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Canada vs United Kingdom

Crypto regulation comparison

← Back to map | Canada | United Kingdom
Canada

Canada

United Kingdom

United Kingdom

Legal
Legal

Canada has a well-developed regulatory framework for cryptocurrency. Crypto trading platforms must register with provincial securities regulators through the CSA, and all crypto businesses must register as money services businesses (MSBs) with FINTRAC. Canada approved spot Bitcoin ETFs in 2021, ahead of most other countries.

The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 0-26.76%
Tax Rate 18-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator CSA, FINTRAC, OSC, AMF
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Stablecoin Rules CSA guidance requires stablecoins to maintain adequate reserves; value-referenced crypto assets regulated
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
Key Points
  • Crypto trading platforms must register with CSA provincial regulators
  • All crypto dealers must register as MSBs with FINTRAC for AML/KYC compliance
  • 50% of capital gains are taxable; business income from crypto is fully taxable
  • Canada approved spot Bitcoin and Ether ETFs in 2021, the first major country to do so
  • CSA issued Staff Notice 21-327 on obligations for crypto trading platforms
Key Points
  • FCA AML registration required for all crypto firms operating in the UK
  • Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
  • Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
  • Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
  • HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)
Sources
Sources