Registration as a resident of the High-Tech Park (HTP) is traditionally perceived as a tool for tax optimization and access to a special legal regime for IT businesses. In practice, however, the HTP’s approach to reviewing applications is not universal. Depending on the declared type of activity, different requirements apply to applicants, and for certain categories of projects a special, more complex procedure is established to assess compliance with the conditions of residency.

Such specific applicants include companies and teams whose business projects involve activities related to digital tokens, crypto platforms, cryptocurrency exchange, as well as other forms of token use, including those having features of financial, investment, or exchange activity. These areas lie at the intersection of IT, financial technologies, and capital market regulation, which explains the increased attention of the HTP to the legal, organizational, and technical business models of such projects.

For these applicants, obtaining HTP resident status is not a formal procedure but a comprehensive process in which not only the technological component of the project is assessed, but also the management structure, internal control system, sustainability of the business model, and potential risks for clients and the market as a whole. For this reason, special requirements have been established for certain categories of applicants that supplement the general conditions for registration with the HTP.

A lack of understanding of these specifics at the application preparation stage often leads to refusal of registration or the need for substantial revision of the business project. In this article, we examine which applicants fall into specific categories, which types of activities are subject to special regulation, and what requirements must be met in order to successfully complete the registration procedure as a resident of the High-Tech Park.

General HTP Approach to Assessing Specific Categories of Applicants

The legal regime of the High-Tech Park is based on the principle of differentiated regulation. This means that requirements for applicants are formed not based on a formal affiliation with the IT sector, but taking into account the nature and substance of the specific activity declared in the business project. The HTP proceeds from the understanding that different types of digital and technological activities involve varying levels of legal, financial, and reputational risks and therefore cannot be assessed according to uniform criteria.

For most classical IT companies (software development, outsourcing, product development), a basic set of requirements applies, as provided for by the general legal regime of the HTP. At the same time, projects related to tokens, crypto platforms, cryptocurrency exchange, and other forms of digital assets are initially regarded as activities with increased regulatory complexity. For such applicants, the HTP establishes additional conditions aimed at ensuring transparency, sustainability, and manageability of their activities.

Why Special Criteria Apply to Certain Types of Activities

Special criteria for certain categories of applicants are primarily обусловлены by the economic and legal nature of the relevant activities. Operations with tokens and cryptocurrencies affect the interests of an unlimited number of persons, involve work with funds and digital assets, and in some cases are essentially close to financial services, investment activities, or exchange operations.

Accordingly, when reviewing applications from such applicants, the HTP assesses not only the technological component of the project but also the company’s ability to:

• manage risks arising from the conduct of such activities;
• ensure protection of clients’ rights and legitimate interests;
• establish internal control and accountability processes;
• ensure information and cybersecurity.

Special criteria allow HTP to minimize systemic risks associated with the use of tokens and cryptocurrencies, while ensuring a legal and predictable mode of operation for bona fide market participants.

The Role of the Declared Type of Activity in the Registration Decision

A key element in assessing an application is the declared type of activity reflected in the business project. It determines the category to which the applicant will be assigned and which requirements will apply when considering registration as an HTP resident.

It is important to note that the HTP evaluates not only the formal name of the activity but also its actual substance. If a business project provides for operations with tokens, interaction with client funds, organization of trading, or placement of digital assets, the applicant will be classified as belonging to a specific category even if such elements are presented as auxiliary or ancillary.

An incorrect or simplified qualification of the type of activity may result in the application being deemed non-compliant with the declared conditions and the submitted documents being considered insufficient for a positive decision.

Relationship Between General HTP Requirements and Special Requirements

For certain categories of applicants, special requirements do not replace the general HTP requirements but supplement them. This means that such applicants must simultaneously:

• comply with the basic registration conditions established for all HTP residents;
• fulfill additional requirements related to the specific type of activity.

General requirements form the basis of the legal status of an HTP resident and concern the applicant’s structure, disclosure of information, compliance of the business project with the objectives of the Park, and observance of the legal regime as a whole. Special requirements, in turn, regulate specific aspects of activities related to tokens, crypto platforms, and cryptocurrencies and imply a higher level of organizational and legal preparedness.

Thus, successful registration as an HTP resident for certain categories of applicants is possible only through a comprehensive approach combining compliance with the general rules of the Park and fulfillment of special requirements arising from the chosen business model.

