Crypto Overview in the Comoros

Regulatory data is for informational purposes only and may not reflect the most current legal developments. Always consult qualified professionals before making decisions.

Legal Classification and Regulatory Framework

Cryptocurrency Status

The Union of the Comoros is an archipelago of three autonomous islands in the Indian Ocean: Grande Comore, Anjouan, and Mohéli. The national government has not enacted comprehensive legislation classifying Bitcoin or other cryptocurrencies under domestic law. Crypto assets are neither banned nor granted any formal legal status at the federal level. The Comorian franc (KMF), pegged to the euro at 491.96775 KMF per euro under a longstanding monetary cooperation agreement with France, remains the only recognized legal tender.

The Banque Centrale des Comores (BCC), headquartered in Moroni, oversees the domestic banking system and implements monetary policy. In January 2025, revised BCC statutes were signed, moving governance sessions from Paris to Moroni. Despite these institutional modernization steps, the BCC has not issued guidance on cryptocurrency trading, custody, or payments for residents. Its stated priorities remain payment system modernization, banking inclusion, and monetary stability, not digital asset oversight.

The autonomous island of Anjouan operates a separate offshore financial licensing regime through its Offshore Finance Authority (OFA), established under the Anjouan Offshore Finance Authority Act of 2005. The OFA issues international crypto licenses to foreign-owned companies incorporating in Anjouan for the purpose of operating outside Comoros. These licenses fall outside the BCC’s direct supervisory mandate and are not formally recognized by the Union government. Their international standing is disputed, and they carry significant legal and reputational risk for licensees (see Crypto License section below).

Regulatory Oversight

Financial oversight in Comoros has a dual structure that reflects its federal system. At the national level, the BCC supervises commercial banks and other financial institutions under the Banking Act. It does not currently supervise virtual asset service providers (VASPs) because no national VASP framework has been enacted.

The Service de Renseignement Financier (SRF) is Comoros’ financial intelligence unit. Established by decree in 2003 and reorganized under Decree No. 20-145/PR of 4 December 2020, the SRF investigates suspicious transaction reports (STRs) from banks and other reporting entities and coordinates inter-ministerial AML/CFT policy. Comoros is assessed under GIABA (the Inter-Governmental Action Group Against Money Laundering in West Africa), a FATF-style regional body. GIABA completed its second-cycle mutual evaluation of Comoros in 2024, noting that no VASP-specific risk assessment has been conducted and that non-financial reporting entities have not yet submitted any STRs. Comoros is not currently on the FATF increased-monitoring list.

The SRF’s capacity is constrained by limited budget allocations. COMESA and the European Union provided IT equipment worth approximately 35 million KMF to the SRF as part of the MASE programme, and the World Bank and African Development Bank have funded training and technical assistance. These investments are gradually improving the SRF’s analytical and reporting capabilities.

Crypto License in Comoros

There is no national cryptocurrency licensing framework in Comoros. The BCC has not established a registration or authorization pathway for domestic or foreign virtual asset service providers. Any company wishing to hold a Comorian license for crypto activities must turn to the autonomous island of Anjouan and its Offshore Finance Authority, which operates independently of the national regulator.

Anjouan International Crypto License

The Anjouan OFA issues an international crypto license to companies incorporated as International Business Companies (IBCs) in Anjouan. The license covers cryptocurrency exchange services (fiat-to-crypto and crypto-to-crypto), digital asset custody, token issuance, crypto lending and deposit products, wallet services, and contracts for difference incorporating crypto assets. Applications are processed in two to eight weeks, no in-person visit is required, and the license is renewable annually.

However, the practical value of this license is severely limited by its disputed legal standing. The Union government’s central authorities, including the BCC, do not formally recognize the OFA’s licensing power. Legal analysis published by multiple law firms confirms that Anjouan’s autonomous administration does not hold sufficient authority under Union law to independently license and oversee financial activity. As a result, the Anjouan license provides no recognized authorization in the United States, European Union, or United Kingdom. Regulators in those jurisdictions, including the SEC, ESMA, and FCA, require separate local registration before a company may solicit clients. Businesses relying solely on an Anjouan license to access regulated markets face significant legal exposure.

