Is crypto legal in Costa Rica? Rules & regulation (2026)

Legal framework

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)

Status by sub-area

• Stablecoins

  None

  Costa Rica has no dedicated stablecoin framework; stablecoin issuance and use fall under general commercial law. Neither SUGEF, SUGEVAL, nor the BCCR have issued rules on reserve backing, redemption rights, audits, or issuer authorization for stablecoins.

  Still pending: Dedicated stablecoin framework (reserve backing, redemption, audits, issuer authorization) pending

• Exchanges / VASP

  Partial

  Crypto exchanges and VASPs may operate legally without a formal license under general commercial law; current AML obligations under Law 7786 already apply, and Bill 22.837 (first debate July 2025) adds mandatory SUGEF registration with full KYC, Travel Rule, and transaction-monitoring requirements. No capital adequacy, market-integrity, or conduct-of-business rules exist.

  Still pending: Bill 22.837 (SUGEF registration mandate for VASPs) pending from first debate July 2025

• Token Offerings

  Partial

  Token sales are unregulated unless the token carries securities characteristics; if it does, SUGEVAL requires prior authorization and an approved prospectus under the Securities Market Law. Utility or payment tokens offered without profit expectations are not subject to securities regulation, but no specific safe-harbor rules exist.

  Still pending: Safe-harbor rules for utility and payment tokens not yet established

• Custody

  Partial

  Custodial crypto services are permitted under general commercial law; no dedicated custody framework exists (no qualified-custodian rules, mandatory segregation, proof-of-reserves, or insurance requirements). Custodians classified as VASPs will be subject to SUGEF AML registration under Bill 22.837.

  Still pending: Custody framework (qualified-custodian, mandatory segregation, proof-of-reserves, insurance) pending

• DeFi

  None

  No regulatory guidance has been issued on DeFi protocols, DAOs, automated market makers, or liquidity pools. Activities fall under general commercial law. The VASP framework in Bill 22.837 focuses on identifiable centralized service providers and does not address protocol-layer or decentralized activity.

  Still pending: Regulatory guidance for DeFi protocols, DAOs, AMMs, and liquidity pools not yet issued

• Tax

  In force

  The Ministerio de Hacienda clarified crypto tax treatment via a 2023 private letter ruling: crypto used in business is subject to Corporate Income Tax; personal investment gains are taxed at 15% capital-gains rate; fees charged for exchange or custody services attract VAT. No specific guidance on staking rewards, airdrops, or mining income has been published.

Key points: crypto & digital assets in Costa Rica

1. 01Legal 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.

   bccr.fi.cr bccr.fi.cr

2. 02Bill 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.

   ticotimes.net delfino.cr abc.fi.cr

3. 03Registration, 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.

   lexology.com ecija.com

4. 04Tax 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.

   ey.com globaltaxnews.ey.com

5. 05Token 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.

   multilaw.com

6. 06Second 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.

   zigram.tech

Timeline of decisions

1. 27 May 2026Law
   Legislative Assembly Gives Final Approval to VASP/Crypto AML Law (Bill 22.837)

   Costa Rica's Legislative Assembly passed Bill 22.837 in its second debate, amending the anti-money-laundering Law 7786 to formally bring Virtual Asset Service Providers (VASPs) under SUGEF supervision, mandatory KYC, and AML/CFT obligations, the country's first binding crypto-sector law.

   The Tico Times

2. 25 May 2026Law
   Legislative Assembly Unanimously Enacts VASP-AML Reform, Bill 25.340 Amends Law 7786

   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

3. 1 Jul 2025Decision
   Bill 22.837 Clears First Debate Unanimously, VASPs to Fall Under CONASSIF/SUGEF

   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

4. 27 Nov 2024Guidance
   BCCR Reaffirms Hands-Off Stance: No CBDC, No Prohibition, No Dedicated License Required

   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

5. 1 Jan 2024Decision · official
   FATF 2024 Enhanced Follow-Up Report Rates Costa Rica Non-Compliant on Recommendation 15 (Virtual Assets)

   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

6. 1 Oct 2022Decision
   Bill 23.415 (Ley del Mercado de Criptoactivos) Introduced, Comprehensive Crypto Market Framework Proposed

   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

7. 6 Aug 2021Guidance · official
   BCCR Publishes Official 'Watchful Tolerance' Policy Paper (ESPE-01-2021)

   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)

8. 1 Jan 2017Guidance · official
   BCCR Issues First Official Declaration: Cryptocurrency Is Not Legal Tender

   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)

9. 30 Apr 1998Law · official
   Law 7786 Enacted, Costa Rica's Foundational AML/CFT Framework

   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)

Sources

1. 1.bccr.fi.cr/publicaciones/monedas-digitales-criptoactivos-y-fintech
2. 2.bccr.fi.cr/publicaciones/Criptomonedas/ESPE-01-2021-Algunas_consideraciones_en_t
3. 3.ticotimes.net/2025/07/02/costa-rica-moves-forward-with-crypto-regulation-to-combat-
4. 4.delfino.cr/2025/07/diputados-aprueban-en-primer-debate-regulacion-para-proveedor
5. 5.abc.fi.cr/publicaciones/acontecer-legislativo/diputados-presentan-nueva-iniciat
6. 6.lexology.com/library/detail.aspx?g=f97911bc-9b9f-4665-a87b-f07743cf9f51
7. 7.ecija.com/actualidad-insights/costa-rica-proyecto-de-ley-sobre-prevencion-de-la
8. 8.ey.com/en_gl/technical/tax-alerts/costa-rican-tax-authority-issues-a-private
9. 9.globaltaxnews.ey.com/news/2023-1492-costa-rican-tax-authority-issues-a-private-letter-ruli
10. 10.multilaw.com/Multilaw/ZENTSO/BusinessGuides/Presentation/Section_Home.aspx?GuideId
11. 11.zigram.tech/resources/cr-crypto-regulation-july-2025/