Which Applicants Belong to “Specific Categories”

The High-Tech Park classifies as specific categories those applicants for resident status whose business projects provide for activities involving the use of digital tokens and cryptocurrencies. Such activities are expressly identified in the HTP legal framework and are considered an independent area requiring a special procedure for assessing compliance with residency requirements.

In particular, specific categories of applicants include projects involving:

• provision of services related to the creation and placement of digital tokens using the Internet, including token promotion services, consulting, and other ancillary services (ICO organizer activity);
• activity of a crypto platform operator, including organization and support of token transactions;
• activity of a cryptocurrency exchange operator related to the purchase, sale, and exchange of digital assets;
• other token-based activities, including those bearing features of professional or exchange securities activity, investment fund activity, securitization, as well as operations involving the creation and placement of proprietary tokens.

The unifying feature of such applicants is not so much the technology used as the economic and legal substance of the declared activity, which involves working with digital assets and the interests of third parties.

Differences from Classical IT Companies

Unlike classical IT companies engaged in software development, provision of IT services, or creation of digital products for specific customers, specific categories of HTP applicants are effectively involved in the circulation of digital assets and the organization of operations with them.

Such projects:

• work with client funds, electronic money, and tokens;
• create infrastructure for transactions between third parties;
• assume obligations toward an unlimited number of users;
• bear increased responsibility for the accuracy and security of operations.

Accordingly, the HTP assesses not only the technological implementation of solutions but also the applicant’s ability to ensure business process sustainability, protection of client rights, operational transparency, and an appropriate level of internal control. For classical IT companies, these aspects are generally not of such decisive importance when considering registration.

Increased Regulatory and Reputational Risks as Grounds for Special Requirements

The identification of specific categories of applicants is driven by the increased regulatory and reputational risks inherent in such projects. Activities involving tokens and cryptocurrencies may affect the financial interests of a wide range of persons and have consequences not only for a particular applicant but also for the business reputation of the HTP legal regime as a whole.

Key risks include:

• risk of breach of obligations toward token holders and platform users;
• risk of loss of funds due to technical failures, errors, or unlawful actions;
• risk of using activities in bad-faith or non-transparent schemes;
• risk of mixing IT activities with the actual provision of financial services.

For these reasons, the HTP applies special requirements aimed at a preliminary assessment of applicants’ organizational, legal, and technological readiness to conduct the declared activities. These requirements help minimize potential negative consequences and ensure a balance between digital economy development and protection of users’ and market interests.

Requirements for Applicants Conducting Token-Related Activities

Activities related to the creation and placement of tokens are defined by HTP as a separate category and are subject to a special assessment when considering applications for registration as residents. This is due to the fact that such projects directly affect the property interests of third parties and include the collection of funds or other assets of civil law in exchange for digital tokens.

When considering applications related to ICO, HTP analyzes not only the use of blockchain technologies, but also the economic model of the project, the nature of the applicant’s obligations and potential risks for participants.

Services for Token Creation and Placement

This category includes activities related to technical, organizational and legal support for the issuance of tokens and initial placement via the Internet. This may include the development of smart contracts, infrastructure configuration, organization of the token sale process and interaction with potential buyers.

In assessing such applicants, the HTP focuses on:

• the applicant’s role in the token creation and placement process;
• the existence of actual control over key elements of the project;
• the scope of obligations assumed toward token holders;
• the degree of involvement in operations with clients’ digital assets.

If the applicant effectively acts as a token placement organizer, stricter requirements apply than to companies providing purely technical services.

Token Promotion and Token Project Support Services

A separate group includes services related to the promotion of tokens, marketing support of ICO, attraction of users and investors, as well as comprehensive support of token projects at all stages.

Although such services may be auxiliary in nature, HTP evaluates them in terms of their impact on buyers of final tokens. If the applicant’s activities contribute to the distribution of tokens and the formation of expectations among an indefinite group of persons, they are considered as part of the ICO activities and are subject to special requirements.Particular attention is paid to:

• the applicant’s involvement in communication with potential token purchasers;
• the nature of information disseminated as part of promotion;
• the existence of mechanisms for disclosure of risks and limitations related to token acquisition.

Consulting and Other Ancillary Services

The ICO direction also includes consulting and other ancillary services if they are directly related to the creation, placement, or sale of tokens. These may include legal, financial, organizational, or technical consultations aimed at launching and operating a token project.

