Detailed overview
Costa Rica at a glance
Costa Rica has no specific crypto statute or VASP licence — Bill No. 22.837 (passed first debate July 2025) would add SUGEF VASP registration but is unenacted; crypto is not legal tender (BCCR 2018) but not prohibited. Payments and e-money sit with the BCCR and SUGEF under CONASSIF, with banking requiring ~USD 31.91m capital. Gambling is famously light-touch: no specific licence, offshore-targeting operators use a generic municipal "data-processing" permit, hotel casinos sit under the Ministry of Public Security, and the JPS holds the state lottery and sports-betting monopoly.
Crypto regime — no specific law (Bill 22.837 pending):
- No specific crypto statute and no VASP licence; crypto is not legal tender (BCCR clarification 2018) but not prohibited (autonomy-of-will principle; no legal coverage)
- Bill No. 22.837 (Crypto Asset Market Law) — Executive Branch initiative (9 December 2021); first debate approved July 2025; would amend Law No. 7786 (Narcotics/AML/CFT) by adding Article 15 quáter requiring SUGEF VASP registration (a compliance checkpoint, not an operating licence), KYC, source-of-funds, beneficial-ownership, PEP enhanced due diligence and the FATF Travel Rule; reporting to the Tax Administration aligned with the OECD CARF; Bill 23-415 also discussed; unenacted
- Article 166 of the Labor Code (Crypto Wage Law) — allows employers to pay employees in crypto
- SUGEF — AML supervisor; SUGEVAL — securities (security tokens); ICD — AML body; CARF data collection expected from 1 January 2027, first international exchanges 2028
- Bitcoin ETFs entered the Costa Rican banking system in 2025; institutional adoption growing
- Tax: territorial — foreign-source crypto income generally outside scope; corporate income tax up to ~30%
Payments and e-money regime (BCCR + SUGEF; CONASSIF apex):
- CONASSIF — senior steering body of the supervisory system (SUGEF, SUGEVAL, SUPEN, SUGESE); regulations proposed/drafted by SUGEF
- BCCR — monetary policy and the payment system: operates SINPE (Sistema Nacional de Pagos Electrónicos) and the very popular SINPE Móvil instant retail rail (>372 million SINPE Móvil transactions in 2022; trajectory continued)
- SUGEF — supervises financial intermediaries (banks, savings-and-credit co-operatives, non-bank financial companies) and, under Article 15 Bis of Law 7558 (2020 reform), those engaged in financial intermediation or fundraising from the public, even if non-bank; also supervises AML/CFT for a wide range of non-financial activities (payment services, remittance, trust, escrow); admission to SINPE requires prior SUGEF AML registration
- Payment Card System (2023 update) — payment gateways and aggregators must register with the BCCR
- SINPE regulations amended — technical standards for non-supervised SINPE participants determined by the BCCR (not SUGEF); ongoing inter-regulator coordination
- CIF — Centro de Innovación Financiera (April 2022) — non-binding consultation/innovation space (CONASSIF + BCCR + IDB)
- Fintech Framework Bill — introduced 9 July 2024 by congresswoman Monserrat Ruiz Guevara (PLN)
- Usury Law 9859 — caps interest rates for credit operations
- Banking minimum capital: ~USD 31.91 million deposit to start banking operations; ~12-month licensing process (SUGEF review → CONASSIF approval → conditional licence → SUGEF final licence)
- Currency: colón (CRC), BCCR-managed-float
Gambling regime — light-touch host; state monopoly for residents:
- No specific online-gambling licence; Law No. 9050 of 2012 + Decree No. 39231-MSP-MH of 2015 introduced taxation and licensing for casinos and "call-connection"/processing firms; original gambling prohibition under the 1922 Gambling Law remains for local players, with subsequent decrees opening the licensed sector
- Junta de Protección Social (JPS) — state monopoly over lottery and sports betting for Costa Rican residents; private bookmakers (online or retail) cannot serve Costa Rican players
- Hotel-based casinos — licensed by the Ministry of Public Security (entertainment-focused hotels)
- Offshore-targeting online operators — register a Costa Rican company (S.A. or S.R.L.) and obtain a municipal "data-processing" commercial licence from one of the 84 municipalities (cantons); serve only foreign markets (block Costa Rican IPs); comply with general business law and AML/CFT
- ~300+ companies historically based here; no specific national online-gambling regulator; SUGEF-driven AML/CFT tightening
- Currency-permissive — operators may settle in crypto in practice; no Costa Rican income tax on foreign-source gambling income (territorial system)
Last verified: May 2026. Reference rate: USD 1 = CRC 453 (1 CRC ≈ USD 0.00221). The colón is BCCR-managed-float; it strengthened ~11.5% against the USD over the past year.
