Bahrain vs Estonia
Crypto regulation comparison
Bahrain
Estonia
Legal
Legal
Bahrain is one of the most crypto-friendly jurisdictions in the Middle East. The Central Bank of Bahrain introduced a comprehensive crypto-asset regulatory framework in 2019, and there is no personal income or capital gains tax. Several major exchanges including Binance have obtained licenses.
Estonia was an early mover in crypto regulation, offering licenses since 2017. However, a 2022 overhaul significantly tightened requirements, revoking hundreds of licenses and imposing stricter capital and compliance standards. Crypto gains are taxed at 20% (rising to 22% from 2025).
Tax Type
No tax
Tax Type
Capital gains
Tax Rate
0%
Tax Rate
20-22%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
CBB (Central Bank of Bahrain)
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Stablecoin Rules
Regulated under CBB crypto-asset module; stablecoin issuance requires CBB licensing
Stablecoin Rules
Regulated under EU MiCA framework
Key Points
- CBB Crypto-Asset Module provides a full regulatory framework for exchanges, custodians, and brokers
- No personal income tax or capital gains tax in Bahrain
- Licensed exchanges include Binance (CoinMENA), Rain, and others
- VASPs must meet AML/CFT requirements and obtain CBB licensing
- Bahrain positions itself as a regional fintech and crypto hub
Key Points
- Estonia issued crypto licenses since 2017 but drastically tightened rules in 2022
- Hundreds of crypto licenses were revoked in 2020-2022 due to AML concerns
- New requirements include higher share capital (€100,000-€250,000) and local management
- Crypto gains taxed at 20% personal income tax (22% from 2025)
- MiCA framework applicable from December 2024