Law of Turkmenistan ‘On Virtual Assets’

Turkmenistan has issued its law on Virtual Assets. Here is the link to the complete text of the law in the Russian language:

https://www.turkmenistan.gov.tm/ru/post/101129/zakon-turkmenistana-o-virtualnyh-aktivah

Here is a somewhat summarized and paraphrased version of the law in the English language:

COMPREHENSIVE SUMMARY: TURKMENISTAN’S LAW ON VIRTUAL ASSETS

Adopted: November 22, 2025
Effective Date: January 1, 2026
Law Number: 298

CHAPTER I: GENERAL PROVISIONS

Article 1: Basic Definitions

The law establishes comprehensive definitions for key terms in the virtual asset ecosystem:

Blockchain is defined as a type of distributed ledger technology where data is recorded sequentially and distributed in blocks, with each new block linked to the previous block through cryptographic signatures.

Virtual Asset means a set of data in electronic-digital form that has value, represents a digital expression of value and/or serves as a means of certifying property and/or non-property rights, created, stored, and circulated using distributed ledger technology or similar technology, but is not a monetary unit (currency), means of payment, or security.

Mining is defined as activity performed using software and hardware to conduct computational operations that ensure the functioning of the blockchain transaction registry by entering information about transactions between users into the distributed ledger. Mining requires continuous electricity supply and may result in the creation of virtual assets that are received by the miner as compensation for confirming transactions.

The law distinguishes between:

Industrial Mining: Mining conducted by legal entities
Private Mining: Mining conducted by individual entrepreneurs
Covert Mining: Mining performed on third-party computing capacity without their knowledge or consent using special software (this is prohibited)

Digital Token is a type of virtual asset that serves as a means of certifying property and/or non-property rights, including rights to claim other objects of civil rights.

Non-Fungible Token (NFT) is a unique digital property object existing as a record in a distributed ledger (blockchain), having no analogues and not subject to interchangeability.

Smart Contract is a contract in digital form, where the execution of rights and obligations is carried out through operations in the blockchain in a strictly defined sequence and upon the occurrence of certain circumstances.

Virtual Asset Service Provider is a legal entity registered in Turkmenistan that, as an entrepreneurial activity, provides one or more types of services related to virtual assets based on a license issued by the authorized body.

Virtual Asset Exchange Operator is a virtual asset service provider that provides buying, selling, and/or exchange services for virtual assets and/or exchange between virtual assets on its own behalf.

Crypto Exchange (Virtual Asset Trading Operator) is a virtual asset service provider that provides an electronic platform and services directly facilitating transactions with virtual assets.

Virtual Asset Wallet is a means (software application or other electronic-digital mechanism/medium) for storing and transferring virtual assets.

Miner is a legal entity or individual entrepreneur engaged in mining.

Mining Equipment refers to hardware and software that enables mining.

Mining Pool is an electronic platform designed to consolidate miners’ mining capacities and organize mining operations.

Issuer is an individual entrepreneur or legal entity that issues virtual assets.

Initial Placement of Virtual Assets is the process of distributing or allocating newly issued virtual assets for the purpose of attracting funds.

Distributed Data Ledger is a database created based on distributed ledger technology, distributed among one or more network nodes and/or computing devices that maintain the system and information integrity by compiling and recording ledger updates independently.

Distributed Ledger Technology is technology that supports distributed storage of encrypted data using cryptographic means.

Article 2: Scope of Application

The law applies to activities in the field of virtual assets within Turkmenistan’s territory.

Important Exclusions: The law does NOT apply to:

Securities and other types of financial instruments defined by Turkmenistan legislation as securities
Currencies, electronic money, reserves, deposits as defined by Turkmenistan banking legislation
Gambling activities

Article 3: Legal Framework

The legislation on virtual assets is based on the Constitution of Turkmenistan and consists of this Law and other regulatory legal acts regulating relations related to virtual assets.

