Uganda

DeFi Intel Research Desk2026-07-14Africa

Crypto regulatory status

Framework: No comprehensive virtual-asset statute. Cryptocurrencies are not legal tender and are barred as a payment instrument: Bank of Uganda (BoU) Circular NPSD 306 (29 April 2022) directs National Payment Systems Act 2020 licensees to desist from facilitating crypto transactions, and the High Court upheld it in Silver Kayondo v Bank of Uganda (24 April 2023). A dedicated VASP regime is in drafting, framed by the Governor's six foundational pillars announced in November 2025.

Uganda has no comprehensive law governing crypto-assets. The Ministry of Finance warned in a 2019 public statement that cryptocurrencies are not legal tender, and on 29 April 2022 the BoU issued Circular NPSD 306 — signed by acting National Payments System director Andrew Kawere — directing every entity licensed under the National Payment Systems Act 2020 to "desist from facilitating crypto-currency transactions," noting that the central bank had "not licensed any institution to sell crypto-currencies or facilitate the trade in cryptocurrencies" and warning it would invoke enforcement powers under Section 13(1)(b) and (f) of the Act. The directive was challenged and upheld: in Silver Kayondo v Bank of Uganda (Miscellaneous Cause No. 109 of 2022), the High Court's Civil Division (Hon. Justice Ssekaana Musa) ruled on 24 April 2023 that the circular was neither illegal nor irrational and that cryptocurrencies "are illegal under the current National Payment System because they are not recognised as legal tender/currency by the BoU," the bank acting within its discretion under Section 4(4) of the Act. Holding or peer-to-peer trading of crypto is not itself criminalised, but converting it through licensed payment rails such as mobile money is barred.

Reform is under way rather than a hard ban. The BoU admitted blockchain and crypto businesses to its regulatory sandbox — a 1 June 2022 letter to the Blockchain Association of Uganda confirmed participation in a controlled setting for live product trials — and the Capital Markets Authority (CMA) operates its own sandbox for tokenising real-world assets. At the Kampala Blockchain Summit on 25 November 2025, BoU Governor Dr Michael Atingi-Ego framed the current stance as a "prudent pause, not prohibition," reiterated that "virtual assets are not legal tender and participation is at one's own risk," and set out six foundational pillars for a future framework: (1) licensing and fit-and-proper standards; (2) client-asset protection; (3) AML/CFT compliance including the FATF Travel Rule; (4) cybersecurity and operational resilience; (5) market integrity and conduct; and (6) transparency and real-time data reporting. He proposed a division of labour — BoU over payments, the CMA over investment-type assets and the Financial Intelligence Authority (FIA) over AML — and observed that 84.5% of Uganda's virtual-asset activity occurs on decentralised platforms.

Tax treatment

Uganda has no separate capital-gains tax and no crypto-specific tax guidance from the Uganda Revenue Authority (URA). Per the URA, "there is no separate capital gains tax legislation in Uganda"; capital gains are instead included in and taxed together with business income under Section 18(1)(a) of the Income Tax Act — at individual rates for business assets, as property income for shares and commercial buildings, and at the standard 30% corporate rate for companies. How these general rules apply to crypto-asset disposals has not been addressed in dedicated URA guidance.

• Capital gains (general): no separate CGT — taxed as business/property income (individuals) or at the 30% corporate rate, under s.18(1)(a) Income Tax Act
• Crypto-specific URA guidance: pending verification — none published

Travel rule applicability

Status: not yet in force. VASPs are required to register with the Financial Intelligence Authority (FIA) and comply with AML/CFT obligations under Uganda's anti-money-laundering law, though the Governor acknowledged industry compliance remains low. The FATF Travel Rule appears as the third of the BoU's six proposed pillars but is not yet a binding transfer-data requirement; specific transfer thresholds are pending verification.

Notable enforcement actions

• 2022. BoU Circular NPSD 306 (29 April 2022) directed all National Payment Systems Act 2020 licensees to stop facilitating crypto transactions, warning of enforcement under s.13(1)(b) and (f) and stating the bank had licensed no institution to trade crypto.
• 2023. In Silver Kayondo v Bank of Uganda (Misc. Cause No. 109 of 2022), the High Court (24 April 2023) upheld the circular and held that crypto is not recognised as legal tender under the National Payment Systems Act.
• 2025. At the Kampala Blockchain Summit (25 November 2025) the BoU Governor set out six pillars for a forthcoming VASP framework, signalling a shift from prohibition toward licensed supervision.

Public licensed CASP list

Uganda maintains no public register of licensed crypto exchanges — the Bank of Uganda has stated it has "not licensed any institution to sell crypto-currencies or facilitate the trade in cryptocurrencies." VASPs are instead expected to register with the Financial Intelligence Authority for AML purposes, and a limited number of firms have engaged the BoU and CMA regulatory sandboxes; no comprehensive licensee list is published. Pending a dedicated VASP law, consult the FIA and the two sandbox operators for current status. Submit known Uganda VASPs to [email protected].

Comparison to neighbours

Compare Uganda crypto regulation with three geographically adjacent jurisdictions:

Doing business in Uganda — practical notes

Serving Uganda residents in 2026 sits in a grey zone. Crypto may lawfully be held and peer-to-peer trading is widespread — much of it off licensed rails — but payment institutions cannot on- or off-ramp crypto to fiat, and no exchange licence currently exists to obtain. AML registration with the FIA applies to VASPs. Firms seeking a regulated foothold currently do so through the BoU or CMA regulatory sandbox; a statutory VASP regime built on the Governor's six pillars is expected but not yet enacted. Verify the current BoU, CMA and FIA positions before structuring any Uganda-facing offering.

Methodology and sources

This profile was researched and updated by DeFi Intel's research desk on 2026-07-14 from the primary and secondary sources listed below. Claims that could not be verified against a source are omitted or marked pending — we do not republish unverified third-party datasets. Submit corrections and primary-source links to [email protected].

Sources

• BIS — Michael Atingi-Ego, "From regulation to growth: Uganda as a regional hub for virtual assets" (Blockchain Summit, 25 Nov 2025)
• Kakuru Advocates — Silver Kayondo v Bank of Uganda (Misc. Cause No. 109 of 2022), High Court ruling of 24 April 2023
• Kenyan Wall Street — Bank of Uganda Circular NPSD 306 to National Payment Systems Act licensees (29 April 2022)
• CIO Africa — Bank of Uganda admits crypto businesses to its regulatory sandbox (letter of 1 June 2022)
• Uganda Revenue Authority — Taxation of capital gains (s.18(1)(a) Income Tax Act)
• Lightspark country brief — Uganda crypto compliance overview (FIA registration; 2019 Ministry of Finance statement)