Costa Rica Crypto Regulation 2026: Law 10961 VASP — Full Guide

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For years, Costa Rica had no crypto-specific rules: crypto was not banned, there was no crypto license, and companies operated under general corporate, tax and contractual law. That has now changed. Law No. 10961 brings businesses that provide crypto services to third parties under anti-money laundering supervision.

This guide explains, in plain terms, what the law does, who must register with SUGEF, when it takes effect, how it treats specific models such as stablecoins and DeFi, and what foreign investors and crypto companies should review now.

Implementation Timeline

The law follows a clear three-step timeline from publication to enforceability.

What Is Law No. 10961?

Law No. 10961 is the Costa Rican law that regulates Virtual Asset Service Providers by adding Article 15 quater to Law 7786, the country’s core anti-money laundering statute. Its purpose is not to promote speculation or approve every token; it is to bring certain crypto businesses into Costa Rica’s anti-money laundering and counter-terrorist financing system.

The law follows the international direction set by the Financial Action Task Force (FATF/GAFI), especially Recommendation 15 on virtual assets and VASPs. Costa Rica had been under pressure to close this gap as part of its international AML commitments.

When Does the New Crypto Law Take Effect in Costa Rica?

Law No. 10961 takes effect three months after its publication, which places entry into force around September 19, 2026. It was published on June 19, 2026, so it is not enforceable from day one.

During that window, CONASSIF is expected to issue the implementing regulations that define the operational details — including the transaction thresholds that trigger enhanced due diligence, registration mechanics and Travel Rule technical requirements. The three months are a preparation window, not a reason to wait: businesses that may qualify as VASPs should map their model and design AML and KYC programs now.

Is Cryptocurrency Legal in Costa Rica?

Yes, cryptocurrency is legal in Costa Rica and is not prohibited. Individuals and businesses may generally hold, receive, transfer or agree to use crypto assets in private transactions, as long as the underlying activity is lawful.

What changed with Law No. 10961 is the treatment of businesses that provide crypto services to others. If a company exchanges crypto, holds crypto for clients, transfers virtual assets, administers virtual assets or provides services connected to the issuance or sale of virtual assets, it must now review whether it qualifies as a VASP. The starting point is usually choosing the right legal vehicle and understanding how companies in Costa Rica are incorporated and maintained.

Is Bitcoin Legal Tender in Costa Rica?

No, Bitcoin is not legal tender in Costa Rica. The Costa Rican colón remains the official currency, and the Central Bank of Costa Rica does not recognize Bitcoin, stablecoins or other virtual assets as legal tender or foreign currency.

This is a key difference from countries that adopted an aggressive legal-tender model. Costa Rica is not requiring businesses to accept Bitcoin, and the new law does not turn crypto into official money — it focuses on supervising the businesses that provide services involving virtual assets.

Do You Need a Crypto License in Costa Rica? And What Does It Cost?

There is no specific “crypto license” in Costa Rica. What the law requires is that covered VASPs register with SUGEF for AML supervision — and that registration is expressly not an authorization to operate. In other words, you do not apply for a crypto license; you determine whether your activity qualifies as a VASP and, if so, you register and comply.

On cost, the law does not set a fixed registration fee. CONASSIF will define the operational details, and the law allows the supervisor to recover reasonable costs, with obligated subjects contributing to supervision expenses according to their size, number of operations and transaction volume. Beyond any official fee, the real budget for a VASP is the compliance program itself: policies, a compliance officer or differentiated structure, monitoring and analytics tools, recordkeeping systems and legal support. Those costs should be planned before launch, not after.

How Does Costa Rica Define Virtual Assets?

Under Law No. 10961, a virtual asset is a digital representation of value or funds that can be traded or transferred digitally and used for payments or investments. The law adds that this does not make virtual assets legal tender in Costa Rica or foreign currency for the Central Bank.

In practice, the focus is not whether a token is “money” in the traditional sense. The focus is whether it can move value, be exchanged, be transferred, be held for others, or be used in a way that creates financial-crime risk.

What Is a VASP Under Costa Rican Law?

A VASP (Virtual Asset Service Provider) is a person or company that, as a business, performs certain virtual asset activities — for itself or on behalf of a third party. The definition is broad: a company does not need to call itself an exchange to fall within scope. What matters is the activity it actually performs.

