World Watch/Costa Rica/Crypto & Digital Assets

Crypto & Digital Assets · Costa Rica

Is crypto legal in Costa Rica? Regulation & rules (2026)

DevelopingLaw 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)Country index 66 · B

Costa Rica shaded by its crypto & digital assets status

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

Legal but not legal tender

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.

Bill 22.837 — VASP AML/CFT registration

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.

Registration, not a license

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.

Tax treatment clarified by Ministerio de Hacienda

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.

Token offerings — SUGEVAL securities test

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.

Second bill — Cryptoassets Market Law (PL 23.415)

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.

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