HTP evaluates not the official name of the service, but its actual content. If the consulting activities affect the structure of the token project, the fundraising model or the conditions of the third party’s participation, the applicant is considered a participant in the activities related to the tokens and must meet the established requirements.

Key HTP Focus Areas When Assessing Such Applicants

When reviewing ICO-related applications, the HTP emphasizes:

• transparency and good faith in interaction with token holders;
• existence of risk management mechanisms and prevention of obligation breaches;
• readiness to disclose information about tokens and related risks;
• ability to ensure information and technical security of operations;
• availability of internal documents and organizational measures governing activities.

The applicant must demonstrate that its activities are not formal or nominal and are structured with due regard for user interests and project sustainability.

Importance of the Business Model and Economic Substance Description

For ICO-related applicants, the business project is the key document on the basis of which the HTP forms an understanding of the real essence of the planned activities. Merely indicating the use of tokens or blockchain is insufficient; the economic substance of the project must be disclosed in detail.

The HTP assesses:

• the purpose of the tokens and their functions;
• how their value is formed;
• what obligations arise toward token holders;
• how these obligations are fulfilled;
• how risks are distributed among project participants.

The more complex and closer to financial markets the token project model is, the higher the requirements for the quality of the business model description and justification of its legal and economic soundness. A correct and transparent project description largely determines the success of registration as an HTP resident.

Requirements for Crypto Platform Operators

In the high-tech park, the crypto platform is considered as a specialized infrastructure that allows you to work with digital assets, including tokens and cryptocurrencies. The main function of such platforms is the organization, support and accounting of transactions between market participants using digital tokens.

Unlike conventional IT projects, the main object of which is software or service, the crypto platform includes interaction with customer funds or digital assets and responsibility for the accuracy and security of operations. This determines the classification of such applicants by a separate category and the need for special HTP requirements.

Specific Requirements for Such Applicants

Crypto platform operators’ activities are subject to enhanced regulation due to their direct impact on third-party property interests. The HTP identifies several key compliance criteria:

• Organizational structure: a clearly defined management and key personnel with competencies in blockchain technologies, finance, and compliance.
• Legal framework: development and maintenance of internal documents regulating operations, client interaction rules, and asset protection measures.
• Financial stability: confirmation of sufficient capital and resources to ensure uninterrupted platform operation and cover potential risks.
• Compliance and transparency: observance of anti-money laundering rules, client identification, and monitoring of suspicious transactions.

Thus, a crypto platform operator must be not merely technologically prepared but also a structured, legally and financially responsible entity.

Importance of Technical Infrastructure and Internal Processes

A key element of HTP compliance is the technical and organizational infrastructure. The platform should provide:

• secure storage and accounting of clients’ tokens and cryptocurrencies;
• system stability and fault tolerance;
• transparent audit of operations and regulatory oversight capability;
• integration with internal risk management procedures.

In addition to technology, the HTP assesses internal processes, including transaction documentation, access control, error correction procedures, and response mechanisms to technical failures. Reliable infrastructure and regulated processes are critical factors in registration decisions.

Increased Focus on Risk Management and Transaction Control

Crypto platform operators’ activities inherently involve heightened risks related to asset security and obligation compliance. Therefore, the HTP pays special attention to:

• mechanisms for detecting and preventing fraudulent activities;
• transaction monitoring procedures for suspicious transactions;
• reserving funds to cover potential losses;
• reporting and transparency in interaction with clients and the regulator.

Assessment of these aspects enables the HTP to ensure that the applicant can provide secure, sustainable, and legally compliant crypto platform operations. Only upon meeting all these conditions may a company expect a positive decision on HTP residency.

Requirements for Cryptocurrency Exchange Operators

Cryptocurrency exchange operators constitute a separate category of HTP applicants, characterized by direct conversion of digital assets and funds between market participants. Unlike crypto platform operators, which can provide infrastructure or organize token trading, exchange services act as intermediaries that facilitate asset conversion and transfer between users.

This activity implies increased responsibility for the accuracy of transactions, the security of customer assets and compliance with financial legislation, which leads to a tightening of requirements for cryptocurrency exchange operators.

Why Requirements Are Stricter

The stricter requirements are explained by the high level of regulatory, financial, and reputational risks inherent in exchange activities, including:

• direct access to user funds requiring enhanced protection and transparency;
• potential involvement in money laundering or abusive token schemes;
• ability to exert operational influence on the digital asset market;
• need to comply with international AML/KYC standards even within the HTP framework.