Article 4: Legal Status of Virtual Assets

Key Provisions:

Virtual assets can be both independent objects of civil law and means of certifying property and/or non-property rights, including rights to claim other objects of civil rights.
Critical Limitation: Virtual assets are NOT legal tender, currency, and/or securities in Turkmenistan.
Virtual assets may be secured or unsecured.

Secured Virtual Assets:

Include digital tokens that certify property and/or non-property rights
Types of secured virtual assets and the rights they certify are established by the issuer in accordance with Turkmenistan legislation
The minimum liquidity condition for collateral, settlements, and emergency redemption is established by the authorized body
Collateral for virtual assets is NOT pledge security or a pledge obligation
Tokenization allows digital representation of real assets issued as tokens on blockchain, providing ownership rights to physical and virtual assets in digital form
NFTs can certify rights to digital or physical objects and be used to confirm authenticity, ownership, and uniqueness

Unsecured Virtual Assets:

Are virtual assets for which there is no person(s) bearing obligations to each holder of such virtual assets
Do not certify rights, are not secured by any rights and obligations, or other objects of civil rights

Article 5: Features of Virtual Asset Circulation

Conditions for acquiring and transferring rights to virtual assets may be expressed in accordance with smart contracts, pre-established algorithms, and distributed ledger technology functions.
All restrictions applicable to the circulation of civil law objects apply to secured virtual assets.
If a virtual asset is secured by an object under arrest or withdrawn from civil circulation, alienation of such virtual asset is not permitted, and any agreement on the alienation of such virtual asset is invalid.

CHAPTER II: STATE REGULATION OF VIRTUAL ASSET ACTIVITIES

Article 6: Main Directions of State Policy

The main directions of state policy include:

State regulation of relations in the field of virtual assets
Creating favorable conditions for virtual asset sector development
Phased implementation of modern relationships using distributed ledger technology, blockchain, smart contracts, and similar technologies
Ensuring transparency of state regulation
Ensuring equality and comprehensive effective protection mechanisms for all participants
Ensuring protection against unfair competition
Training highly qualified personnel
Conducting studies and research on implementing distributed ledger technology and blockchain in various industries
Implementing appropriate supervisory methods
Developing and strengthening international cooperation

Article 7: Basic Principles of State Regulation

Five Key Principles:

Expediency: Justified necessity of regulating virtual asset circulation to ensure technological development and risk prevention
Adequacy: Proportionality of risks, forms, and levels of regulation considering all acceptable alternatives
Balance: Ensuring balance of interests of virtual asset circulation participants in regulatory activities
Predictability: Consistency of regulation, including plans for preparing draft regulatory legal acts, allowing participants to plan their activities
Environmental Safety: Compliance with environmental protection requirements using environmentally clean, safe, and minimally hazardous technologies, including renewable energy sources

Article 8: Types of Regulated Activities

Three types of activities are recognized as regulated:

Mining
Emission (issuance) and initial placement of virtual assets
Activities of virtual asset service providers

Article 9-14: Regulatory Bodies and Their Competencies

Cabinet of Ministers of Turkmenistan (Article 10):

Determines unified state policy
Approves procedures for organizing emission, initial placement, and circulation of virtual assets
Approves rules for state procurement of virtual assets
Establishes conditions for foreign issuers to issue virtual assets in Turkmenistan
Sets state fees for registration of emission and public placement

Central Bank of Turkmenistan (Authorized Body) (Article 11):

Implements state policy for virtual asset market development and functioning
Develops state programs for implementing distributed ledger technology
Conducts state registration of miners and issues registration certificates
Issues licenses to virtual asset service providers
Conducts state registration of emission and/or public placement of virtual assets
Maintains registry of virtual asset exchange operators
Applies enforcement measures against service providers for violations
Monitors and evaluates the effectiveness of virtual asset circulation

Ministry of Finance and Economics (Article 12):

Participates in implementing state policy
Controls compliance with anti-money laundering, counter-terrorism financing, and counter-proliferation financing legislation
Develops state development program projects

Ministry of Communications (Article 12):

Ensures Internet access for persons engaged in virtual asset activities
Provides externally protected Internet network

