Belarus is moving crypto-banks from concept to regulatory machinery. Presidential Decree No. 19 created the category, and National Bank resolutions No. 157 and No. 158 bring the register procedures into force on 18 July 2026.
The main signal is institutional design. A crypto-bank in Belarus will need two approvals in practice: HTP approval for the token activity and business project, and National Bank inclusion in a register that defines the permitted financial operations.
What happened
On 29 June 2026, HTP Belarus said the country was finalizing the legal framework for crypto-banks. Dmitry Kalechits, first deputy head of the HTP Supervisory Board Secretariat, pointed to two documents before the Supervisory Board: requirements for applicants and their business projects, and requirements for internal-control rules.
The base regime was set earlier. Presidential Decree No. 19 of 16 January 2026 defines a crypto-bank as a joint-stock company that is an HTP resident and is included in the National Bank’s crypto-bank register.
On 30 June 2026, the National Bank adopted two implementing resolutions. Resolution No. 157 approves administrative procedures for inclusion in the register, changes to register entries, and exclusion from the register. Resolution No. 158 sets the rules for maintaining the register. Both enter into force on 18 July 2026.
The decree also sets financial thresholds. Before applying, founders must form charter capital of at least 20 million Belarusian rubles. After inclusion in the register, the crypto-bank must place 10 million Belarusian rubles in a conditional irrevocable deposit at the National Bank.
How we read this: two-key authorization
Two-key authorization is a regime where launch depends on two regulatory centers: the sector-specific crypto perimeter and the financial-supervision perimeter.
In Belarus, the first key sits with HTP. The HTP Supervisory Board approves the crypto-bank activity, while the HTP Secretariat has a role in supervising digital-sign operations. The second key sits with the National Bank. It maintains the register, issues the certificate, defines the banking, payment, and financial operations allowed for each crypto-bank, and can limit operation volumes.
This is a heavier regime than ordinary crypto-company registration. A crypto-bank can combine token activity with banking, payment, and related financial operations, but only inside the list approved by the National Bank in the register decision.
In our experience, the substance sits in the combination of tokens, payment rails, and banking secrecy. When those three elements sit inside one company, the regulator needs a tighter perimeter than it would for an exchange or a broker.
What this changes
For Belarus, the regime creates a separate institutional category between a traditional bank, a payment organization, and a crypto-asset provider. The participant remains an HTP resident, but it also enters a National Bank register and a dedicated layer of banking, payments, AML/CFT, and token supervision.
For applicants, market entry becomes expensive and document-heavy. The file includes capital, a National Bank deposit, a five-year strategic plan, HTP approval of the activity, ownership information, and evidence on the source of funds contributed to charter capital.
For the market, this increases the chance that the first crypto-banks look more like infrastructure and payments players than lightweight crypto-native startups. The regime allows token operations, but the documents are written around financial stability, registers, supervision, permitted operations, and exclusion from the register.
What we will watch next
The concrete monitoring signals:
- the first entrant in the crypto-bank register: it will show whom the regime is really designed for;
- the list of permitted operations in the National Bank decision: it will show how broad the crypto-bank function can become;
- the public register on the National Bank website: its fields and update cadence will show the level of transparency;
- HTP requirements for the business project and internal controls: they will show where the crypto-operational filter sits;
- National Bank limits on the number of crypto-banks and operation volumes: they will show whether the regime is a pilot corridor or scalable infrastructure.
Belarus is choosing a regulated hybrid: token activity stays in HTP’s orbit, while the financial side gets a National Bank perimeter. The real test starts when the first name enters the register and the allowed operations become visible.
Silk DeFi is a research project on crypto, DeFi, AI, and regulation across Eurasia.
Part of its practical lens comes from RiskOS Labs’ work on risk, infrastructure, and regulatory-facing projects.