The Russian E-Money Association in assistance with the Central Bank of Russia prepared a regulatory framework that would legitimize e-wallet inactivity fees on the domestic market, JPMorgan analyst Alexei Gogolev tells investors in a research note. The analyst believes the Central Bank of Russia's blessing is likely to be viewed as positive since the market "feared a complete ban of inactivity fees in Russia." While this is likely to be viewed as positive, certain requirements within the proposed legislation mean that Qiwi may not be able to collect up to 2% of its 2019 revenue in a one-off transition to a new way of inactive e-wallet recognition, says the analyst. He keeps a Neutral rating Qiwi shares and highlights "regulatory uncertainty among key long-term risks for the investment case."