Estonia vs Kazakhstan
Crypto regulation comparison
Estonia
Kazakhstan
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).
Kazakhstan has a dual approach to crypto regulation. The Astana International Financial Centre (AIFC) operates as a regulated sandbox where licensed crypto exchanges can operate under AFSA supervision. Outside the AIFC, crypto regulation is more restrictive. Kazakhstan became a major mining hub after China's ban but has since tightened mining regulations.
Tax Type
Capital gains
Tax Type
Capital gains
Tax Rate
20-22%
Tax Rate
10%
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator
AFSA (Astana Financial Services Authority), NBK (National Bank of Kazakhstan)
Stablecoin Rules
Regulated under EU MiCA framework
Stablecoin Rules
AIFC (Astana International Financial Centre) has its own framework for digital assets including stablecoins
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
- AIFC provides a regulatory sandbox for licensed crypto exchanges and businesses
- Mining is legal and licensed, with a specific tax on electricity consumption for miners
- Kazakhstan became the world's second-largest Bitcoin mining country after China's 2021 ban
- 2022 mining crackdown introduced stricter licensing and energy consumption taxes
- Outside AIFC, domestic crypto payments and exchanges face greater restrictions