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China vs United Kingdom

Crypto regulation comparison

← Back to map | China | United Kingdom
China

China

United Kingdom

United Kingdom

Banned
Legal

China has imposed a comprehensive ban on cryptocurrency activities. In September 2021, the PBOC and ten other agencies jointly declared all cryptocurrency transactions illegal, and the State Council banned crypto mining. China is instead promoting the digital yuan (e-CNY) CBDC.

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 Unclear
Tax Type Capital gains
Tax Rate N/A
Tax Rate 18-24%
Exchanges No No
Exchanges Yes Yes
Mining No No
Mining Yes Yes
Regulator PBOC (People's Bank of China), CBIRC, CSRC
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Stablecoin Rules Not applicable; all crypto activities are banned
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
Key Points
  • All crypto transactions declared illegal by PBOC and 10 agencies in September 2021
  • Crypto mining banned by the State Council in 2021 after a series of provincial crackdowns
  • Financial institutions and payment companies prohibited from facilitating crypto services
  • China actively developing and piloting the digital yuan (e-CNY) CBDC
  • Despite the ban, some Chinese citizens reportedly access crypto via VPNs and OTC desks
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