Due to these factors, the HTP imposes additional requirements on exchange operators’ organizational structure, internal procedures, and technical solutions that do not apply to less risky token-related activities.

Assessment of Model Transparency and Operating Mechanisms

When reviewing applications, the HTP pays particular attention to the transparency of the business model and operating mechanisms of the exchange service, including:

• description of asset flows and transaction rules;
• procedures for controlling each transaction and accounting for client funds;
• asset reserving and insurance systems;
• measures to prevent errors, fraud, and unauthorized access;
• internal regulations and reporting documentation for users.

Only with a detailed and transparent exchange model does the HTP consider granting resident status.

Impact of Transaction Nature on Registration Decisions

The nature of transactions directly determines which HTP requirements apply and the level of project scrutiny. For example:

• if exchange operations are limited to internal platform tokens and do not involve third parties, requirements may be less stringent;
• if operations involve external cryptocurrencies and tokens of a wide range of clients, the full set of special requirements applies: risk control, process transparency, compliance, and technical and organizational readiness.

Thus, the greater the impact on users’ property rights and the financial market, the higher the HTP requirements for cryptocurrency exchange operators. Compliance with these criteria is a key factor in obtaining resident status.

Other Token-Based Activities

The HTP also identifies as a separate category token-based activities intersecting with the financial market and bearing features of:

• professional securities activity, where tokens function as investment instruments and their issuance and circulation require compliance with securities market rules;
• exchange activity, where a platform or company organizes token transactions and provides conditions for their purchase and sale;
• investment fund activity, where tokens are used for collective investment or accumulation of funds for specific projects;
• securitization, where tokens represent rights to assets or income streams similar to traditional financial instruments.

These activities go beyond classical IT activities, as they involve third-party property interests, creation of financial obligations, and compliance with investment and exchange regulations.

Creation and Placement of Proprietary Tokens

In addition to the above, a separate category includes projects engaged in the creation and placement of proprietary tokens, even without direct third-party operations. In such cases, HTP evaluates:

• the economic and legal nature of the token;
• its functions within the business model;
• potential risks for users and investors;
• the company’s readiness to ensure transparency and operational control.

Even internal token creation is considered an activity requiring special requirements for business projects, documentation, and organizational structure.

Why Such Projects Require Particularly Thorough Legal Assessment

Projects with tokens of a financial nature require heightened scrutiny by the HTP because errors or inconsistencies in their organization may lead to:

• violation of client and investor rights;
• financial losses and reputational risks;
• non-compliance with securities and investment legislation;
• risks of blending IT and financial regulation.

Therefore, such projects are assessed not only from a technological perspective but also in terms of legal and financial sustainability. The HTP reviews company structure, business processes, risk management, and model transparency.

Boundary Between IT Activity and the Financial Market

The HTP’s main task in assessing such projects is to determine where IT activity ends and the financial market begins.

• IT activity: creation of platforms, infrastructure, software solutions, and support of token functionality as digital instruments within a company.
• Financial market: token issuance, investment attraction, transaction organization, and management of third-party assets.

If a project affects clients’ property interests or performs financial instrument functions, the HTP treats it as financially oriented activity and applies additional legal, organizational, and management requirements.

Thus, correct project qualification, transparent economic model description, and compliance with legal norms are key conditions for successfully obtaining HTP resident status for applicants working with financially-based tokens.

Conclusion

Registration as a resident of the High-Tech Park for specific categories of applicants is a process requiring careful approach, thorough preparation, and understanding of regulatory specifics. Companies working with tokens, crypto platforms, exchange services, or other financially-oriented activities face increased HTP requirements regarding business models, organizational structure, internal processes, and documentation.

To successfully complete registration, it is essential not only to correctly describe the technological and economic substance of the project but also to prepare a complete set of documents complying with both general and special Park requirements. Insufficient elaboration of the business project or simplified activity qualification may lead to refusal or the need for substantial document revision.

Our team has experience in auditing company activities and documentation, developing required internal and external documents, and supporting preparation of business projects and other materials for organizations subject to special requirements. We help optimize processes, minimize risks, and ensure compliance with all HTP criteria, significantly increasing the chances of successfully obtaining resident status.

How to contact us 

For more information or to request a consultation on registration as a resident of the HTP in Belarus, do not hesitate to contact us. We are here to help and support you.

Phone and email communication options are available for your convenience:

• +375293664477 (WhatsApp/Telegram/Viber);
• info@spex.by.