Draft of the Cryptocurrency Framework Published
A consultative meeting with private sector stakeholders was held at the National Center for Cyberspace to review the draft framework for cryptocurrency regulation. This meeting ultimately led to the approval of a document that serves as a legal infrastructure, providing a clear vision for the management and development of the cryptocurrency ecosystem in the country. With the participation of multiple institutions and input from experts, this document aims to create transparency and legality in cryptocurrency activities while facilitating economic development, attracting investment, and supporting industry stakeholders.
Table of Contents
The consultative meeting with private sector stakeholders in the cryptocurrency sector regarding the draft regulation framework was held in Azar 1403 at the National Center for Cyberspace. In this meeting, Hossein Dalirian, the spokesperson of the National Center for Cyberspace, elaborated on the necessities, objectives, and drafting process of the cryptocurrency framework. Emphasizing the importance of regulated governance in this field, he introduced this document as a strategic step toward addressing challenges and ensuring transparency in the crypto ecosystem. He stated that the National Center for Cyberspace has an approach focused on development in the crypto sector and is working to make activities in this field more transparent and lawful through this document. He highlighted one of the main challenges in the crypto ecosystem as the presence of subjective and inconsistent perspectives and said: “The approval of this document can help rectify these viewpoints and establish a legal umbrella over this ecosystem. This will prevent redundant efforts and create a clear and cohesive environment for activities.”
Participation of Multiple Institutions in Drafting the Document
The spokesperson of the National Center for Cyberspace, referring to the drafting process of the cryptocurrency regulatory framework, stated: “The Ministry of Economic Affairs and Finance, as the primary authority for this document, has collaborated with eight other institutions, including the Judiciary, the Ministry of Industry, Mine and Trade (MIMT), the Ministry of Information and Communications Technology (ICT), the Ministry of Energy, the Central Bank, the Law Enforcement Command, and the Intelligence Organization of the IRGC, to prepare the initial draft. The National Center for Cyberspace, after receiving this draft, gathered expert opinions and additional feedback from cooperating institutions through the Regulatory Affairs Deputy and then submitted the document to the Supreme Commission for Cyberspace Regulation for review and approval.” Dalirian also emphasized the importance of considering the opinions of private sector stakeholders in this field, stating: “The National Center for Cyberspace has held multiple meetings with stakeholders, officials, and experts. With the aim of engaging all stakeholders, the Center has made efforts to incorporate their feedback into the cryptocurrency regulation document, and these opinions will be presented at the Supreme Commission for Cyberspace Regulation.” He further noted: “The cryptocurrency regulation document serves as a strong foundation for governance in this domain, benefiting both the country and its people. The consensus among responsible institutions demonstrates the government’s serious commitment to resolving uncertainties in this field and establishing effective oversight and clear regulations for cryptocurrency stakeholders.” The spokesperson also highlighted the importance of this document as a high-level policy framework, stating: “The document will be approved by the Supreme Commission for Cyberspace Regulation. After completing the necessary legal procedures and being officially issued, it will serve as the guiding framework for all active institutions in the country regulating this sector. Once the document is issued, all previous regulations that conflict with it will be revoked, and legislative bodies must base their frameworks on this document.”
Emphasis on Freedom and Development
Additionally, Amir Sayyah, Deputy for Economic and Regulatory Affairs at the National Center for Cyberspace, stated in this meeting: “The National Center for Cyberspace approaches the digital asset ecosystem with a developmental perspective and seeks to manage the risks associated with this ecosystem. Therefore, in finalizing this document, expert opinions and feedback from industry stakeholders have been gathered to ensure a comprehensive and practical regulatory framework.” He added: “This document is fundamentally based on the principles of freedom and development. The National Center for Cyberspace aims to define the boundaries of illegal activities while creating an open environment for private-sector operations. Given the Supreme Leader’s emphasis on development and job creation, this document strives to present clear policies and delineate the boundaries between lawful activities and violations.” Sayyah pointed out that blockchain technology and cryptocurrencies are identity-agnostic and high-risk, stating: “This document provides a secure and supportive environment for stakeholders, with oversight being conducted retrospectively. This ensures that operational boundaries are defined before activities commence. This approach not only facilitates investment and job creation but also encourages other economic actors to enter this space.”
