Estonia vs Kenya
Crypto regulation comparison
Estonia
Kenya
Legal
No Regulation
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).
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
20-22%
Tax Rate
1.5-3% (proposed digital asset tax)
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
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
- 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
- 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