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Bulgaria vs Kenya

Crypto regulation comparison

Bulgaria

Bulgaria

Kenya

Kenya

Legal
No Regulation

Cryptocurrency is legal in Bulgaria and subject to a flat 10% tax on capital gains, one of the lowest in the EU. Bulgaria adopted the EU's MiCA framework and requires crypto service providers to register. The country has a notable history with crypto due to a large government Bitcoin seizure in 2017.

Kenya has no comprehensive cryptocurrency legislation, though it is one of Africa's leading crypto markets by adoption. The Central Bank has issued warnings but no formal ban. Kenya's 2023 Finance Act introduced a 3% Digital Asset Tax on income from digital asset transfers, signaling growing regulatory attention.

Tax Type Capital gains
Tax Type Varies
Tax Rate 10%
Tax Rate 1.5-3% (proposed digital asset tax)
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator NRA (National Revenue Agency), FSC (Financial Supervision Commission)
Regulator CBK (Central Bank of Kenya), CMA (Capital Markets Authority)
Stablecoin Rules Regulated under EU MiCA framework
Stablecoin Rules No specific stablecoin regulation
Key Points
  • Flat 10% personal income tax rate applies to crypto capital gains
  • VASPs must register with the NRA for AML compliance
  • MiCA framework applicable from December 2024
  • Bulgaria reportedly seized approximately 200,000 BTC in a 2017 crime bust (status debated)
  • No specific crypto legislation beyond EU directives and general tax law
Key Points
  • No specific cryptocurrency legislation, but the 2023 Finance Act introduced a 3% Digital Asset Tax
  • CBK has issued multiple warnings about crypto but has not imposed a ban
  • CMA considering a framework for digital asset regulation
  • Kenya consistently ranks among the top countries globally for crypto adoption (P2P volume)
  • M-Pesa mobile money dominance shapes how Kenyans access crypto via P2P exchanges