United Kingdom vs Romania
Crypto regulation comparison
United Kingdom
Romania
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').
Cryptocurrency is legal in Romania. Crypto gains are taxed at 10% as 'income from other sources' under the fiscal code. VASPs must register with the relevant authorities for AML compliance. Romania has a growing crypto community and is transitioning to the EU MiCA framework.
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 gains taxed at 10% as 'income from other sources' under Article 114 Fiscal Code
- Annual gains up to RON 600 (~EUR 120) exempt from tax per Article 116 Fiscal Code
- VASPs must register for AML/CFT compliance
- ASF oversees financial market conduct; BNR handles monetary policy
- MiCA framework applicable from December 2024
Sources
- HMRC - Cryptoassets Manual
- FCA - Cryptoassets Information
- HMRC - Capital Gains Tax Rates
- HMRC - Cryptoassets Manual: Mining
- FCA - Regulation of Digital Assets Speech
- FCA - Cryptoasset Registration Application
- FCA - Regulating Cryptoasset Activities (DP25/1)
- FCA - Financial Promotion Rules for Cryptoassets (PS23/6)