Armenia vs South Africa
Crypto regulation comparison
Armenia
South Africa
Armenia adopted a comprehensive Law on Crypto Assets in May 2025, effective July 2025, modeled on the EU's MiCA. The Central Bank of Armenia licenses crypto service providers. Non-entrepreneur crypto gains are tax-free (0%); ECOS Free Economic Zone offers incentives for blockchain startups. Licensing enforcement begins January 2026.
South Africa has embraced crypto regulation. In 2022, the FSCA declared crypto assets as financial products under the Financial Advisory and Intermediary Services (FAIS) Act, requiring crypto service providers to obtain FSCA licenses. SARS taxes crypto gains under capital gains tax (up to 18% effective rate for individuals) or income tax depending on trading frequency. South Africa is the largest crypto market in Africa.
Key Points
- Law on Crypto Assets adopted May 2025, effective July 2025
- Central Bank of Armenia licenses all crypto service providers
- 0% capital gains tax for non-entrepreneur crypto transactions
- Framework modeled on EU MiCA regulation
- Licensing enforcement begins January 31, 2026
Key Points
- Crypto declared a financial product under FAIS Act (2022); service providers must be FSCA-licensed
- FSCA began licensing crypto asset service providers (CASPs) in 2023
- Capital gains taxed at effective rate up to 18% (45% max marginal rate × 40% inclusion)
- Frequent trading may be classified as income and taxed at marginal rates (up to 45%)
- SARB regulates cross-border crypto transactions under exchange control regulations