Costa Rica is a light-touch host jurisdiction: no specific crypto or gambling licences (offshore-targeting online operators use a municipal "data-processing" permit; hotel casinos sit under the Ministry of Public Security; JPS holds the state lottery/sports-betting monopoly), with payments and e-money in a maturing BCCR/SUGEF regime under CONASSIF, and the Bill 22.837 VASP registration regime pending enactment.
Is there a crypto licence in Costa Rica?
Not yet. There is no specific crypto statute or VASP licence. Bill No. 22.837 (first debate July 2025) would add Article 15 quáter to Law No. 7786 requiring SUGEF VASP registration with KYC, Travel Rule and AML/CFT obligations — but is unenacted. Crypto is not legal tender (BCCR 2018) but not prohibited; SUGEF/SUGEVAL/ICD apply under general law.
The legal foundation:
- No specific crypto statute; not legal tender (BCCR 2018 clarification); not prohibited
- Bill No. 22.837 — Executive proposal (9 December 2021); first debate July 2025; would add Article 15 quáter to Law No. 7786 (AML/CFT) — SUGEF VASP registration, KYC, source-of-funds, PEP enhanced due diligence, Travel Rule, reporting to the Tax Administration in line with CARF
- SUGEF — AML supervisor; SUGEVAL — securities (security tokens require authorisation, prospectus, issuer registration); ICD — AML body; CARF data collection from 1 January 2027 (first exchanges 2028)
- Article 166 of the Labor Code — permits crypto wage payments
- Tax: territorial; foreign-source generally outside scope
Structure:
- No licensing fee; corporate setup (S.A./S.R.L.), AML/KYC, beneficial-ownership transparency, compliance officer (in practice market-led ahead of statutory mandate)
- SINPE/banking access requires SUGEF AML registration in practice
- Bitcoin ETFs entered the banking system in 2025; growing institutional integration
Operational reality:
- A flexible, low-friction regime today — but the trajectory is toward formal SUGEF VASP registration once Bill 22.837 is enacted; design for that outcome
- Banks/EMIs expect FATF-aligned AML/KYC, beneficial-ownership disclosure and compliance officers as a banking-access condition
- Independent legal/AML/tax counsel and direct verification with SUGEF/SUGEVAL/BCCR on current status are essential
Payments & E-money (BCCR + SUGEF; CONASSIF apex)
Best for payment, card-scheme, gateway/aggregator, wallet and (qualified) banking operators prepared to license under the BCCR/SUGEF framework with CONASSIF oversight.
What it is: A combination of: BCCR participation rules (SINPE/SINPE Móvil; Payment Card System 2023 registration of gateways and aggregators), SUGEF financial-intermediary licensing/registration (Article 15 Bis of Law 7558; 2020 reform), and CONASSIF-approved banking licensing under Law No. 7558; with the proposed SUGEF "payment receiving entities" regime in consultation.
Who it suits: Banks, non-bank financial intermediaries, payment gateways/aggregators, e-wallet operators, remittance providers, BNPL/credit firms (subject to Usury Law 9859), and fintechs targeting the CR/Central-American market and SINPE rails.
Covers: Banking, payment-card-system participation (gateways, aggregators), SINPE/SINPE Móvil participation, financial-intermediation services, AML/CFT-supervised non-bank activities (payments, remittance, trust, escrow).