For companies seeking a cost-effective initial legal base for offshore operations, the Anjouan license remains technically accessible and affordable, with low capital requirements and no mandatory audit of annual accounts for IBCs. However, prospective licensees should conduct thorough due diligence on how banking partners, institutional clients, and counterparties in their target markets will treat an Anjouan-issued authorization. The license does not carry the reputational weight of frameworks in Malta, Singapore, or other established jurisdictions.

Absence of a National Framework

As of the date of this publication, no bill, consultation paper, or formal proposal to establish a national VASP licensing or registration regime has been made public by the Union government or the BCC. The 2024 GIABA mutual evaluation found that Comoros lacks a risk-based approach to virtual assets and has not defined supervisory measures or priority resources for the sector. Any material development toward a national crypto framework would be announced through the BCC’s official communications at banque-comores.km.

Tax Treatment

Comorian tax law, modeled on the French Code Général des Impôts, applies a progressive personal income tax to residents, with rates ranging from zero on lower brackets to approximately 30% at the top. The standard corporate tax rate for resident companies is up to 35%. Reduced rates of 5% to 15% may apply within designated free economic zones in Moroni and Anjouan. A value-added tax applies at a standard rate of around 10% on most goods and services.

No cryptocurrency-specific tax guidance has been issued by the Direction Générale des Impôts or the BCC. Given the absence of a domestic regulatory classification for crypto assets, it is unclear how gains from trading, staking, or other crypto activity would be assessed in practice for domestic residents. The practical enforcement of any crypto tax obligation is further limited by near-zero domestic adoption.

For offshore IBCs incorporated in Anjouan and operating exclusively outside Comoros, income derived from foreign sources is generally exempt from Comorian corporate tax, withholding tax, and dividend tax. Capital gains on crypto trading conducted abroad are typically not taxable under the offshore IBC structure. Companies must pay annual renewal fees to the OFA to maintain their license and operational status.

Market Characteristics

Adoption and Infrastructure

Domestic cryptocurrency adoption in Comoros is minimal. The national banking rate reached 39% in 2024, according to BCC data, leaving the majority of the population outside the formal financial system. Internet penetration and electricity reliability remain development-stage challenges. Everyday transactions rely on cash and mobile money, not digital assets.

The most structurally significant intersection of cryptocurrency with the Comorian economy is in remittances. Diaspora transfers, primarily from the estimated 150,000 to 200,000 Comorians living in France, account for roughly 25% of GDP. Remittances rose by 5.6% in 2025, continuing a multi-year trend. Crypto-based transfer services have the theoretical potential to reduce costs on this corridor, but practical adoption is negligible due to limited awareness, the KMF peg structure, and the absence of regulatory clarity for crypto payment providers.

Islamic finance principles are deeply embedded in Comorian financial culture. The country is predominantly Muslim, and this shapes attitudes toward interest-bearing products and speculative trading, both of which are features of many crypto market structures. Any future domestic adoption strategy would need to address Sharia compliance considerations to gain traction with local institutions and retail users.

Industry Presence

The cryptocurrency industry’s physical presence in Comoros is almost exclusively oriented toward offshore service provision through Anjouan. International exchanges, wallet providers, and trading platforms have obtained Anjouan licenses to establish a formal legal base, even though their client bases are located in other jurisdictions. The country’s economic focus under Plan Comores Emergent 2030 remains on infrastructure, agriculture, tourism, and the 2027 Indian Ocean Island Games, rather than fintech or blockchain innovation.

There are no regulatory sandboxes, government blockchain pilots, or formal innovation programs operating in Comoros. The BCC’s modernization agenda through 2025 covers electronic payment infrastructure and banking system supervision, not crypto-specific initiatives. Monitoring the BCC’s official publications and any announcements from the Union government’s Ministry of Finance is the most reliable way to track regulatory change.

• Banque Centrale des Comores: https://banque-comores.km/
• GIABA Mutual Evaluation Report, Comoros 2024: fatf-gafi.org