Ministry of Energy (Article 12):

Determines tariff establishment procedures and rules for providing electricity to miners and service providers
Issues permits for connecting installations to energy systems
Determines possible installation placement sites
Controls electrical energy use in project development, construction, and operation

Other Central Executive Bodies (Article 13):

Participate in implementing unified state policy
Adopt regulatory legal acts in coordination with the authorized body
Interact on matters of ensuring virtual asset circulation

Local Executive Bodies (Article 14):

Ensure implementation of unified state policy
Facilitate virtual asset circulation in their territories
Support entities engaged in virtual asset activities

Article 15: Rights and Obligations of Legal Entities and Individuals

Rights:

Own, use, and dispose of virtual assets
Exchange virtual assets for other types of virtual assets
Acquire or sell virtual assets in accordance with established procedures
Engage in mining
Conduct other activities using virtual assets
Legal entities may issue and place their own virtual assets in Turkmenistan and abroad

Obligations:

Comply with Turkmenistan legislation on virtual assets
Provide information and reports on virtual asset transactions within established deadlines and procedures

CHAPTER III: MINING OPERATIONS

Article 16: Mining

Mining is carried out in the form of private and industrial mining
Private mining is conducted by individual entrepreneurs (residents and/or non-residents)
Industrial mining is conducted by legal entities (residents and/or non-residents)
Covert mining is PROHIBITED in Turkmenistan

Article 17: Electronic Registry of Miners

The Electronic Registry of Miners is an information system (resource, hardware and software of the authorized body) for remote registration and providing registration certificates to miners, integrated with the State Services Portal.

Main Objectives:

Maintaining records and creating a unified database of miners operating in Turkmenistan
Providing remote registration capability
Ensuring transparency, controllability, and increased energy efficiency in mining
Providing favorable conditions for miners
Studying and preparing analytical and statistical materials

Article 18: Miner Registration

Registration Requirements:

Persons engaged in mining MUST undergo state registration
Registration is conducted EXCLUSIVELY in electronic form via the Internet with remote registration capability
Registration certificate (with QR code) is issued electronically
Legal entities and individual entrepreneurs may begin mining from the day of receiving the registration certificate
Registration certificate is issued with UNLIMITED validity period

Requirements and Conditions for Obtaining Registration Certificate:

Mandatory registration with all necessary information specified by the Cabinet of Ministers
Payment of registration fee
Ownership of mining equipment
Possession of an active virtual asset wallet for crediting virtual assets obtained from mining
Ensuring technical serviceability and proper quality of electrical supply system with fire, sanitary, and technical safety requirements
Non-engagement in covert mining
Providing information related to mining or virtual asset circulation free of charge within established deadlines upon request by the authorized body

Article 19: Joint Mining Activities – Mining Pools

Miners may organize mining pool activities for joint operations
Mining pool organizers may be legal entities or individual entrepreneurs registered in Turkmenistan
Mining pool organizers provide services to combine the capabilities of several technical and hardware devices used by mining pool participants to acquire virtual assets and distribute mined virtual assets among participants
Legal entities organizing mining pools may also be virtual asset service providers
Mining pool organizers must register and comply with requirements defined in Article 18
The authorized body supervises compliance with these requirements

CHAPTER IV: EMISSION AND PUBLIC PLACEMENT OF VIRTUAL ASSETS

Article 20: Emission and Public Placement

Purposes:

Attracting investments and borrowed funds
Ensuring accounting, exchange, and certification of ownership rights to property

The procedure for organizing and conducting emission, initial placement, and circulation of virtual assets is determined by the Cabinet of Ministers.

Article 21: State Registration

Emission and/or public placement of virtual assets by issuers is subject to state registration by the authorized body.

