Crypto Overview in Costa Rica
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Regulatory data is for informational purposes only and may not reflect the most current legal developments. Always consult qualified professionals before making decisions.
Key Takeaways
- Costa Rica has no dedicated cryptocurrency law. Private ownership and use of crypto assets is legal under the general principle that anything not explicitly forbidden is permitted.
- The Banco Central de Costa Rica (BCCR) declared in 2017 that cryptocurrencies are not legal tender, not foreign currency, and carry no state guarantee – but did not ban them.
- Bill 22837 (Expediente 22837), which would have added Article 15 quáter to Ley 7786 and required PSAVs to register with SUGEF, passed first debate in July 2025 but was archived in December 2025 without enactment. Two replacement bills (Exp. 25.340 and 25.362) were introduced in late 2025 and remain in early legislative stages as of mid-2026. No mandatory PSAV registration requirement is currently in force.
- Crypto gains from personal investment are subject to the 15% capital gains tax introduced by Ley 9635 (2019); business-linked crypto income falls under corporate income tax.
Table of Contents
Legal Classification & Regulatory Framework
Cryptocurrency Status
Costa Rica takes a permissive approach to cryptocurrency, operating on the constitutional principle that any activity not explicitly prohibited by law is permitted for private parties. The Banco Central de Costa Rica (BCCR) issued a formal statement in October 2017 clarifying that cryptocurrencies are not recognized as legal tender in the country. Because they are not issued by any central bank, the BCCR also ruled they do not qualify as foreign currency under Costa Rica’s monetary exchange regime. Transactions in cryptocurrency proceed at the user’s own risk, with no government guarantee.
Despite this non-recognition, the BCCR did not prohibit private purchase, sale, or use of crypto assets. Under Costa Rican contract and civil law, private parties may agree to settle obligations in whatever form they choose, which allows crypto to function as a contractual means of payment. The BCCR has described this posture as “vigilant tolerance”: neither endorsing nor banning digital assets.
Crypto assets are generally classified as virtual or intangible property by government bodies. The Ministerio de Hacienda confirmed this classification in private letter ruling MH-DGT-OF-0460-2023 (August 2023), which provides the most current official tax guidance on how digital assets are treated under existing law.
Tax Treatment
Costa Rica applies a territorial tax system, meaning only income generated from Costa Rican sources is subject to domestic taxation. The Ministerio de Hacienda administers tax obligations through the Dirección General de Tributación.
Under ruling MH-DGT-OF-0460-2023, the tax treatment of crypto depends on the nature of the activity:
Business income: Crypto linked to commercial activity – such as exchange services, custody, or mining conducted within Costa Rica – is subject to Corporate Income Tax (Impuesto sobre las Utilidades) as Costa Rican-source income.
Capital gains: Gains from personal crypto holdings sold at a profit are subject to the 15% capital gains tax introduced by Ley 9635 (Ley de Fortalecimiento de las Finanzas Públicas, 2019). This rate applies to capital income from non-business assets.
VAT: Fees charged for crypto services – including exchange, custody, and key management – are subject to the 13% value added tax.
Territorial scope: Crypto income generated entirely outside Costa Rica is generally not subject to local taxation, though businesses should obtain professional guidance on determining the source of income. On November 26, 2024, Costa Rica signed the Multilateral Agreement for automatic exchange of information under the OECD Cryptoasset Reporting Framework (CARF-MCAA), signalling growing engagement with international tax transparency.
Regulatory Oversight
Several bodies have roles in overseeing crypto-related activity, though no single agency holds comprehensive sector-specific authority:
Banco Central de Costa Rica (BCCR): Sets monetary policy and has issued statements on crypto’s legal status. The BCCR also oversees SINPE, Costa Rica’s interbank payment network, which the proposed Cryptoassets Market Law (Expediente 23415) would connect to registered crypto providers.
Superintendencia General de Entidades Financieras (SUGEF): Financial supervisory authority. Under proposed legislation (Expediente 25.340 and 25.362, introduced December 2025), SUGEF would become the designated AML/CFT supervisor for Virtual Asset Service Providers (Proveedores de Servicios de Activos Virtuales, PSAVs). That role is not yet established by law.
Consejo Nacional de Supervisión del Sistema Financiero (CONASSIF): The steering body that coordinates SUGEF, SUGEVAL, and other superintendencies, and issues binding sector-wide regulations.
