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United Kingdom vs Malta

Crypto regulation comparison

← Back to map | United Kingdom | Malta
United Kingdom

United Kingdom

Malta

Malta

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').

Malta positioned itself as the 'Blockchain Island' with the 2018 Virtual Financial Assets (VFA) Act, one of the world's first comprehensive crypto regulatory frameworks. The MFSA licenses VFA service providers and oversees ICOs. Long-term crypto holdings are generally not subject to capital gains tax for individuals, while trading profits may be taxed as income.

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 18-24%
Tax Rate 0-35%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Regulator MFSA (Malta Financial Services Authority)
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
Stablecoin Rules Regulated under MFSA VFA framework and EU MiCA
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
  • Virtual Financial Assets Act (2018) provides a comprehensive licensing framework
  • MFSA licenses VFA exchanges, brokers, custodians, and portfolio managers
  • Long-term crypto holdings generally not subject to capital gains tax for individuals
  • Day trading profits may be taxed as business income at progressive rates up to 35%
  • Transitioning to EU MiCA framework from December 2024
Sources
Sources