Article 22: Grounds for Refusal of Registration

Registration may be refused if:

Documents presented for registration and information contained therein do not comply with Turkmenistan legislation
The issuer fails to comply with the adopted decision on virtual asset emission
State fees and/or payments required by legislation are not paid

Article 23: Suspension, Cancellation, or Invalidation of Emission

Emission and/or public placement may be:

Suspended by the authorized body upon discovery of violations of legislation requirements or false data in published information until violations are eliminated
Deemed Failed by the authorized body if the issuer fails to eliminate violations that led to suspension
Declared Invalid upon corresponding court decision

Consequences:

All virtual assets of the issue must be withdrawn from circulation
Funds received by the issuer from placing virtual assets declared failed or invalid must be returned to their owners
Costs related to declaring emission failed or invalid are borne by the issuer
The issuer may appeal to court if disagreeing with suspension, cancellation, or invalidation decisions

Article 24: State Fees and Payments

State fees for registration of emission and/or public placement are collected in accordance with Turkmenistan legislation
The amount, collection procedure, and payment of state fees are established by the Cabinet of Ministers
Services for emission and/or public placement are provided on a paid basis in the procedure established by the authorized body

Article 25: Unified State Registry of Virtual Asset Emission

The Unified State Registry must contain information about:

Issuer name
Quantity and nominal value (as of registration date) of virtual assets
Other information in accordance with Turkmenistan legislation

The procedure for maintaining the registry is established by the Cabinet of Ministers.

Article 26: Virtual Asset Wallet

Virtual asset wallets are created to enable storage and transactions with virtual assets
Wallets are opened by virtual asset exchange operators after completing identification and verification procedures in accordance with the Law “On Counteracting Legalization of Proceeds from Crime, Terrorism Financing, and Financing of Proliferation of Weapons of Mass Destruction”

CHAPTER V: VIRTUAL ASSET SERVICE PROVIDERS AND CRYPTO EXCHANGES

Article 27: Virtual Asset Service Providers

Definition: Legal entities registered in Turkmenistan, operating under a license and providing services related to virtual assets.

Who CANNOT Be Founders, Participants (Shareholders), or Officials:

Individuals permanently residing in offshore zones and/or legal entities (non-residents) registered in such zones
Individuals and legal entities having accounts in banks located in offshore zones
Legal entities whose participant (shareholder) is an individual permanently residing in an offshore zone
Political parties, trade unions, and other public associations
Legal and natural persons included in the list of persons with information about involvement in terrorism, terrorism financing, and financing of proliferation of weapons of mass destruction
Legal and natural persons about whom negative information exists based on data from state bodies combating terrorism, extremism, drug trafficking, and proliferation of weapons of mass destruction
Persons with outstanding or unremoved criminal records, including in other states
Persons with unfulfilled court decisions on payment of financial obligations
Other persons established by Turkmenistan legislation

Article 28: Authorized Capital

The size of the authorized capital of virtual asset service providers is established in accordance with Turkmenistan legislation.

Article 29: Services Related to Virtual Assets

Five Types of Services:

1. Purchase, Sale and/or Exchange of Virtual Assets

Activities involving buying, selling, and exchanging virtual assets

2. Exchange Between Virtual Assets

Exchanging one or several types of virtual assets for other types

3. Transfer of Virtual Assets

Transferring virtual assets on behalf of and in the interests of the client by the service provider itself or through another provider

4. Storage, Management, and Control of Virtual Assets

Responsible storage and/or management of virtual assets or instruments allowing control of virtual assets
Must ensure safety of virtual assets and/or control instruments with the ability to independently move virtual assets in the interests of and on behalf of third parties
Service provider moves virtual assets only when such management or movement is carried out in accordance with the virtual asset owner’s instructions
Providers offering storage services MUST ensure client funds are stored on electronic media not connected to the Internet (cold wallets) in the procedure established by the authorized body

5. Financial Services Related to Placement and/or Sale of Virtual Assets

Providing and/or participating in providing financial services related to initial placement and/or sale of virtual assets by the issuer
Service provider may conclude transactions regarding placement or sale of virtual assets on behalf of, at the expense of, and in the interests of the issuer