Superintendencia General de Valores (SUGEVAL): Securities regulator; may assert jurisdiction if a token is classified as a security under existing securities law.
Unidad de Inteligencia Financiera (UIF) del Instituto Costarricense sobre Drogas (ICD): Receives and analyses suspicious transaction reports (Reportes de Operaciones Sospechosas) from obligated subjects, including PSAVs.
On the legislative front, Expediente 22837 – which proposed adding Article 15 quáter to Ley 7786 to register PSAVs with SUGEF for AML/CFT purposes – passed its first debate in July 2025 but was archived by the Asamblea Legislativa in December 2025 after expiring under the four-year constitutional time limit (caducidad cuatrienal). Two successor bills (Expediente 25.340, a parliamentary initiative, and Expediente 25.362, an executive initiative) were introduced in December 2025 and remain in early stages as of mid-2026. The broader Cryptoassets Market Law (Expediente 23415, introduced by Diputada Johana Obando in October 2022) also remains under legislative debate as of mid-2026, without final enactment.
Business Environment
Banking Relationships
Banking access for crypto businesses in Costa Rica presents the same friction found across much of Central America. Opening accounts is legally possible but requires substantial documentation, a clearly defined business model, and robust AML procedures. State banks such as Banco Nacional de Costa Rica and Banco de Costa Rica apply enhanced due diligence to crypto-linked clients without publicly announced blanket bans.
Costa Rica’s removal from the EU’s AML gray list following a 2023 reform on foreign-source passive income has improved its standing for international correspondent banking relationships. When pending PSAV registration legislation (Exp. 25.340 and 25.362) eventually passes, banks will gain clearer legal reference for evaluating crypto business clients, which may reduce friction over time.
Companies seeking accounts should ensure they hold proper legal entity registration in Costa Rica, a documented AML compliance program, and records of beneficial ownership filed with the BCCR’s beneficial ownership registry.
Innovation Support
Costa Rica has no dedicated regulatory sandbox for crypto or blockchain businesses as of mid-2026. The country’s technology sector – anchored by decades of free-trade-zone investment in IT and life sciences – provides skilled workforce and infrastructure, but the government has not launched targeted incentives for digital asset companies.
The fintech sector has grown organically, supported by stable institutions, widespread internet penetration, and a relatively well-educated workforce. Blockchain applications in supply chain, conservation, and public records have attracted project interest, though no formal government programs fund these at scale. Merchant adoption of crypto payments has grown particularly in tourism-facing businesses along the Pacific coast.
Crypto License in Costa Rica
Costa Rica does not have a dedicated crypto licensing regime. There is currently no “crypto license” or “VASP license” required to operate as a digital asset service provider. Proposed legislation (Expediente 25.340 and 25.362, both introduced in December 2025) would introduce a mandatory registration requirement with SUGEF for Proveedores de Servicios de Activos Virtuales (PSAVs) – an AML/CFT compliance mechanism, not an operating authorization. As of mid-2026, neither bill has passed. Until legislation is enacted, crypto businesses may operate as ordinary commercial entities under general commercial law, provided their activities do not cross into regulated financial intermediation or securities issuance.
Proposed Registration Framework
No mandatory PSAV registration requirement exists under current law. The pending bills (Expediente 25.340 and 25.362) would, if enacted, add Article 15 quáter to Ley 7786 requiring any entity providing virtual asset services in Costa Rica to register with SUGEF. The proposed definition of “activo virtual” covers any digital representation of value that can be traded or transferred online, explicitly excluding legal tender.
Under the proposed framework, covered PSAVs would include: exchanges that trade virtual assets for fiat or for other virtual assets; custodians that hold cryptographic keys on behalf of third parties; wallet service providers; and entities that participate in or provide financial services related to token issuance. Peer-to-peer transactions between individuals, and entities that merely accept crypto as payment for goods or services, would generally fall outside the PSAV definition.
As a baseline under current law (regardless of pending legislation), all crypto businesses must incorporate through the Registro Nacional and file beneficial ownership information with the BCCR. Existing AML/CFT obligated subjects (money transmitters, exchange houses, certain financial intermediaries) already operate under Articles 15 and 15 bis of Ley 7786.
