Estonia vs South Korea
Crypto regulation comparison
Estonia
South Korea
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).
South Korea is one of the world's largest crypto markets. The Virtual Asset Users Protection Act (VAUPA), effective July 2024, provides comprehensive investor protection including requirements for exchanges to hold user assets in cold storage and carry insurance. All VASPs must register with FIU and comply with strict AML rules under the Specific Financial Information Act. A 20% crypto gains tax (above KRW 2.5 million exemption, raised from the original 250K KRW threshold) has been deferred multiple times and is now scheduled for January 2027.
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
- Virtual Asset Users Protection Act (VAUPA) effective July 2024 — major investor protection law
- VASPs must register with FIU and partner with real-name verified bank accounts
- 20% national tax (22% effective incl. 2% local income surtax) above KRW 2.5M annual exemption (deferred to January 2027)
- Exchanges must hold 80%+ of user assets in cold wallets and carry insurance/reserves
- Only won-denominated trading pairs allowed on major exchanges (Upbit, Bithumb, Coinone, Korbit)
