France vs Kenya
Crypto regulation comparison
France
Kenya
Legal
No Regulation
France has one of Europe's most developed crypto regulatory frameworks. The PACTE law (2019) established the PSAN (prestataire de services sur actifs numériques) registration regime, now transitioning to MiCA licensing. Crypto gains are subject to the 30% flat tax (prélèvement forfaitaire unique).
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
30%
Tax Rate
1.5-3% (proposed digital asset tax)
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
AMF (Autorité des Marchés Financiers), ACPR
Regulator
CBK (Central Bank of Kenya), CMA (Capital Markets Authority)
Stablecoin Rules
Regulated under MiCA; stablecoin issuers need e-money or credit institution license
Stablecoin Rules
No specific stablecoin regulation
Key Points
- 30% flat tax on crypto capital gains (12.8% income tax + 17.2% social charges) for non-professionals
- PSAN registration required by AMF for all crypto service providers (mandatory since 2023)
- Transitioning from PSAN regime to MiCA licensing framework in 2024-2025
- Professional crypto traders may opt for progressive income tax rates
- France is home to major crypto companies including Ledger and Société Générale's FORGE
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