How Are Stablecoins, NFTs, DeFi, Mining and P2P Treated?

The law regulates activities, not labels. Whether a stablecoin, NFT, DeFi, mining or P2P project is covered depends on whether someone, as a business, performs a VASP activity such as exchange, transfer, custody or issuance-related services. CONASSIF regulations will refine these edges, but here is the practical reading.

Do VASPs Need to Register With SUGEF?

Yes, covered VASPs must register with SUGEF (Superintendencia General de Entidades Financieras). SUGEF supervises these providers for AML/CFT compliance under a risk-based approach, VASPs must keep their registration updated, and they may be included in a centralized registry.

This must be understood correctly: the law states that registration with SUGEF does not represent an authorization to operate. It is not a banking license, a securities license or a general approval of every product, token or service offered by the company.

AML, KYC, Recordkeeping and Reporting Obligations for VASPs

A VASP needs a real compliance program, not just a corporate structure: documented policies, trained personnel, internal procedures, risk analysis and evidence that the controls actually work. For an exchange, custody provider, wallet operator or fintech, this should be reviewed before launch, not after.

The Travel Rule and Virtual Asset Transfers in Costa Rica

The law requires VASPs to obtain and maintain originator and beneficiary information for virtual asset transfers, consistent with FATF standards — the rule commonly known as the Travel Rule. This is one of the areas with the greatest operational impact.

For exchanges, custodians, wallet infrastructure providers, OTC desks and transfer platforms, this may require changes to onboarding, data architecture, blockchain analytics, transaction monitoring, compliance workflows and user agreements.

Trusts, Fiduciary Structures and Virtual Assets in Costa Rica

When regulated activities involve the administration of trusts that include virtual assets, they fall under the supervision established in Article 15 quater, as developed by CONASSIF. This matters because Costa Rica is often used for escrow, fiduciary and asset-holding structures.

If virtual assets are involved, the analysis must include not only contract law and fiduciary duties, but also AML supervision, beneficial ownership, transaction monitoring, reporting and possible registration issues.

Banking Reality for Crypto Companies in Costa Rica

A VASP framework does not automatically solve the banking challenge for crypto businesses in Costa Rica. Local banks may remain cautious due to risk appetite, correspondent banking concerns and enhanced due diligence requirements.

A serious crypto structure should not be incorporated first and explained to banks later. Banking strategy belongs in the legal design from the start: ownership structure, source of funds, compliance program, client profile, operating jurisdictions and transaction flows all affect whether a bank will work with the company.

Crypto Tax in Costa Rica: Territorial Source and Economic Substance

Costa Rica generally follows a territorial-source tax system, so a company is not taxed merely because it exists in Costa Rica. The analysis depends on where income is generated, where the activity is performed, where value is created, where management decisions are made and whether the income is Costa Rican-source.

This matters for crypto because many businesses operate across borders, with foreign users, offshore infrastructure or management outside the country. Crypto tax planning should therefore be reviewed together with corporate structure, operational substance and compliance obligations.

Penalties for Non-Compliance Under Costa Rica’s New Crypto Regulation

Non-compliance can be expensive. The reform updates the sanction framework under Law 7786 for VASPs and other covered persons who fail to register, identify customers, keep records, report suspicious transactions, provide information to authorities, or who deal with unregistered providers.

• Fines from 5% to 50% of the total transaction amount in certain cases.
• Fines from two to one hundred base salaries for specific compliance failures.
• Late payment surcharge if a fine is not paid within the legal term.
• Publication of final sanctions by supervisory authorities.
• Inspection, information request and enforcement powers by competent authorities.

What Foreign Crypto Companies Should Know About Costa Rica

The new regulation can reach foreign groups, not only local companies serving local clients. A foreign group may need legal review if it uses a Costa Rican company, operates from Costa Rica, has management in Costa Rica, hires local personnel, targets Costa Rican users or administers virtual asset structures through a Costa Rican nexus.

This is especially relevant for exchanges, OTC desks, wallet and custody providers, token issuers, fintech and Web3 startups evaluating Costa Rica. Advice should cover not only incorporation but AML obligations, tax exposure, banking feasibility, beneficial ownership, contracts and operational substance.