Article 30: Virtual Asset Exchange Operator

A legal entity registered in Turkmenistan, operating under a license issued by the authorized body and entered in the registry of virtual asset exchange operators
Founders or participants (shareholders) may be legal entities and individuals (residents and/or non-residents)
Operators provide services specified in paragraphs 1 and 2 of Article 29 through specialized platforms
The authorized body conducts state registration of operators and maintains their registry
The procedure for operator activities and registry maintenance is established by the Cabinet of Ministers

Article 31: Procedure and Requirements for Providing Services

Key Provisions:

Services related to virtual assets are provided EXCLUSIVELY on specialized platforms
Services are provided by virtual asset service providers based on licenses issued by the authorized body
Service providers may provide one or several services specified in Article 29, except for conditions and limitations provided
To expand the range of services, providers may engage other providers as agents
For risk assessment and regulatory compliance, providers create digital client profiles including information about the client, fund transfers (transactions), and other indicators for monitoring activities and preventing undesirable operations
Credit institutions of Turkmenistan (except virtual asset exchange operators) are PROHIBITED from providing services specified in paragraphs 1 and 2 of Article 29
The procedure and requirements for credit institutions to provide services specified in paragraphs 3, 4, and 5 of Article 29 are determined by acts of the Central Bank
The procedure and requirements for legal entities (not credit institutions) to provide services specified in Article 29 are determined by the authorized body
Protection of specialized platforms and personal data stored on them is carried out in accordance with Turkmenistan legislation on information and cybersecurity

Article 32: Distributed Data Ledger

Created by the authorized body and also by other virtual asset service providers based on permission from the authorized body
Created as a system where information is stored on multiple network nodes and/or computing devices (not on a central server) to ensure security, transparency, and impossibility of data forgery

Article 33: Crypto Exchange Activities

Crypto exchanges operate as legal entities in organizational-legal forms (except enterprises of public organizations) determined by Turkmenistan legislation
Crypto exchanges may provide services related to virtual assets specified in Article 29 as virtual asset service providers
As service providers, crypto exchanges MUST ensure protection of personal information and virtual assets of their clients
The procedure for creation, functioning, and reporting of crypto exchanges is determined by the Cabinet of Ministers in accordance with this Law

Article 34: Licensing

Licensing of virtual asset service provider activities is carried out in accordance with Turkmenistan legislation on licensing certain types of activities.

Article 35: Enforcement Measures Against Service Providers

Objectives:

Operational response to risks in service provider activities
Protection of interests and rights of clients and other consumers

Grounds for Application: Violations of norms and requirements established by this Law

Types of Enforcement Measures:

Prescription (directive orders)
Imposing fines on service providers and their officials
Restrictions on providing certain types of services related to virtual assets
Suspension of license
Revocation of license

The Authorized Body Applies Measures in Cases of:

Violation of Turkmenistan legislation when conducting virtual asset service provider activities
Obstruction of supervision and inspection activities conducted by the authorized body
Actions or inaction of service providers that threaten the rights and legitimate interests of clients and other consumers
Actions or inaction of officials of service providers that entail violation of Turkmenistan legislation, suspension and/or revocation of license, forced liquidation, or bankruptcy of the service provider
Failure to provide or provision of untimely, inaccurate, incomplete reporting and/or other information in the established procedure to the authorized body

Article 36: Anti-Money Laundering Measures

Miners and virtual asset service providers MUST take measures to counter legalization of proceeds from crime, terrorism financing, and financing of proliferation of weapons of mass destruction and implement requirements of Turkmenistan legislation in this area.

CHAPTER VI: ADVERTISING IN THE VIRTUAL ASSET SPHERE

Article 37: Requirements for Advertising

Mandatory Compliance: Persons engaged in virtual asset activities must comply with advertising requirements for virtual assets and their activities as provided by Turkmenistan legislation.