Operational requirement: Costa Rican entity; CONASSIF-approved banking licence (SUGEF review; ~USD 31.91m capital deposit; ~12-month process) or relevant SUGEF/BCCR registration; AML/CFT (Law No. 7786), KYC and beneficial-ownership; SINPE technical standards (BCCR-set); Payment Card System registration (BCCR, 2023 update); Usury Law 9859 interest caps; consumer-protection rules; MEIC oversight where applicable.
Headline figures
- Primary instruments: Law No. 7558 (Organic Law of the BCCR; Article 15 Bis 2020 reform); SINPE/Payment Card System rules (BCCR); Law No. 7786 (AML); Law No. 8204 (AML/CFT extension); Usury Law 9859; CONASSIF/SUGEF regulations
- Regulators: BCCR (monetary, payments); SUGEF (intermediaries, AML); SUGEVAL (securities); CONASSIF (apex); MEIC (consumer protection)
- Banking entry: ~USD 31.91m minimum capital deposit; ~12-month process
- Infrastructure: SINPE / SINPE Móvil (>372m transactions in 2022); CIF Financial Innovation Center (April 2022)
- Reform pipeline: SUGEF "payment receiving entities" draft; Fintech Framework Bill (9 July 2024)
- Currency: CRC, BCCR-managed-float; no exchange-control regime
Is there a gambling licence in Costa Rica?
There is no specific gambling licence. Offshore-targeting online operators use a generic municipal "data-processing" commercial licence (one of 84 municipalities) and may serve only foreign markets; hotel-based casinos are licensed by the Ministry of Public Security; lottery and sports betting for Costa Rican residents are an exclusive monopoly of the JPS.
The legal foundation:
- No specific online-gambling statute; Law No. 9050 of 2012 + Decree No. 39231-MSP-MH of 2015 — taxation/licensing of casinos and "call-connection"/processing firms; 1922 Gambling Law residual prohibition
- Junta de Protección Social (JPS) — state monopoly over lottery and sports betting for Costa Rican residents (private bookmakers/online operators cannot serve Costa Rican players)
- Ministry of Public Security — licenses hotel-based casinos (entertainment-focused hotels)
- Municipalities (84 cantons) — issue the generic commercial "data-processing" licence under municipal commercial law
- AML/CFT: Law No. 7786 + ICD oversight; SUGEF for in-scope activities; KYC and beneficial-ownership transparency expected by banks/EMIs
Structure:
- Offshore-targeting online operators: Costa Rican S.A./S.R.L.; municipal "data-processing" licence; physical presence; Spanish-language records and audits; block Costa Rican IPs; no taxation on foreign gambling revenue under territorial principle (subject to municipal/CIT specifics)
- Hotel casinos: Ministry of Public Security authorisation; Law No. 9050 levy on casinos
- State lottery/sports betting: JPS only
- Online (resident-facing): not licensable to private operators
- No bespoke gambling regulator; AML/CFT framework and general commercial law apply
Gambling — Municipal Data-Processing Licence (offshore online) / Ministry of Public Security (hotel casino) / JPS (state monopoly)
Best for offshore-targeting online operators using a Costa Rican company and municipal data-processing licence, and for hotel-based casino operators; not for resident-facing online or private lottery operators.
What it is: A generic municipal commercial licence ("data-processing") used by offshore-targeting online-gambling companies, plus Ministry of Public Security authorisation for hotel-based casinos; lottery/sports betting for residents is a JPS monopoly.
Who it suits: International online-gambling operators using a Costa Rican base to serve foreign markets, hotel/resort casino operators, and (where in scope) suppliers/service providers to the broader sector.
Covers: Offshore-targeting online casino/sportsbook/poker (under data-processing permits); hotel-based casino games (under MoPS licensing); not resident-facing online, not private lottery (JPS monopoly).
Operational requirement: Costa Rican entity with a registered local office and physical presence; municipal data-processing permit; AML/CFT (Law No. 7786) and KYC; IP-blocking of Costa Rican users; bilingual records and Spanish-language audits; for hotel casinos, MoPS authorisation and Law No. 9050 compliance; territorial-tax structuring and beneficial-ownership transparency.