• Crypto exchanges evaluating a Costa Rican entity.
• OTC desks serving Latin American clients.
• Wallet and custody providers.
• Token issuers using Costa Rican corporate vehicles.
• Web3 and blockchain startups with founders or management in Costa Rica.
• Fintech companies integrating crypto payments or settlement rails.
• Trust, escrow or fiduciary structures holding virtual assets.
• International groups seeking tax or operational flexibility.
• Companies in other regulated sectors, including gaming or online betting that may also require a gambling license review.

Does a Costa Rican Company With Fully International Operations Need SUGEF Registration?

Not necessarily — the law regulates activities, not corporate nationality. If a Costa Rican company is only a passive holding vehicle and does not operate the exchange, provide custody, transfer virtual assets for clients, sign contracts with users, or generate operational income in Costa Rica, it should not need to register with SUGEF as a VASP.

The analysis changes if the Costa Rican company is the entity that actually provides the VASP service — for example, if it signs the client contracts, operates the exchange, controls the platform, receives the fees, provides custody or transfers assets for users. In that case, SUGEF registration may be required even if the clients are abroad.

Official and International Sources to Monitor

Law No. 10961 is published and in the implementation phase. Its final practical effect will depend on the CONASSIF implementing regulations expected within three months of publication.

• Law No. 10961 — official publication (La Gaceta, Alcance No. 78, June 19, 2026)
• Law 7786 — full consolidated text (SCIJ)
• Legislative Assembly of Costa Rica
• SUGEF — General Superintendency of Financial Entities
• CONASSIF — National Council for Financial System Supervision
• ICD — Costa Rican Drug Institute and Financial Intelligence Unit
• FATF — Financial Action Task Force
• GAFILAT — Latin American Financial Action Task Force

Frequently Asked Questions About Crypto Regulation in Costa Rica

What is Law No. 10961 in Costa Rica?

Law No. 10961 is the enacted reform to Law 7786 (processed as legislative file No. 25.340, previously known as Bill No. 25,340). It adds Article 15 quater to regulate Virtual Asset Service Providers for anti-money laundering, counter-terrorist financing and proliferation financing purposes. It was published in La Gaceta on June 19, 2026.

When does Costa Rica’s new crypto law enter into force?

Law No. 10961 was published on June 19, 2026 and takes effect three months after publication, around September 19, 2026. CONASSIF has up to three months to issue the implementing regulations that define thresholds, scope and technical requirements.

Do I need a crypto license in Costa Rica?

There is no specific crypto license in Costa Rica. Covered VASPs must register with SUGEF for AML supervision, and that registration is expressly not an authorization to operate. You do not apply for a crypto license; you determine whether your activity qualifies as a VASP and, if so, register and comply.

How much does it cost to register as a VASP in Costa Rica?

The law does not set a fixed registration fee. CONASSIF will define the details, and the supervisor may recover reasonable costs, with obligated subjects contributing to supervision expenses based on their size and operations. The main real cost is the compliance program itself: policies, a compliance officer or differentiated structure, monitoring tools, recordkeeping and legal support.

Is cryptocurrency legal in Costa Rica?

Yes. Cryptocurrency is not prohibited in Costa Rica. However, businesses that provide crypto-related services may now be subject to VASP registration and AML compliance obligations under Law No. 10961.

Is Bitcoin legal tender in Costa Rica?

No. Bitcoin is not legal tender in Costa Rica. The Costa Rican colón remains the official currency, and virtual assets are not recognized as legal tender or foreign currency by the Central Bank of Costa Rica.

What is Bill No. 25,340 in Costa Rica?

Bill No. 25,340 was the legislative file (expediente) for the crypto reform. It is now enacted as Law No. 10961, which adds Article 15 quater to Law 7786 to regulate Virtual Asset Service Providers.

What is a VASP in Costa Rica?

A VASP is a person or company that, as a business, performs covered virtual asset activities such as crypto-fiat exchange, crypto-to-crypto exchange, virtual asset transfers, custody, administration, control or financial services related to the issuance, commercialization, offer or sale of virtual assets.

