Kyrgyzstan vs South Africa
Crypto regulation comparison
Kyrgyzstan
South Africa
Legal
Legal
Kyrgyzstan adopted the Law on Virtual Assets in 2022 requiring licensing for exchanges, mining, and VASPs. Over 120 licensed VASPs operate. Crypto turnover exceeded traditional securities market in 2024.
South Africa has embraced crypto regulation. In 2022, the FSCA declared crypto assets as financial products under the Financial Advisory and Intermediary Services (FAIS) Act, requiring crypto service providers to obtain FSCA licenses. SARS taxes crypto gains under capital gains tax (up to 18% effective rate for individuals) or income tax depending on trading frequency. South Africa is the largest crypto market in Africa.
Tax Type
Income
Tax Type
Capital gains
Tax Rate
10%
Tax Rate
18% (effective max ~18%)
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
No
Regulator
State Financial Supervision Authority
Regulator
FSCA (Financial Sector Conduct Authority), SARB (South African Reserve Bank)
Stablecoin Rules
Regulated under Virtual Assets Law
Stablecoin Rules
Crypto assets declared financial products under FAIS; stablecoins included
Key Points
- Law on Virtual Assets adopted in 2022 with licensing framework
- Over 120 licensed VASPs active by late 2024
- Three license types: trading operator, currency exchanger, mining operator
- Crypto sector contributed 800M KGS in taxes in 2024
- Virtual assets not recognized as legal tender but circulate under special regime
Key Points
- Crypto declared a financial product under FAIS Act (2022); service providers must be FSCA-licensed
- FSCA began licensing crypto asset service providers (CASPs) in 2023
- Capital gains taxed at effective rate up to 18% (45% max marginal rate × 40% inclusion)
- Frequent trading may be classified as income and taxed at marginal rates (up to 45%)
- SARB regulates cross-border crypto transactions under exchange control regulations