Authorized Activities
Exchanges, OTC desks, custodians, and wallet providers may all operate in Costa Rica under general commercial law. No SUGEF registration requirement is currently in force; when the pending bills (Exp. 25.340 and 25.362) are enacted, those meeting the PSAV definition would be required to register with SUGEF and maintain KYC, transaction monitoring, and suspicious activity reporting to the ICD-UIF. Mining is treated as commercial activity subject to standard income tax, with no mining-specific permit required. Individuals may buy, sell, hold, and self-custody crypto assets without restriction; P2P transactions and self-custody would not trigger registration obligations under the proposed framework. Token issuance is permitted under general commercial law, but issuers should obtain a legal opinion on whether a given token qualifies as a security, which would bring SUGEVAL oversight into scope. No dedicated token issuance or ICO framework currently exists in Costa Rica.
Registration Process and Obligations
No PSAV registration process with SUGEF currently exists, as the enabling legislation has not been enacted. Under the proposed framework in Exp. 25.340 and 25.362, the process would require: incorporation of a Costa Rican legal entity (Sociedad Anónima or S.R.L.) through the Registro Nacional; filing of beneficial ownership information with the BCCR; enrollment in the ICD’s UIF Reportes platform for suspicious transaction reporting; and submission of a PSAV registration to SUGEF documenting the services offered, ownership structure, AML/CFT compliance program, and a designated compliance officer.
The proposed sanctions regime would allow SUGEF to supervise PSAVs on a risk-based basis and maintain a public registry of registered providers, with fines ranging from two to one hundred base salaries (salarios base) for non-compliance, and authority to freeze funds linked to suspected illicit activity. Businesses considering a Costa Rican presence should monitor legislative progress on these bills and consult SUGEF for official guidance once any law is enacted.
Market Characteristics
Adoption Patterns
Cryptocurrency adoption in Costa Rica has grown organically, with the most visible concentration in urban San José and in tourist-oriented coastal areas. Bitcoin Jungle, a grassroots Lightning Network project founded in 2021 in the Osa Peninsula region (centered on Dominical, Uvita, and Ojochal), has built one of Central America’s most documented circular Bitcoin economies. The project uses a free Lightning wallet built on open-source Galoy infrastructure, and hundreds of merchants in the region accept Bitcoin through the network. The initiative was co-founded by expatriates Richard Scotford and Lee Salminen.
Real estate transactions using cryptocurrency have become increasingly common, particularly among international buyers, as Costa Rican contract law allows private parties to denominate and settle obligations in agreed-upon assets. Bitcoin ATMs operate in multiple locations across the country.
Industry Focus
Costa Rica’s combination of permissive general law and favorable territorial tax treatment has attracted crypto businesses operating across several sectors. Exchanges, custody providers, and OTC desks serve both resident and international clients under general commercial law, currently without any mandatory SUGEF registration layer (pending enactment of the proposed PSAV framework).
GameFi platforms, decentralized finance projects, and NFT-related operations have also chosen Costa Rica for operational incorporation, benefiting from the absence of sector-specific restrictions. The country’s established online gaming sector provides a degree of familiarity with digital-asset-adjacent business models.
Regulatory Evolution
Costa Rica’s crypto regulatory landscape remains largely governed by general commercial and AML/CFT law, with no dedicated virtual asset legislation enacted as of mid-2026. Expediente 22837 – which would have added Article 15 quáter to Ley 7786 to bring PSAVs under formal SUGEF AML/CFT supervision – passed first debate in the Asamblea Legislativa on July 2, 2025 but was archived in December 2025 after the four-year constitutional window (caducidad cuatrienal) expired. GAFILAT had flagged the absence of a FATF Recommendation 15-compliant VASP framework, and this gap remains open pending the successor bills (Exp. 25.340 and 25.362, both introduced December 2025).
The broader Cryptoassets Market Law (Expediente 23415) – which would define crypto categories, govern SINPE integration, and establish a tax regime specific to crypto – remains pending in the Asamblea Legislativa as of mid-2026. If enacted, it would represent a significant step toward a comprehensive legal framework, though it explicitly preserves the non-legal-tender status of crypto assets and does not propose adoption along the lines of El Salvador’s bitcoin law.
Costa Rica has never been placed on the FATF Grey List (Jurisdictions Under Increased Monitoring). It undergoes regular follow-up through GAFILAT, and a FATF follow-up assessment visit conducted in January 2024 concluded that the country continues to strengthen its AML/CFT measures. Enactment of a PSAV registration law remains the principal outstanding item identified in that assessment cycle.
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Regulatory Overview
Regulatory data is for informational purposes only and may not reflect the most current legal developments. Always consult qualified professionals before making decisions.
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