United Kingdom vs El Salvador
Crypto regulation comparison
United Kingdom
El Salvador
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').
El Salvador made history in September 2021 by becoming the first country to adopt Bitcoin as legal tender through the Bitcoin Law. However, under a January 2025 IMF agreement (Decreto 199), El Salvador amended the law to make Bitcoin acceptance by businesses voluntary rather than mandatory, and repealed several articles. There is no capital gains tax on Bitcoin. The CNAD regulates digital assets.
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
- First country to adopt Bitcoin as legal tender in September 2021 via the Bitcoin Law
- Government developed the Chivo wallet for citizens, offering $30 USD in BTC incentive
- January 2025 Decreto 199 made merchant Bitcoin acceptance voluntary (IMF condition)
- No capital gains tax on Bitcoin transactions for individuals
- Government has been accumulating Bitcoin reserves and launched Bitcoin-backed bonds
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)