Costa Rica doesn’t have a law that says you can’t use Bitcoin. It also doesn’t have a law that says you can. That’s not a mistake - it’s the whole point. For businesses and individuals operating in cryptocurrency, this ambiguity isn’t a bug; it’s a feature. And in 2026, that gray area is wider than ever.
Bitcoin Isn’t Legal Tender - But You Can Still Use It
The Central Bank of Costa Rica made it clear back in 2017: Bitcoin and other cryptocurrencies are not legal tender. They’re not backed by the government. You can’t pay your taxes with them. Your landlord doesn’t have to accept them. But here’s the twist - nobody’s stopping you from using them anyway.
If you want to buy coffee with Ethereum at a café in San José, you can. If you want to send Solana to a friend in Liberia, you can. If you want to trade NFTs with someone across the border, you can. The law doesn’t say no. And in a country where bureaucracy moves slowly, that’s often enough.
This is what makes Costa Rica different from places like El Salvador, where Bitcoin became legal tender, or Argentina, where strict capital controls push people toward crypto out of necessity. In Costa Rica, crypto isn’t a workaround - it’s an option. And because it’s unregulated, it’s free to grow.
The 2025 Law That Changed Everything (Without Changing Anything)
On July 2, 2025, Costa Rica’s Legislative Assembly took its first step toward regulating crypto. Bill 22.837 was approved in its first debate. It’s not law yet - but it’s close. And it’s the closest thing the country has ever had to a crypto rulebook.
The bill targets Virtual Asset Service Providers (VASPs). That’s a fancy term for exchanges, wallet providers, crypto casinos, and anyone who moves digital assets for others. Under this law, these businesses must register with SUGEF - the country’s financial supervisor. They’ll need to know who their customers are, keep records of every transaction, flag suspicious activity, and update their risk assessments regularly.
Here’s the catch: registration doesn’t mean approval. SUGEF won’t give you a license. They won’t say, “You’re good to go.” They’ll say, “You’re on the list. Now follow the rules.” It’s like getting your name on a waiting list for a permit you’re not sure exists.
That’s the gray area in action. The government isn’t banning crypto. It’s not endorsing it. It’s just watching. And if you’re doing something shady, they’ll notice.
Who’s Operating in the Gray? (And Why)
Costa Rica has become a magnet for crypto startups that want low cost, low hassle, and zero red tape. You won’t find any country in Latin America with fewer barriers to entry.
- No minimum capital requirement to start a crypto business
- No need to hire local directors or keep an office in-country
- No special crypto license needed - just basic company registration
That’s why GameFi platforms, decentralized exchanges, and crypto casinos are setting up shop here. A startup in Ukraine or Nigeria might spend months and tens of thousands of dollars getting licensed in Estonia or Malta. In Costa Rica, they can incorporate a company in three days, open a corporate bank account (if they’re lucky), and start operating before their competitors finish their business plan.
And it’s not just startups. International investors are quietly funneling capital into local crypto ventures, knowing that if regulation tightens later, they’ll have already established a presence. It’s a race against time - and right now, Costa Rica is the finish line.
The Hidden Risks of Operating in the Gray
Just because you can do something doesn’t mean you’re safe.
Imagine you run a crypto exchange in San José. You follow the AML rules. You verify your users. You keep records. But if someone deposits stolen funds, and the U.S. Treasury flags your transaction, you’re not protected. You don’t have a license. You don’t have legal clarity. You’re just a company with a Costa Rican ID and a lot of questions.
There’s no court precedent for crypto disputes here. If a customer claims you stole their tokens, there’s no clear legal path to resolve it. Banks are wary. Some will work with you. Others will close your account the moment they see “crypto” on your business description.
And while the government says it’s not banning crypto, it also hasn’t said it won’t crack down. The 2025 bill is a warning: we’re watching. And if you’re not compliant, you could be caught in the next sweep.
Legal experts warn that businesses operating in this gray zone are one political shift away from disaster. A new president, a new legislature, a new public outcry - and suddenly, the rules change overnight.