Do crypto exchanges need to register with SUGEF in Costa Rica?

Covered crypto exchanges that qualify as VASPs must register with SUGEF for AML supervision. CONASSIF regulations will define important operational details.

Does SUGEF registration authorize a crypto company to operate?

No. SUGEF registration is not an authorization to operate. It is a registration and AML supervision mechanism, not a general license approving every activity, product or token.

Are stablecoins regulated in Costa Rica?

Stablecoins fit the definition of a virtual asset. A business that exchanges, transfers or custodies stablecoins for third parties will likely qualify as a VASP and must comply with AML obligations under Law No. 10961.

Are NFTs regulated in Costa Rica?

It depends on use. A purely unique collectible may sit outside scope, but if an NFT is used to move value, is exchanged, or is offered or sold as a financial product, the provider’s activity can fall within VASP rules. CONASSIF regulations will clarify edge cases.

Is DeFi regulated in Costa Rica?

The law targets providers acting as a business. A genuinely decentralized protocol with no operator is harder to fit, but a front-end, operator or company that controls or profits from the service may be treated as a VASP.

Is crypto mining a VASP activity in Costa Rica?

Mining on your own account is generally not a listed VASP activity. It can change if you also exchange, custody or transfer virtual assets for third parties as a business.

Is peer-to-peer (P2P) crypto trading regulated in Costa Rica?

Occasional private P2P trades are typically not a VASP activity. Running P2P as a business — providing exchange or transfer services to others — can trigger VASP status and SUGEF registration.

Does a Costa Rican company need SUGEF registration if all operations and income are abroad?

Not necessarily. If the Costa Rican company is only a passive holding or corporate vehicle, does not operate the exchange, does not sign contracts with clients, does not provide custody or transfer services, and all operations and income are generated outside Costa Rica, it should not need SUGEF VASP registration.

When would a Costa Rican company with foreign clients need VASP registration?

Registration may be required if the Costa Rican company is the entity that actually provides VASP services, signs client contracts, operates the platform, receives service fees, provides custody, transfers virtual assets or manages the virtual asset business from Costa Rica, even if the clients are located abroad.

Is a passive Costa Rican holding company a VASP?

A passive Costa Rican holding company should not be considered a VASP if it does not perform virtual asset services and only holds shares, investments or corporate ownership interests. The analysis changes if the company performs exchange, custody, transfer, administration or issuance-related services.

Do crypto custodians need to comply with the new law?

Yes, if they qualify as VASPs. The definition includes custody, deposit, administration or control of virtual assets by any means.

Does the new Costa Rica crypto law apply to foreign companies?

It may apply if the foreign company has a Costa Rican nexus, uses a Costa Rican entity, operates from Costa Rica, serves Costa Rican operations or performs covered VASP activities in a way that brings it within the scope of local regulation.

Are crypto gains taxable in Costa Rica?

They may be taxable depending on source, activity and substance. Costa Rica generally follows a territorial-source tax system, so the treatment depends on where the income is generated and where the business activity is performed.

Does Costa Rica follow FATF standards for crypto?

Law No. 10961 was designed to strengthen Costa Rica’s compliance with FATF Recommendation 15 on virtual assets and Virtual Asset Service Providers.

Can a Costa Rican company operate a crypto exchange?

Potentially yes, but the company must be reviewed for VASP registration, AML compliance, tax treatment, banking feasibility, user contracts, beneficial ownership and operational substance.

What should crypto companies do now?

Map the business model, determine whether they qualify as VASPs, prepare AML and KYC policies, review SUGEF registration implications, assess tax exposure and monitor CONASSIF implementing regulations before the law becomes enforceable.

About the author: Gonzalo Gutiérrez Acevedo, Managing Partner & Founder, AG Legal (click to expand)

Gonzalo Gutiérrez has led AG Legal since founding the firm in 2000, with over three decades advising national and international clients on foreign investment, corporate law, tax, trusts, real estate, immigration and litigation in Costa Rica. He is a certified Notary Public, holds Master’s degrees in Tax Law and Business Law (ULACIT), is a Specialist in International Taxation (UCR/CICAP, 2024), and is the Costa Rica country lead for the chapter in International Trust Laws and Analysis (Wolters Kluwer).

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