Cryptocurrency Oversight Should Be Retrospective, Not Preemptive
Sayyah outlined the objectives of the document, emphasizing legal regulation, liberalization, and oversight in the cryptocurrency sector, stating: “This document is structured into four sections: production and issuance of digital assets, storage and custody, secondary markets and exchange, and service provision. The primary goal is to differentiate roles and responsibilities in this domain to create a unified structure and streamline efforts against illegal activities.” He also noted: “Under this document, the National Financial Security Council, affiliated with the Ministry of Economic Affairs and Finance, will oversee its implementation. The Council’s responsibilities include aligning regulations, resolving ambiguities, handling disputes, supervising service providers through industry associations, and reporting to the Supreme Council of Cyberspace.” Sayyah stressed that oversight in this field should be retrospective rather than preemptive, adding: “Regulatory frameworks should have clear and transparent boundaries for economic actors. The ‘kill switch’ for businesses should be out of reach, meaning that violators should be penalized rather than shutting down businesses altogether. If anyone resists transparency and regulatory compliance, pushing the use of this technology towards underground activities, they will face consequences.”
Web 3.0 and Token Economy: A $35 Billion Opportunity for Iran
In this meeting, Pooria Asteraky, editor-in-chief of the Blockchain and Digital Assets Research Journal, analyzed the characteristics and impact of Web 3.0 and the token economy. Highlighting the key features of Web 3.0—such as decentralization, high volume of microtransactions, borderless liquidity, and asset tokenization—he emphasized that these developments significantly increase asset value. Asteraky stated that digitalization, ease of asset transfer, and storage enhance asset value, adding: “In the next five years, the token economy could contribute $1.76 trillion to global GDP. Iran’s share of this could be around 2%, amounting to approximately $35 billion. Additionally, the total value locked in DeFi will grow from $45 billion to $800 billion, and by 2030, 10% of the global economy will be token-based.” Discussing Iran’s position, Asteraky pointed out: “So far, Iran has primarily benefited from crypto mining, holding, and trading. However, there are other opportunities, particularly through collaboration with BRICS, which could benefit Iran. Unfortunately, we have seen destructive regulations in the mining sector. Up until 2019, Iran held a 10% share of global mining, but due to poor regulations, this share dropped to 0.3% by 2023, according to on-chain data. Policies such as pricing electricity for miners above export rates and mandating cryptocurrency sales at below-market rates to the government have reduced the value-creation potential of mining.” Asteraky also criticized the Central Bank’s crypto framework, describing it as restrictive and prohibitive. He argued that the document contains vague and incorrect definitions, and some crucial blockchain sectors—such as tokenization—are entirely restricted. He concluded by stressing the need for clear and supportive regulations, warning: “Just as we fell into the trap of excessive internet censorship years ago, we are now seeing a similar approach to Web 3.0. Meanwhile, other countries are actively leveraging these opportunities.”
Establishment of the Financial Security Council for Centralized Oversight of Digital Assets
Mohammadreza Alipour, a legal researcher, also commented on the draft cryptocurrency framework, stating: “The approach focuses on developing the digital asset ecosystem while managing associated risks. The goal is to provide solutions that facilitate ecosystem growth while addressing government concerns over oversight and regulation. The draft classifies digital assets into categories such as cryptocurrencies, asset-backed tokens, stablecoins, and utility tokens. It also proposes the establishment of a Financial Security Council under the Ministry of Economy as the primary oversight body.”
In this meeting, blockchain activists discussed the challenges and opportunities of regulation in the cryptocurrency ecosystem. The proposal to establish a supra-organizational center for better oversight and management of the industry was presented as an effective solution to enhance supervision. Activists in this field pointed to the untapped potential of sandboxes, emphasizing that only certain ministries, such as the Ministry of Industry, Mine, and Trade, have utilized them in areas like the online gold system, while other entities have yet to fully leverage this capacity. Additionally, the need for borderless financing for the cryptocurrency industry was highlighted. Crypto activists also noted the resistance within certain sectoral sandboxes that oppose innovation, including financial institutions that hinder the growth and development of new advancements.
A Step Forward in the National Center for Cyberspace
The change in approach by the Supreme Council of Cyberspace, which has now taken on a regulatory role after years, was highlighted as one of the positive developments in this meeting. Activists emphasized that the distinction of roles among institutions in the draft is its strong point, as this ensures that each entity can clearly fulfill its responsibilities. At the conclusion of this meeting, cryptocurrency sector activists expressed satisfaction with the drafting process of the cryptocurrency regulatory framework and evaluated it as a progressive step forward. The emphasis on a developmental approach, the distinction between regulatory and supportive roles of institutions, and the establishment of a secure and regulated framework for economic activities were considered among the positive aspects of this draft. Ultimately, the meeting underscored the necessity of continued cooperation between the government and the private sector to achieve the outlined objectives.