How to Stay Out of Trouble (Even in the Gray)
You don’t need a license to operate in Costa Rica - but you do need discipline.
- Register your company with the National Registry. This is non-negotiable. No legal entity = no banking = no business.
- Apply for SUGEF registration under the pending bill. Even if it’s not law yet, filing early shows you’re serious. It’s a shield.
- Implement full KYC/AML - not just for show. Use tools like Chainalysis or Elliptic to screen transactions. Document everything.
- Avoid high-risk jurisdictions. If you’re dealing with users from sanctioned countries, you’re asking for trouble - even if Costa Rica doesn’t care.
- Keep your banking relationship alive. Use a local bank that understands crypto. If they’re nervous, offer to share your compliance policies. Transparency builds trust.
Most importantly: don’t assume you’re invisible. International regulators - especially the U.S. Financial Crimes Enforcement Network (FinCEN) and the FATF - are watching Costa Rica. They know it’s a hotspot. And they’re not going to let it stay that way forever.
Why This Matters for the Rest of Latin America
Costa Rica isn’t just a haven - it’s a test case. Other countries in the region are watching closely. Panama is debating similar rules. Colombia is tightening its grip. Brazil is moving slowly but surely.
Costa Rica’s model - tolerate, monitor, regulate only the worst actors - might become the template. It’s not perfect. But it’s pragmatic. It lets innovation thrive without giving up on financial safety.
If you’re a crypto founder, this is your chance to build something here before the walls close in. If you’re an investor, this is your window to get in early. But if you’re waiting for a green light from the government? You’re already too late.
What Comes Next?
The second debate of Bill 22.837 is expected in late 2026. If it passes, Costa Rica will officially bring VASPs under its AML umbrella. That won’t make crypto legal - but it will make compliance mandatory.
Expect more banks to open doors for compliant businesses. Expect more startups to flock here. And expect the gray area to slowly turn into a yellow zone - caution, not prohibition.
By 2027, Costa Rica may not be the wild west anymore. But it won’t be a fortress either. It’ll be the place where crypto businesses that play by the rules get to stay - and everyone else gets pushed out.
Is it legal to use Bitcoin in Costa Rica?
Yes, it’s legal to use Bitcoin and other cryptocurrencies for private transactions in Costa Rica. The Central Bank confirmed in 2017 that they are not legal tender, but they are not banned either. Individuals and businesses can accept, send, and trade crypto without breaking any laws - as long as they don’t violate anti-money laundering rules.
Do I need a license to run a crypto exchange in Costa Rica?
Not yet - but you must register with SUGEF under the pending 2025 legislation (Bill 22.837). Registration isn’t a license. It’s a compliance requirement. You won’t get official permission to operate, but failing to register could lead to penalties if the law passes. Most serious businesses register now to avoid future disruption.
Can I open a bank account for my crypto business in Costa Rica?
It’s difficult, but possible. Many banks are hesitant due to regulatory uncertainty. Your best chance is to register your company properly, implement strong KYC/AML policies, and work with banks that already serve fintech clients. Some local banks, especially those with international ties, are starting to accept compliant crypto businesses - but expect scrutiny.
What happens if I don’t comply with the new AML rules?
If Bill 22.837 becomes law, non-compliant VASPs could face fines, asset freezes, or criminal charges under Costa Rica’s existing money laundering laws. Even without the law, if you’re involved in suspicious transactions, international authorities like FinCEN may flag your business - leading to blocked payments, frozen accounts, or blacklisting by global payment processors.
Is Costa Rica a good place to start a crypto business in 2026?
Yes - if you’re prepared to operate in uncertainty. It’s the cheapest and fastest jurisdiction in Latin America to set up a crypto business. No capital requirements, no local office rules, low taxes. But you must be disciplined. Build strong compliance systems now. The gray area won’t last forever. The smartest operators are using this window to build, not just to avoid rules.