This piece is an overview, written for an international audience, of how TON is regulated outside Russia in three key jurisdictions: Belarus, Kazakhstan and the European Union. Each zone has its own logic; for a foreign observer the relevant questions are both what is allowed and what is restricted. Based on Belta, BelTA Pravo, Adam Smith Lithuania, ESMA publications and the MiCA regulation, current as of May 2026.
In brief
- Belarus — the most retail-friendly regime for individual holders: Decree #8 (2017), Decree #19 (2026) — crypto is legal, individual income tax on crypto operations is 0% until 31.12.2025 (extended on most operations). Crypto banks launch in July 2026.
- Kazakhstan — licensed crypto exchanges inside AIFC (Astana International Financial Centre); 2023 Law on Digital Assets. Operators include Binance Kazakhstan, ATAIX, Intebix.
- EU (MiCA) — in force since 30.12.2024 for most assets; for CASPs (service providers) a transition period runs to July 2026. Toncoin trades freely as an asset; service providers operate under licence.
- Stablecoins in the EU — Tether (USDT) has no MiCA licence; Circle (USDC) does. A gradual USDT delisting is unfolding on European exchanges.
Belarus: Decree #8 and Decree #19
Decree #8 (2017) — the foundation
Presidential Decree #8 of 21.12.2017 “On the development of the digital economy” is the foundational document. Key points for a TON holder:
- Cryptocurrency (including Toncoin) is legal for ownership and peer-to-peer operations.
- Mining, exchange and withdrawal are permitted.
- Tax: individuals are exempt from personal income tax on crypto operations through 1 January 2026 (recent amendments extend the exemption on most operations).
- Crypto-exchange operators must be HTP residents (High-Tech Park, Minsk).
HTP hosts residents such as dzengi.com (formerly Currency.com), which conduct legal fiat-to-crypto exchange, including TON.
Decree #19 (January 2026) — crypto banks
On 16 January 2026 Presidential Decree #19 “On crypto banks and certain matters of control over digital tokens” was signed. Most provisions take effect six months later — around 18 July 2026.
Key points:
- Crypto bank — a new type of financial institution, an HTP resident.
- Eleven categories of operations — exchange of crypto assets for fiat, lending against crypto collateral, crypto-asset deposits, crypto-card issuance, asset management and so on.
- 26 currencies and assets — the list includes BTC, ETH, USDT, USDC and notably TON / Toncoin. This is the first time a CIS-region regulator explicitly names TON among assets eligible for crypto-banking operations.
- KYC/AML under Belarusian rules — mandatory.
For non-residents this is potentially a useful channel: open an account with a Belarusian crypto bank where allowed for non-residents, use a crypto card for payments, hold TON under Belarusian law.
iA window of opportunity
By our estimate, after 18 July 2026 Belarus becomes one of the lowest-friction legal channels to operate with TON for the CIS audience. But the specific account-opening procedures and service catalogues will depend on internal crypto-bank regulations and licensing terms.
Kazakhstan: AIFC and the Law on Digital Assets
In Kazakhstan, crypto-assets are governed by the Law of the Republic of Kazakhstan “On Digital Assets in the Republic of Kazakhstan” (2023). The key infrastructure is the AIFC (Astana International Financial Centre) — an English-law financial hub with its own regulator, AFSA.
What is available in AIFC
- Licensed crypto exchanges: Binance Kazakhstan, ATAIX, Intebix, BitFinance and several other venues. By 2026, around 10 active licences.
- TON support: on major AIFC exchanges, TON trades in TON/USDT and TON/KZT (tenge) pairs.
- Personal taxation: 10% personal income tax on income from digital-asset sales (general PIT rates).
- KYC: mandatory, with residency verification. Russian non-residents can open accounts but the procedure is stricter than in Belarus.
Mining
Kazakhstan was a top-3 global mining hub until 2022; after the 2022-2023 energy restrictions, licence issuance slowed but did not stop. Not directly relevant to TON (PoS), but indicative of the country’s flexibility on crypto.
Belarus vs Kazakhstan for a retail TON user
| Parameter | Belarus | Kazakhstan |
|---|---|---|
| Personal tax | 0% (extended through 2026) | 10% PIT |
| KYC for non-residents | soft | strict |
| Licensed venues | dzengi.com and HTP residents | AIFC: ATAIX, Intebix, Binance KZ |
| Crypto cards | from July 2026 (crypto banks) | via online banks, limited |
| Account-opening difficulty | low to medium | medium to high |
| TON support | named explicitly in Decree #19 | available on exchanges in spot pairs |
EU: MiCA — what changed in 2024-2026
Markets in Crypto-Assets Regulation (MiCA) — Regulation (EU) 2023/1114, the EU’s main crypto law. Implementation timeline:
- From 30 June 2024 — for stablecoin issuers (ART, EMT — fiat-pegged tokens).
