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Estonia vs Ukraine

Crypto regulation comparison

Estonia

Estonia

Ukraine

Ukraine

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).

Ukraine passed the 'On Virtual Assets' law in 2022, establishing a legal framework for crypto. The NSSMC is designated as the primary regulator for virtual assets. Crypto gained significance during the Russia-Ukraine war, with Ukraine receiving over $100 million in crypto donations. Tax rules specify 18% income tax plus 1.5% military levy on crypto gains. Full implementation of the regulatory framework has been delayed due to the ongoing conflict.

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 20-22%
Tax Rate 18% + 1.5% military levy
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator Finantsinspektsioon (EFSA), Rahapesu Andmebüroo (FIU)
Regulator NSSMC (National Securities and Stock Market Commission), NBU
Stablecoin Rules Regulated under EU MiCA framework
Stablecoin Rules Under development in virtual assets legislation
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 Assets law passed in 2022, establishing legal status for crypto
  • NSSMC designated as primary regulator for virtual assets; NBU handles stablecoins
  • 18% personal income tax + 1.5% military levy on crypto gains (19.5% total)
  • Over $100M in crypto donations received during Russia-Ukraine war
  • Full regulatory implementation delayed due to ongoing conflict