Reviewed: 30 July 2026.
Cashback, reward points and airline miles may look similar but can represent different legal interests. Cash cashback becomes ordinary non-cash money once credited to a bank account. Points and miles are usually conditional units governed by the loyalty programme’s own terms.
Cash, points and miles are not the same
Rubles credited to an account or card. Once credited, they are ordinary non-cash funds.
Conditional units used for a discount or partial payment under bank or merchant rules.
Conditional access to award travel, upgrades or services if programme requirements are met.
A conditional future benefit depending on transaction confirmation and no refund.
When cashback enters the bankruptcy estate
Article 128 of the Russian Civil Code treats non-cash money as property and an object of civil rights. Under Article 213.25 of the Bankruptcy Law, funds in the debtor’s accounts are controlled by the financial manager during asset realisation, subject to statutory and court-approved exclusions.
Rubles already credited as cashback are therefore included in the account balance. Their marketing label and exemption from personal income tax do not create a separate bankruptcy immunity.
Cashback that has not yet been credited
If a transaction occurred but the bank or merchant will calculate the reward later, the programme terms matter. The entitlement may remain conditional until the transaction is confirmed: a refund, cancellation, breach of rules or closure of the product may eliminate it. Once rubles are paid, the financial manager should be informed.
When points and miles may have property value
Rospotrebnadzor describes reward points as conditional accounting units whose accrual, use and expiry are set by the programme operator. A number displayed in an application does not by itself prove the existence of transferable property that can be sold for creditors.
The economic significance increases where the rules permit:
- conversion into rubles or withdrawal to a bank account;
- transfer, pooling or booking a reward for another person;
- payment for a substantial part of goods, travel or accommodation;
- paid reinstatement or extension of expiry;
- inheritance or another form of succession.
If units are strictly personal, non-transferable, non-cashable, revocable and usable only as a future discount, independent sale may be impractical. The conclusion nevertheless requires the actual terms and balance; any dispute is resolved by the financial manager and the bankruptcy court.
| Asset | What to check | Practical approach |
|---|---|---|
| Cashback rubles in an account | Credit date and source | Treat as account funds |
| Pending cashback | Confirmation and cancellation terms | Disclose a material expected receipt |
| Merchant points | Transfer, cash-out and maximum payment share | Assess under the rules and actual utility |
| Airline miles | Third-party awards, transfer, fees and expiry | Disclose a material balance and restrictions |
| Promo code or one-off discount | Personal use and transferability | Usually no independent market value |
Preparing for bankruptcy
Collect account statements and list programmes with material balances.
Save the current rules, expiry date and permitted uses.
Separate credited rubles from conditional units and future rewards.
Give the information to counsel and the manager without passwords or SMS codes.
Statements, screenshots and programme rules are generally sufficient for disclosure. Passwords, card credentials and one-time codes should not be shared. The Bank of Russia specifically warns about fraudsters who offer to exchange cashback for rubles and ask for banking data and SMS codes.
May rewards be spent before filing?
Ordinary use of a small discount for routine consumption is not automatically concealment. Deliberate cash-out, transfer to a relative or purchase of a valuable item with a large balance shortly before filing may, however, raise questions about purpose and the destination of the resulting value.
A safer approach is to record the balance and analyse it with other assets. If the programme permits third-party award travel, mileage transfers or a substantial cash withdrawal, the transaction should be transparent and documented.
What happens during asset realisation?
After bankruptcy is declared, the financial manager controls estate property and account funds. New cash credits, including cashback, appear on the account and are considered with other receipts, subject to applicable exclusions.
Loyalty units may produce a different result: the programme may close with the banking product, units may expire or transfer may be prohibited. The relevant question is whether an enforceable, economically realisable right exists, not simply whether an application displays a balance.
Frequently asked questions
Is cash cashback income for the bankruptcy estate?
Once credited, it is non-cash money in the account. Personal income tax exemption does not automatically exclude it from the bankruptcy estate.
Must 500 merchant points be disclosed?
A small non-transferable balance will often lack independent market value. Material or convertible balances should still be reported with the programme rules.
Can a financial manager sell airline miles?
Only where the rules provide a lawful and economically sensible transfer or use for the estate. Many programmes restrict transfer and impose expiry.
May the debtor conceal a non-bank rewards account?
Potentially valuable rights should not be concealed. Open classification is especially important where the balance is large or can fund purchases for others.
Must the debtor provide the application password?
No. Provide information and evidence, not passwords, card credentials or SMS codes. Agree a safe verification method with the financial manager.
Official sources
- Bankruptcy Law, Article 213.25 — property and accounts
- Civil Code, Article 128 — objects of civil rights
- Supreme Court Plenum Resolution No. 48 — formation of the estate
- Federal Tax Service — cash and bonus cashback
- Rospotrebnadzor — loyalty programmes and consumer rights
- Bank of Russia — cashback exchange fraud
Related guidance
- Personal bankruptcy legal service
- Additional card in bankruptcy: whose money is it?
- Asset realisation in personal bankruptcy
Review digital balances before filing
At a paid initial consultation, we will separate cash, conditional rewards and transferable property rights, then determine what should be disclosed to the financial manager.