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United Kingdom vs Japan

Crypto regulation comparison

← Back to map | United Kingdom | Japan
United Kingdom

United Kingdom

Japan

Japan

Legal
Legal

The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').

Japan is one of the world's most comprehensively regulated crypto markets. The Payment Services Act and Financial Instruments and Exchange Act govern crypto exchanges and tokens. Japan classifies crypto as "crypto-assets" and taxes gains as miscellaneous income at rates up to 55%, though reforms to lower this rate are under active discussion.

Tax Type Capital gains
Tax Type Income
Tax Rate 18-24%
Tax Rate 15-55%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Regulator FSA (Financial Services Agency), JVCEA
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
Stablecoin Rules 2022 stablecoin law requires issuers to be licensed banks, trust companies, or fund transfer agents
Key Points
  • FCA AML registration required for all crypto firms operating in the UK
  • Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
  • Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
  • Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
  • HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)
Key Points
  • Crypto exchanges must register with the FSA under the Payment Services Act
  • Crypto gains taxed as miscellaneous income at up to 55% (national + local tax)
  • Japan's self-regulatory body JVCEA sets industry standards for exchanges
  • 2022 stablecoin legislation (revised Payment Services Act) regulates stablecoin issuance
  • Government considering tax reform to apply a flat 20% separate taxation on crypto gains
Sources
Sources