Headline figures
- Primary instruments: Law No. 9050 of 2012; Decree No. 39231-MSP-MH of 2015; municipal commercial-law permits (84 cantons); Law No. 7786 (AML); JPS lottery/sports-betting monopoly
- Costs: no specific gambling-licence fee; data-processing-licence costs reported ~USD 7,000 first year (secondary/not primary-verified); hotel-casino levy per Law No. 9050
- Tax: territorial — no Costa Rican income tax on foreign-source gambling income; CIT ~30% on local-source income
- Restrictions: offshore-targeting only; cannot serve Costa Rican residents; cannot offer JPS-monopoly products to locals
- Reform direction: AML/CFT tightening (SUGEF), but the light-touch licensing posture persists
Costs and timelines at a glance
- Crypto: no specific licence; Bill No. 22.837 (first debate Jul 2025; would add Art. 15 quáter to Law No. 7786 — SUGEF VASP registration, KYC, Travel Rule, CARF-aligned reporting); SUGEF/SUGEVAL/ICD; Article 166 Labor Code (crypto wages); CARF data collection ~1 Jan 2027, first exchanges 2028; Bitcoin ETFs in banking system 2025; territorial tax (CIT ~30%); banks expect FATF-aligned AML/KYC
- Payments primary instruments: Law No. 7558 (Organic Law of the BCCR; Art. 15 Bis 2020 reform); SINPE/Payment Card System rules (BCCR; 2023 PCS update — gateways/aggregators register with BCCR); SUGEF AML registration prerequisite for SINPE admission
- Payments regulators: BCCR (payments); SUGEF (intermediaries/AML); SUGEVAL (securities); CONASSIF (apex)
- Banking entry: ~USD 31.91m capital deposit; ~12-month process
- Reform pipeline: SUGEF "payment receiving entities" draft; Fintech Framework Bill (9 Jul 2024); CIF (Apr 2022)
- Gambling: no specific licence; Law No. 9050/2012 + Decree No. 39231-MSP-MH/2015 (casino + "call-connection"); JPS state lottery/sports-betting monopoly; Ministry of Public Security hotel casinos; municipal "data-processing" licences (84 cantons) for offshore-targeting online; IP-block local users
- Data-processing licence cost (reported): ~USD 7,000 first year — not primary-verified
- Currency: CRC, BCCR-managed-float
- FX: USD 1 = CRC 453 (1 CRC ≈ USD 0.00221)
Who Costa Rica suits and who it does not
Suitable for
- Offshore-targeting online-gambling operators (casino, sportsbook, poker) able to use a Costa Rican company and a municipal data-processing licence to serve foreign markets, with strict IP-blocking of Costa Rican users and FATF-aligned AML/KYC
- Hotel/resort casino operators able to obtain Ministry of Public Security authorisation and comply with Law No. 9050/2012 levies
- Crypto exchanges, brokers, custody and payment-processor operators able to operate under general commercial/AML law today and pivot to SUGEF VASP registration when Bill 22.837 is enacted
- Banks, non-bank financial intermediaries, payment gateways/aggregators and fintechs able to meet BCCR/SUGEF/CONASSIF requirements (incl. ~USD 31.91m capital for banks) and Article 15 Bis (2020 reform); SINPE-integrated FinTechs
- Groups comfortable in a territorial-tax, common-law-influenced civil-law system with strong institutional democracy and OECD membership
Not suitable for
- Operators seeking a clear, bespoke crypto or online-gambling licence — Costa Rica does not issue one; the regime is permit-based via general law and municipal licensing
- Anyone wanting to serve Costa Rican residents with private lottery, sports betting or resident-facing online gambling — JPS holds the state monopoly and private operators cannot serve local players
- Crypto businesses expecting tax holidays beyond the territorial principle, or unable to demonstrate substance and beneficial-ownership transparency
- Banking-only models unable to meet ~USD 31.91m capital deposit or a ~12-month CONASSIF-approval process
- Businesses sensitive to SUGEF-driven AML tightening, CARF (2027/2028) implementation or potential enactment of Bill 22.837 (VASP registration) and the Fintech Framework Bill