Estonia vs Kyrgyzstan
Crypto regulation comparison
Estonia
Kyrgyzstan
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).
Kyrgyzstan adopted the Law on Virtual Assets in 2022 requiring licensing for exchanges, mining, and VASPs. Over 120 licensed VASPs operate. Crypto turnover exceeded traditional securities market in 2024.
Tax Type
Capital gains
Tax Type
Income
Tax Rate
20-22%
Tax Rate
10%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator
State Financial Supervision Authority
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
Regulated under Virtual Assets Law
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
- Law on Virtual Assets adopted in 2022 with licensing framework
- Over 120 licensed VASPs active by late 2024
- Three license types: trading operator, currency exchanger, mining operator
- Crypto sector contributed 800M KGS in taxes in 2024
- Virtual assets not recognized as legal tender but circulate under special regime