Crypto License in Costa Rica

What the market describes as a Costa Rica crypto license is, in practice, the successful completion of three mandatory steps. Each pillar is a legal requirement, not an optional enhancement.

• Pillar 1: Legal Entity Formation. Incorporate an S.A. (Sociedad Anonima) or S.R.L. (Sociedad de Responsabilidad Limitada) with the company’s activity clauses explicitly covering virtual asset services. Generic commercial activity clauses are insufficient for SUGEF enrollment. The legal representative must be able to obtain a Costa Rican Firma Digital (digital signature) for government portal filings. Note: the Firma Digital requires the legal representative to be a Costa Rican national or permanent resident. Foreign founders typically appoint a local representative for this role;
• Pillar 2: SUGEF VASP Enrollment. Register on the SUGEF Article 15 quater (Ley 10961) platform as an AML-supervised entity. This enrollment creates ongoing reporting obligations, including the appointment of an Compliance Officer, the designated individual responsible for all submissions on the SUGEF platform;
• Pillar 3: BCCR RTBF Registry Filing. Complete the annual filing of the Registro de Transparencia y Beneficiarios Finales (RTBF) through the Central Bank’s centraldirecto.fi.cr portal. The RTBF captures beneficial ownership data and is a mandatory annual obligation for all Costa Rican legal entities. The filing deadline is 30 April each year.

Costa Rica imposes no minimum share capital, no mandatory local office, and no residency requirement for shareholders. The compliance requirements that do apply are specific and carry legal consequences if unmet.

Entity Requirements

• S.A. or S.R.L. structure with explicit virtual asset service clauses in the corporate object;
• Registered legal address in Costa Rica (a registered agent address satisfies this requirement);
• At least one legal representative named in the corporate registry.

AML/CFT Program Requirements

• Written AML/CFT policy covering risk assessment, transaction monitoring, and client identification procedures;
• KYC onboarding procedures aligned with FATF Recommendations for the VASP sector;
• Appointment of an Compliance Officer to manage submissions on the SUGEF Article 15 quater platform;
• Risk matrix documenting the company’s exposure to money laundering and terrorist financing risks by product, geography, and client type.

Beneficial Ownership and Transparency

• Beneficial owners holding 25% or more of the company must be disclosed under Law 9449 (AML and Transparency Requirements);
• UBO data must be reported through the BCCR RTBF portal and updated whenever ownership changes.

Digital Signature Requirement

All mandatory filings on the SUGEF and BCCR portals require a Firma Digital issued by a Costa Rican accredited certification authority. The Firma Digital is only available to Costa Rican nationals and permanent residents. Foreign founders and shareholders who do not hold residency must appoint a local legal representative who holds this credential. LegalBison manages this appointment as part of its standard Costa Rica incorporation service.

Costa Rica’s territorial tax principle remains in place: income generated from customers located outside Costa Rica is not subject to local corporate income tax. This remains a genuine commercial advantage for internationally-focused crypto platforms.

However, the characterization of Costa Rica as a “tax-free” jurisdiction for crypto companies requires correction in the context of 2026 obligations. Costa Rica has implemented the OECD Crypto-Asset Reporting Framework (CARF) through Bill 24.811. VASPs are now required to collect and report user transaction data to the Ministerio de Hacienda for exchange with other CARF-participating jurisdictions under international automatic exchange of information agreements.

What this means in practice: a Costa Rican VASP serving users in CARF-participating countries must implement the data collection, record-keeping, and reporting infrastructure CARF requires. Failure to do so creates regulatory exposure both in Costa Rica and in the jurisdictions where reported users are tax residents.

LegalBison advises on CARF compliance architecture as part of its Costa Rica VASP implementation service, including the data fields required, the reporting timeline, and the interface with the Ministerio de Hacienda’s reporting system.

Costa Rica applies a territorial tax system. Revenue earned from clients or counterparties located outside Costa Rica is not subject to local corporate income tax. This applies to exchange fees, custody fees, payment processing margins, and other income streams generated from international operations.

Income from Costa Rican-resident clients is taxable at the standard corporate rate. Most internationally-oriented platforms structure their client base and operations so that the majority of revenue qualifies as foreign-sourced.

The annual corporate tax declaration must be filed regardless of the territorial exemption. Compliance with this obligation is monitored and non-filing creates penalties.

Costa Rica has a rather lenient taxation regime when it comes to crypto companies. However, in order to benefit from the available incentives, a company must conduct its operations strictly outside the country. If that’s the case, the corporate income tax on blockchain activities is 0%.

At the same time, if the activities are conducted within Costa Rica, the corporate income tax will be as high as 30%. The capital gains tax for companies is also at 30%.

If you hold cryptocurrencies as an investment and realise profit from selling them, this gain is generally subject to the capital gains tax.

Operating a company in Costa Rica comes with a host of advantages, making it a top choice for crypto businesses and virtual asset service providers. Costa Rica offers a highly skilled, multilingual workforce and a robust infrastructure, supporting efficient business operations and international expansion. The country’s territorial tax principle ensures that only income generated within Costa Rica is taxed, providing significant tax benefits for companies with global operations.

Costa Rica’s financial system is well-developed, with numerous international banks and financial institutions present, making it easier for crypto companies to access essential banking services. The lack of explicit laws specifically regulating cryptocurrency transactions creates a flexible regulatory framework, allowing businesses to innovate and adapt quickly. Additionally, the Costa Rican government has taken proactive steps to support the crypto sector, introducing initiatives and policies that foster a transparent and predictable business environment.

With its strategic location in Central America, Costa Rica offers seamless access to major markets in both North and South America, further enhancing its appeal for international crypto businesses seeking to scale their operations.