Draft of the Digital Asset Regulation Framework
In this session, the draft of the digital asset regulation framework was presented by the National Center for Cyberspace to private sector activists for review. After reaching a consensus among stakeholders, it will be approved by the High Commission for Cyberspace Regulation. The following sections of this draft were outlined:
Section 1: Definitions and Terminology
The first section of this draft defines terms and concepts related to digital assets. Article 1 states that these definitions, in addition to their legal status, will serve as the basis for identifying and resolving technical and expert ambiguities in various topics for the responsible institutions. The definition of digital assets in this section is as follows: any digital representation of value or rights that can be stored and transferred electronically using distributed ledger technology. Digital assets are categorized into four types: 1. Asset-backed digital assets, any digital asset that holds value equivalent to a fixed amount of a tangible asset or a collection of assets. 2. Cryptocurrency, a form of encrypted digital currency that is created either centrally (by a central bank) or decentralized and is exchanged in a decentralized manner. 3. Digital currency, a digital form of a country’s official currency issued and supplied by an authorized public institution of that country. 4. Utility digital assets, any digital asset issued and offered to provide access to a product, service, or privilege. Additionally, a clause states that digital assets are not limited to these types. If any disputes arise regarding their nature or classification, the Secretariat of the High Commission for Cyberspace Regulation will serve as the specialized authority for determining their classification.
Section 2: Institutional Design
This section focuses on institutional design. Article 2 states that the National Financial Supply Council, as per Article 2 of the Production and Infrastructure Finance Law, is responsible for overseeing the implementation of assigned responsibilities, ensuring compliance with regulatory mandates, and aligning actions with overarching policies and objectives. Article 3 specifies that any regulatory provisions or directives concerning digital assets issued by any entity must be approved by the council. Article 4 assigns the responsibility of granting service provider licenses for digital assets to a professional association approved by the Secretariat of the High Commission for Cyberspace Regulation. The council can approve service conditions for various offerings, including initial issuance, secondary market creation, asset custodianship, collateralization, and portfolio management. Article 5 states that the Secretariat of the High Commission for Cyberspace Regulation must continuously review the council’s performance in the digital asset sector. The Secretariat must report to the High Commission every six months. It also has the authority to temporarily suspend non-compliant actions by responsible entities until a final decision is made by the High Commission.
Section 3: Storage and Custody of Digital Assets
This section addresses digital asset storage and custody. Article 6 states that service providers are responsible for safeguarding the digital assets held by them. The council must approve frameworks and standards for digital asset storage through regulations. The Secretariat must assess proposed storage mechanisms for potential risks and ensure their compliance with council-approved regulations. It will also oversee adherence to these standards.
Section 4: Production and Issuance of Digital Assets
This section discusses the production and issuance of digital assets. Article 7 mandates that the Ministry of Industry, Mining, and Trade draft necessary regulations for the manufacture, import, and use of cryptocurrency mining equipment and present them to the council. Article 8 obligates the Ministry of Petroleum and the Ministry of Energy to draft regulations for energy production and supply for mining farms that use energy-intensive consensus mechanisms. These regulations include incentives for investment in renewable energy, improvements in power grid efficiency, and automated energy consumption controls. A clause in this article prioritizes energy allocation for large-scale mining farms (above 5 MW) hosting small investors and those operating in designated locations specified by the Ministry of Petroleum or Energy.
Article 9 states that the initial issuance of digital assets, except for asset-backed digital assets and cryptocurrencies, will be permitted upon registration through the national licensing portal, either via service providers or designated websites. Licensing will require public disclosure of a whitepaper, identity verification of the issuer, and details on the issuance process. Article 10 states that the issuance of asset-backed digital assets to the public will require approval from the Securities and Exchange Organization. The related regulation must be approved by the council. Required documents include a whitepaper with an operational plan, business model, corporate governance structure, liquidity policies, and asset backing mechanisms. Clause 1 of this article mandates that licensing should not take longer than 30 days. Clause 2 requires the Secretariat to develop oversight guidelines for custodians of backed assets within three months.