- From 30 December 2024 — for all other assets and service providers (CASPs).
- Until 1 July 2026 — transition period for providers under national licence; after that date, EU-wide CASP authorisation becomes mandatory.
Toncoin within MiCA
MiCA distinguishes three types of crypto-assets:
- EMT (E-Money Tokens) — USDC, EUROC. Strict EMI licence.
- ART (Asset-Referenced Tokens) — Tether USDT, tokens backed by a fiat or asset basket. Issuer licence required.
- Other crypto-assets — Bitcoin, Ethereum, Toncoin. Trade freely; no issuer licence required. Service providers (exchanges, wallets) must hold a CASP licence.
So Toncoin as a token trades in the EU without separate authorisation. Licensing applies to service providers: exchanges (Bitvavo, Bitstamp, Coinbase EU), custody-enabled wallets, staking providers.
EU stablecoins: USDT under pressure
Tether has not obtained an EMI licence in the EU. Under MiCA, since 2024 European crypto exchanges must:
- Not offer USDT to retail users in the EU;
- Gradually delist USDT trading pairs for retail;
- Mark USDT as an “unregulated stablecoin” for institutional operations.
In 2025-2026 the major European exchanges (Coinbase EU, Crypto.com, Kraken EU) have carried out partial USDT delistings. Bitstamp kept USDT for institutional accounts but hid it from retail listings.
For a TON user in the EU:
- USDT-jetton remains accessible in TON via DEX (STON.fi, DeDust) — DEXes do not fall under MiCA obligations directly;
- On European CEXes, USDT-pair coverage for TON is gradually shrinking;
- Alternatives: USDC (Circle has an EMI licence), DAI, euro-stablecoins (EURC).
What a licensed CASP must do
After authorisation from July 2026, an EU service provider must:
- Run KYC/AML under MiCA + AMLD 5/6;
- Segregate client funds;
- Disclose terms of service and risks (white paper);
- Report to ESMA;
- Comply with operational resilience requirements (DORA).
For Russian residents, access to licensed CASPs in most EU countries is closed — Russian passport plus Russian residency triggers an automatic refusal. Russian-passport holders with EU residency typically pass, but with extra questions.
Comparison of the three jurisdictions
| Criterion | Belarus | Kazakhstan | EU |
|---|---|---|---|
| Toncoin as an asset | explicitly permitted | permitted | trades freely |
| Personal tax | 0% (extended) | 10% PIT | per national rules, typically 20-30% |
| KYC for Russian passports | soft | strict | very strict |
| Crypto banks | yes (from July 2026) | via AIFC | via CASP |
| USDT access | unrestricted | unrestricted on exchanges | restricted, delisting |
| Mining/validation | permitted, HTP incentives | permitted with licence | permitted under MiCA |
What to choose as a TON user
From practice in 2025-2026:
- If you hold small amounts and care mostly about self-custody and payments — stay where you are, hold in Tonkeeper, declare on sale, don’t over-engineer.
- If you have meaningful volume and need a legal exchange channel — through Belarusian HTP residents (dzengi.com and similar) or Kazakhstan’s AIFC exchanges.
- If you plan to interface with EU fiat / euros — you need EU residency. Otherwise, all CEXes are closed; only DEXes remain.
- If your focus is staking/validation — Belarus (via HTP) or Kazakhstan (via AIFC) offer the most predictable regulation.
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What to watch next
- Belarus — final crypto-bank regulations under Decree #19 are due in summer 2026. Track HTP rule-making.
- Kazakhstan — AFSA updates on AIFC exchange licensing; the number of venues open to non-residents is rising.
- EU — MiCA transition ends in July 2026; the final list of authorised CASPs lands. More stablecoin delistings are likely.
Related materials — TON’s legal status in Russia, sanctions risks.
Sources
- Decree #8 “On the development of the digital economy” (Belarus, 2017).
- Presidential Decree of the Republic of Belarus #19 of 16.01.2026 “On crypto banks…”.
- Law of the Republic of Kazakhstan “On Digital Assets in the Republic of Kazakhstan” (2023).
- AIFC, AFSA (Astana Financial Services Authority) — register of licensed exchanges.
- MiCA, Regulation (EU) 2023/1114 — official ESMA publication.
- Reporting from Belta, BelTA Pravo, Onliner (Belarus); Adam Smith Lithuania on MiCA; Reuters and Bloomberg on 2025-2026 practice.
All data is from public sources as of 9 May 2026; for jurisdiction-specific scenarios consult local lawyers and tax advisers.
