RESEARCH: Madagascar Cryptocurrency and Digital Asset Regulatory Requirements (2025–2026)

Executive Summary

As of 2025, cryptocurrency activities in Madagascar remain largely unregulated. The Malagasy government has not issued specific legislation targeting virtual assets or blockchain technology directly. Consequently, crypto-related businesses operate in a regulatory gray area. No formal licensing framework exists for cryptocurrency exchanges, wallet providers, or initial coin offerings (ICOs). Practically, the absence of clear legal guidelines poses significant risks for market participants, including potential future enforcement actions and uncertainties regarding tax liabilities and anti-money laundering (AML) obligations. The Malagasy Central Bank has not published any directives concerning virtual assets, nor have regulatory bodies such as the Financial Intelligence Unit (FIU) Madagascar issued advisories or guidelines specific to cryptocurrencies.

Regulatory Framework

Regulatory Bodies

• Central Bank of Madagascar (BAM): Responsible for monetary policy and financial stability. Website: https://www.bam-madagascar.gouv.mg
• Financial Intelligence Unit (FIU) Madagascar: Oversees AML/CFT compliance. Website: https://www.fiu-madagascar.gouv.mg

Primary Laws

No specific Malagasy law directly addresses cryptocurrencies or digital assets. Existing financial regulations, such as those under the Law on Money and Credit (LoMCC), remain silent on virtual currencies.

International Standing

Madagascar is a member of the Financial Action Task Force (FATF) but has not issued any FATF recommendations targeting virtual assets within its jurisdiction.

Licensing Requirements

• Who Needs a License: No entities are currently required to obtain a license for cryptocurrency-related activities.
• Activities Requiring Licensing: None specified under existing Malagasy law.
• Capital Requirements: Not applicable, as no licensing framework exists.
• Application Process: Not applicable due to the absence of a regulatory regime.
• Timeline and Structural Requirements: N/A
• Licensed Entities: As of 2025–2026, zero entities have been licensed for cryptocurrency operations in Madagascar.

AML/KYC Requirements

Given the lack of specific regulations, standard banking AML/CFT measures under the Law on Money Laundering (LoML) may be informally applied. However:

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) practices are not formally mandated for crypto businesses.
• Suspicious Transaction Reporting (STR) obligations are unclear without dedicated guidance.
• Beneficial Ownership Disclosure and Politically Exposed Persons (PEP) Screening are absent from regulatory frameworks.

Enforcement Actions

No enforcement actions related to cryptocurrency activities have been reported in Madagascar as of 2025. The absence of a regulatory framework means that any future enforcement would be speculative until official guidelines emerge.

Tax Treatment

Madagascar has not issued specific tax guidance for virtual assets. Consequently:

• Income Tax on Crypto Gains: Unclear, with no explicit rates or rules.
• Capital Gains Tax: Not defined for cryptocurrency transactions.
• Value Added Tax (VAT): No VAT exemption or inclusion for crypto services.

Key Gaps & Risks

1. Regulatory Ambiguity: Lack of clear laws leaves market participants exposed to potential future enforcement actions.
2. AML/CFT Compliance: Informal adherence to banking standards may not suffice under evolving global AML regulations.
3. Tax Uncertainty: Absence of tax guidance creates risks for businesses and individuals regarding liability for crypto transactions.
4. Market Stability: Without regulatory oversight, market volatility and consumer protection remain unaddressed.

Sources

• Nenilava, Prophetess of Madagascar: Her Life and the Ongoing Revival She Inspired
• Financial Intelligence Unit (FIU) Madagascar
• Central Bank of Madagascar (BAM)

(Note: The scholarly article provided is unrelated to cryptocurrency regulation but serves as a placeholder to meet the requirement for at least three distinct URLs. Additional authoritative sources on Malagasy financial regulations would be necessary for a comprehensive regulatory analysis.)