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Estonia vs Japan

Crypto regulation comparison

← Back to map | Estonia | Japan
Estonia

Estonia

Japan

Japan

Legal
Legal

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).

Japan is one of the world's most comprehensively regulated crypto markets. The Payment Services Act and Financial Instruments and Exchange Act govern crypto exchanges and tokens. Japan classifies crypto as "crypto-assets" and taxes gains as miscellaneous income at rates up to 55%, though reforms to lower this rate are under active discussion.

Tax Type Capital gains
Tax Type Income
Tax Rate 20-22%
Tax Rate 15-55%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator FSA (Financial Services Agency), JVCEA
Stablecoin Rules Regulated under EU MiCA framework
Stablecoin Rules 2022 stablecoin law requires issuers to be licensed banks, trust companies, or fund transfer agents
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
Key Points
  • Crypto exchanges must register with the FSA under the Payment Services Act
  • Crypto gains taxed as miscellaneous income at up to 55% (national + local tax)
  • Japan's self-regulatory body JVCEA sets industry standards for exchanges
  • 2022 stablecoin legislation (revised Payment Services Act) regulates stablecoin issuance
  • Government considering tax reform to apply a flat 20% separate taxation on crypto gains
Sources
Sources