanded business opportunities and enhanced control over the legality of foreign exchange transactions.