Advertising Requirements:

Advertising about virtual assets placed (distributed) both in Turkmenistan and abroad (including involving third parties) MUST:

Contain warnings about participation risks
Contain information about potential risks in operations related to virtual assets, including:
- Complete loss of funds and other civil law objects transferred in exchange for virtual assets, including due to volatility of virtual asset value
- Technical failures (errors)
- Commission of unlawful acts, including theft
- Lack of state backing for virtual assets
- That virtual assets are NOT a means of payment in Turkmenistan
If advertising includes an offer, it must provide all conditions of the proposed contract and description of actions for accepting the offer
If advertising describes past indicators, modeled indicators, and indicators that may occur in the future, consumers must be specifically explained the essence of such indicators and the probabilistic nature of conclusions made based on them, in compliance with Turkmenistan advertising legislation
General advertising requirements are implemented in accordance with Turkmenistan advertising legislation

Article 38: Advertising Restrictions

Advertising of Virtual Assets MUST NOT Contain:

Promises or guarantees about the effectiveness (profitability) of activities related to using virtual assets, except for cases of indicating information about activity effectiveness for the preceding period confirmed by an audit organization
Information about luxury items, bonuses, and discounts
Information about conducting transactions with virtual assets as an easy way to get rich
Claims about the significance of activities related to using virtual assets for achieving professional or personal success
Images of minors
Statements condemning non-participation in activities related to using virtual assets

CHAPTER VII: VIOLATIONS IN THE VIRTUAL ASSET SPHERE

Article 39: Types of Violations

Violations include:

Conducting activities without a license or certificate in the virtual asset sphere
Conducting activities without complying with licensing and permit requirements and conditions provided by Turkmenistan legislation
Conducting covert mining
Non-compliance with virtual asset advertising requirements
Other violations established by Turkmenistan legislation

Article 40: Liability for Violations

Violation of this Law entails liability established by Turkmenistan legislation.

CHAPTER VIII: FINAL PROVISIONS

Article 41: Limitations in the Virtual Asset Sphere

Important State Protections and Restrictions:

The Cabinet of Ministers of Turkmenistan is NOT liable in case of depreciation or loss of virtual assets and does not compensate their value
The state does NOT answer for obligations of virtual asset service providers
Naming Restrictions: Persons engaged in mining, emission, initial placement of virtual assets, and virtual asset service providers are PROHIBITED from using in their names or symbols the words “state,” “Turkmenistan,” “Turkmen,” “Turkmenistani,” “national” in full or abbreviated form, in any language and any combination, including using both lowercase and uppercase letters or their combinations
Terminology Restrictions: Legal entities and individual entrepreneurs, except those engaged in mining, emission, initial placement of virtual assets, and virtual asset service providers, are PROHIBITED from using in their names and advertising campaigns the words and/or phrases “virtual asset,” “cryptocurrency,” “digital asset”

Article 42: Dispute Resolution

Disputes arising in the virtual asset sphere are resolved in the procedure established by Turkmenistan legislation.

Article 43: Entry into Force

This Law enters into force on January 1, 2026.

KEY TAKEAWAYS

Comprehensive Framework: Turkmenistan has created one of the most detailed regulatory frameworks for virtual assets in Central Asia, covering mining, issuance, trading, and service provision.
Licensing Regime: All major activities (mining, service provision, exchanges) require registration or licensing through the Central Bank.
No Legal Tender Status: Virtual assets are recognized as objects of civil rights but explicitly are NOT legal tender in Turkmenistan.
Strict AML/KYC: Anonymous wallets and transactions are prohibited; all participants must be identifiable in accordance with anti-money laundering standards.
Consumer Protection Focus: Extensive advertising restrictions, mandatory risk disclosures, and prohibitions on misleading claims demonstrate strong consumer protection orientation.
Environmental Considerations: Unique among crypto regulations, the law explicitly includes environmental safety as a core principle of state regulation.
State Oversight: The Central Bank (authorized body) has comprehensive regulatory and supervisory powers over the entire virtual asset ecosystem.
Cold Storage Requirement: Service providers must store client funds on devices not connected to the Internet.
Enforcement Mechanisms: Clear enforcement measures ranging from prescriptions to license revocation ensure regulatory compliance.
International Alignment: The law aligns with international standards (FATF) while adapting them to Turkmenistan’s specific context and economic development goals.

/// nCa, 5 December 2025