Central Bank’s Authority Over Cryptocurrencies and Payment Instruments
According to Article 11, the issuance and use of cryptocurrencies as payment instruments will be governed by the regulations of the High Council of the Central Bank of Iran. The Central Bank will be responsible for implementation, and the Secretariat must review compliance with overarching policies.
Article 12 states that licensing conditions for utility digital assets will depend on the type of service or product they provide access to. If no specific regulatory authority is assigned, their issuance will not require special licensing. Article 13 requires the Secretariat to review and define mechanisms for digital asset creation aimed at financial purposes.
Section 5: Secondary Market and Digital Asset Exchanges
This section outlines secondary markets and digital asset exchanges. Article 14 allows licensed service providers to create secondary markets for digital assets, provided they comply with storage and disclosure requirements. Article 15 mandates that secondary markets adhere to anti-money laundering and counter-terrorism financing regulations. The Financial Intelligence Unit will propose specific AML/CFT regulations for digital assets, which must be approved by the council.
According to Article 16, the directive on adhering to security standards for safeguarding user rights and the technical infrastructure of secondary markets shall be approved by the council in collaboration with the Judicial Deputy of the Judiciary and the Ministry of Communications and Information Technology, with the Secretariat of the Council and the National Center for Cyberspace taking the lead. Additionally, under Article 17, the Iranian Registry of Deeds and Properties is required to establish an integrated online registration infrastructure for the transfer of cryptocurrencies that represent ownership of specific assets, in order to enhance transparency and protect user rights. This infrastructure must be provided through web services and made accessible to individuals via the National Center for Governmental Information Exchange.
Article 18 stipulates that the National Competition Center is obligated to identify any actions by private or public entities that result in securing a dominant position for the supply and demand of cryptocurrencies, causing disruption or delay in the functioning of cryptocurrency exchange platforms, complicating the identification of genuine orders in cryptocurrency trading databases, creating misleading or false directions regarding the supply, demand, or price of cryptocurrencies, or strengthening foreign competitors of domestic service providers, thereby affecting market integrity, financial stability, and investor rights. The center must then refer the case to the Competition Council. The Competition Council, in turn, has the authority to temporarily or permanently restrict or halt the activities of violators.
Section 6: General Service Provision Requirements
Section 6 outlines the conditions for providing public services. According to Article 19, the Secretariat of the Council is required to collaborate with the Ministry of Culture and Islamic Guidance to prepare and, through the Council, approve the necessary guidelines for advertising, marketing, and activities on social media related to the services provided by cryptocurrency service providers. Article 20 states that the Secretariat of the Council, in cooperation with the private sector, must develop a user education manual for all activities within the cryptocurrency ecosystem, including the storage and transfer of assets, investment, and more, to prevent phishing and various types of fraud. Under Article 21, the Secretariat of the Council is obligated to collaborate with the Central Insurance of Iran to prepare new mechanisms for insuring cryptocurrencies or their backing and, after approval by the Council, issue them to manage risks for users and service providers. Additionally, according to Article 22, the Secretariat of the Council is required to determine the financial and legal conditions and standards for the collateralization of cryptocurrencies through the national collateralization system, enabling the collateralization of domestic assets within the monetary-banking networks to enhance the usability of cryptocurrencies and encourage user activity within the domestic ecosystem. Article 23 stipulates that the Secretariat of the Council must, in addition to using cryptocurrencies for external financing (finance) and foreign investment as outlined in Clause (c) of Article 29 of the Law on Financing Production and Infrastructure, determine the conditions for using cryptocurrencies for this purpose and submit them for approval by the Council.
Perhaps the final article can be considered the conclusive ruling of this regulation. This article states: “Given the authority delegated by the Supreme Council of Cyberspace to the High Commission for Regulatory Affairs, all resolutions and regulations contrary to this framework in the field of cryptocurrencies will be null and void from the date of approval of this document. The National Center is obligated, based on the authority delegated by the Supreme Leader and the Supreme Council of Cyberspace, to prevent the approval or issuance of guidelines in this field as necessary and to pursue the necessary amendments to previous resolutions with the relevant authorities.”
Approval of the Digital Asset Regulation Framework
A day after this meeting, on December 18, 2024, the sixth session of the High Commission for Cyberspace Regulation, presided over by “Seyed Mohammadamin Aghamiri,” convened with representatives from all relevant institutions. The meeting reviewed the overall framework of the “Digital Asset Regulation Framework,” which was ultimately approved and issued on January 9, 2025.
