Crypto & Digital Assets · Costa Rica
Is crypto legal in Costa Rica? Rules & regulation (2026)
Costa Rica shaded by its crypto & digital assets status
Crypto is developing in Costa Rica, primarily under Law No. 7786 (AML/CFT Act, as proposed to be amended by Bill 22.837 to encompass VASPs under SUGEF); general commercial law; SUGEVAL Securities Market Law for token offerings with securities characteristics; Ministerio de Hacienda private letter ruling on crypto taxation (2023, ongoing applicability).
Cryptocurrency is legal in Costa Rica as a private intangible asset freely exchangeable under general commercial law, but the Central Bank (BCCR) does not recognize it as legal tender. Bill 22.837, passed in its first legislative debate on 2 July 2025, amends the AML Law (No. 7786) to formally define virtual assets and VASPs and to require their registration with SUGEF for AML/CFT compliance, marking the first legally binding framework for the sector. No standalone VASP license or comprehensive crypto market law was yet in force as of early 2026, though a second bill (Proyecto de Ley 23.415, Cryptoassets Market Law) is under separate legislative review.
Key points
Cryptocurrencies may be freely held, exchanged, and transferred under contractual freedom and general commercial law; the BCCR explicitly does not recognize them as legal tender and has published analysis noting their high volatility relative to the colón.
Passed first debate on 2 July 2025, the bill amends Law 7786 to formally define 'virtual asset' and 'VASP', require SUGEF registration, and impose KYC/CDD, Travel Rule, beneficial-ownership transparency, and suspicious-transaction reporting obligations; fines for non-compliance range from two to one hundred base salaries.
Unlike most FATF-aligned jurisdictions, Costa Rica's emerging regime requires SUGEF registration as a compliance checkpoint, not a formal authorization to operate, making it one of the last major jurisdictions without mandatory VASP licensing.
A 2023 private letter ruling confirmed crypto is an intangible asset: business holdings are subject to Corporate Income Tax; personal investment gains are taxed at 15% capital-gains rate; fees for exchange or custody services attract VAT.
Tokens exhibiting securities characteristics (profit expectations, investment-return rights) require prior SUGEVAL authorization and an approved prospectus under the Securities Market Law; utility and payment tokens without such features face no specific securities-law obligation.
Proyecto de Ley 23.415, a broader Cryptoassets Market Law that could introduce tiered licensing for different categories of crypto businesses, was under legislative review in early 2026 but had not been enacted.
Timeline - major decisions & events
In its second and final debate, the Legislative Assembly unanimously approved Expediente 25.340, amending Law 7786 to require all Virtual Asset Service Providers (VASPs) to register with SUGEF and comply with AML/CFT obligations including KYC, beneficial-owner identification, transaction records, PEP controls, and suspicious-activity reporting to the ICD financial intelligence unit. The law enters into force three months after publication in La Gaceta, finally closing the regulatory gap FATF flagged in 2024.
La Nación ↗All 41 legislators present voted to advance Bill 22.837, the Executive's December 2021 bill to add Article 15 quáter to Law 7786 and bring VASPs under SUGEF's risk-based AML supervision; passage was driven in part by an imminent FATF mutual evaluation scheduled for November 2025. The bill was subsequently revised and re-introduced as Expediente 25.340 before final enactment.
The Tico Times ↗Senior BCCR officials publicly confirmed Costa Rica has no plans for a central bank digital currency and will maintain its permissive-but-unguaranteed approach: crypto is legal for private parties under general commercial law, no government-issued license is required to operate a VASP, and users bear all risk without state recourse.
CoinDesk ↗FATF's follow-up review found Costa Rica non-compliant on Recommendation 15, which mandates VASP registration and AML/CFT supervision, directly pressuring the country to legislate before its next full mutual evaluation; all other 36 recommendations were rated Compliant or Largely Compliant.
FATF ↗A legislator filed the most ambitious crypto bill to date, proposing to regulate mining, exchange, custody, and transfers; give public entities the option to accept crypto for taxes; and create a favourable tax regime (zero income-tax, zero VAT on crypto activities) with optional SINPE central-payment-system integration for VASPs, the bill remained pending as of mid-2026.
EY Centro América ↗The Banco Central de Costa Rica released its first formal policy paper on digital currencies and crypto-assets, coining the doctrine of 'tolerancia vigilante': crypto activities are permitted to foster fintech innovation, but crypto is not legal tender, carries no state guarantee, and individuals and businesses act entirely at their own risk, the framework that would govern the country for the following five years.
Banco Central de Costa Rica (BCCR) ↗The Banco Central de Costa Rica issued its inaugural public statement on cryptocurrency, declaring Bitcoin and similar assets are not legal tender under Costa Rican monetary law, lack central-bank or state backing, cannot be classified as foreign exchange under the exchange regime, and that anyone choosing to use them assumes all associated risks, establishing the legal gray zone that would persist for nearly a decade.
Banco Central de Costa Rica (BCCR) ↗FATF published its inaugural Mutual Evaluation Report assessing Costa Rica's AML/CFT regime under Law 7786, finding the country largely compliant overall but noting gaps in supervision and beneficial-ownership transparency; this baseline assessment set the benchmark against which all subsequent crypto-related regulatory obligations, including Recommendation 15, would be measured.
FATF ↗The Legislative Assembly enacted Law 7786 ('Ley sobre Estupefacientes, Sustancias Psicotrópicas, Drogas de Uso No Autorizado, Actividades Conexas, Legitimación de Capitales y Financiamiento al Terrorismo'), creating the AML/CFT compliance and supervisory regime under SUGEF that would, after amendment by Bill 25.340 in 2026, become the direct legal basis for VASP regulation in Costa Rica.
Procuraduría General de la República (PGR) ↗Costa Rica - other topics
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