When we published our Virtual Assets Regulation Across Africa guide, the continent’s regulatory landscape was still taking shape. Many jurisdictions had begun considering how to regulate crypto assets. However, legislative frameworks remained fragmented and, in some cases, uncertain.
Since then, several jurisdictions have made meaningful progress. Some have refined existing regulatory frameworks, while others have introduced entirely new regimes specifically designed for virtual assets. Three recent developments illustrate how the landscape is evolving: South Africa’s changing approach to exchange control, Rwanda’s introduction of a comprehensive virtual asset framework and Zimbabwe’s emergence as one of the continent’s most comprehensive digital asset regulatory jurisdictions.
Although the three jurisdictions have adopted different regulatory models, they reflect a broader trend across Africa. The conversation has shifted from whether crypto assets should be regulated to how they should be regulated. The challenge is to balance innovation, market integrity and financial stability.
South Africa’s evolving regulatory framework
South Africa has been at the forefront of crypto asset regulation on the continent. Crypto assets already qualify as financial products for regulatory purposes. However, uncertainty remains about how the country should treat crypto assets under its exchange control framework.
That uncertainty has become more pronounced following two recent High Court decisions. The courts reached different conclusions on whether crypto assets fall within the existing Exchange Control Regulations.
In Standard Bank vs South African Reserve Bank (SARB) (May 2025), the court found that cryptocurrencies are neither “currency” nor “capital” as contemplated in the regulations. The court adopted a strict interpretation of the legislative wording.
A year later, in Mangundhla vs South African Reserve Bank (June 2026), the court reached the opposite conclusion. It held that Bitcoin could constitute both capital and a form of money. This interpretation considered Bitcoin’s economic function as a store of value and medium of exchange.
These contrasting judgments highlight the challenges of applying decades-old exchange control legislation to rapidly evolving digital assets. They also create practical uncertainty for businesses involved in cross-border crypto transactions. Similar facts could produce different legal outcomes, depending on the interpretation adopted.
SARB has responded by proposing draft Capital Flow Management Regulations. These regulations would expressly include crypto assets within the definition of “capital”. If adopted, they would provide greater legal certainty by bringing crypto assets squarely within South Africa’s exchange control framework.
In August 2026, the SARB published the draft Crypto Assets Manual for Cross-Border Activities. Businesses must read this manual alongside the Capital Flow Management Regulations. It provides practical guidance on implementing the draft regulations. In particular, it explains the application and adjudication process for conducting the business of an Authorised Crypto Asset Service Provider (CASP).
The manual also outlines the permissions and conditions applicable to cross-border crypto asset transactions. Furthermore, it details related administrative responsibilities and reporting requirements to the SARB.
The practical implications could be significant. Cross-border crypto transactions may become subject to exchange control approval requirements or authorised dealer processes. Meanwhile, regulatory enforcement would benefit from a clearer statutory basis.
Based on the published draft documents, the SARB considers crypto asset transactions to become cross-border when parties transfer assets between a domestic Authorised CASP and an offshore CASP. The same applies when a domestic Authorised CASP transfers assets to a non-custodial wallet. These transactions result in cross-border inflows or outflows that the parties must report to the SARB.
This trigger point has important implications. If the SARB publishes the regulations in their current form, only individuals will be allowed to externalise crypto assets through Authorised CASPs. They must use either their single discretionary allowance or foreign capital allowance.
Taken together, these developments suggest that South Africa is moving towards a more integrated regulatory framework. The Financial Sector Conduct Authority will increasingly regulate crypto assets as financial products. However, the assets will also carry exchange control implications when businesses or individuals use them to transfer value across borders.
Rwanda adopts a purpose-built virtual asset regime
While South Africa is adapting existing legislation to accommodate crypto assets, Rwanda has chosen a different path. It has introduced legislation specifically designed to regulate the sector.
Law No. 023/2026 establishes a comprehensive licensing and supervisory framework for virtual asset service providers. Rather than relying on existing financial legislation, the law creates a dedicated regime. It governs how virtual asset businesses may operate within Rwanda. Importantly, the legislation does not recognise crypto assets as legal tender. Instead, it permits their use within a regulated ecosystem. Service providers must obtain licences and comply with ongoing supervision.
The institutional design is equally deliberate. The Capital Market Authority holds primary responsibility for regulating virtual asset service providers. Meanwhile, the National Bank of Rwanda retains oversight of payment systems and monetary stability. The Financial Intelligence Centre oversees compliance with anti-money laundering and counter-terrorism financing requirements.
This allocation of responsibilities reflects Rwanda’s policy choice. The country regulates crypto assets primarily as investment and capital market instruments rather than payment mechanisms.
The legislation covers a broad range of virtual asset activities. These include exchanges, custody services, trading platforms, transfer services, token issuance and investment management.
At the same time, the law excludes fully decentralised systems where no identifiable operator can comply with regulatory obligations. This approach allows regulators to focus on entities they can realistically supervise.
The framework also incorporates safeguards to manage systemic risk. Crypto assets cannot serve as a means of payment unless regulators specifically authorise their use. Furthermore, certain higher-risk activities face restrictions. These include crypto mixers, ATMs and mining infrastructure.
Perhaps most notably, Rwanda’s framework looks beyond today’s market. It expressly addresses tokenisation, virtual asset offerings and the issuance of stablecoins, subject to regulatory approval.
Through these provisions, Rwanda signals an ambition to do more than regulate existing market activity. It also seeks to create an environment capable of supporting future digital financial products.
These developments position Rwanda as one of the continent’s more comprehensive and forward-looking virtual asset jurisdictions. They also contribute to the broader evolution of crypto regulation in Africa.
Zimbabwe builds a comprehensive digital asset ecosystem
While South Africa is refining existing legislation and Rwanda has adopted a dedicated virtual asset law, Zimbabwe has pursued a broader regulatory strategy. It has introduced a coordinated framework that regulates the full digital asset lifecycle. This includes issuance, trading, custody, tokenisation and capital markets participation.
Between 2025 and 2026, Zimbabwe enacted a series of legislative and regulatory reforms. These changes formally brought virtual assets, Virtual Asset Service Providers (VASPs), tokenised securities and blockchain-based financial infrastructure within its legal framework.
The reforms rest on three interconnected pillars: anti-money laundering regulation, securities and capital markets regulation, and the specialised framework of the Victoria Falls International Financial Services Centre (VFIFSC).
The Finance Act, 2025 introduced statutory recognition of virtual assets and VASPs. Consequently, activities such as virtual asset exchanges, custodial services, token issuances and virtual asset transfers moved from a largely uncertain regulatory position into the mainstream financial services framework.
Virtual asset businesses must now register with the Financial Intelligence Unit. They must also comply with ongoing anti-money laundering and counter-terrorist financing obligations.
The regulatory framework expanded further through the Money Laundering and Proceeds of Crime (Virtual Asset Service Providers Registration) Regulations, 2026. These regulations introduced detailed requirements relating to governance, customer due diligence, cybersecurity measures, Travel Rule compliance and regulatory supervision.
Significantly, the framework may also extend to certain decentralised finance (DeFi) arrangements. This applies where operators exercise sufficient control over the relevant platform or protocol.
Zimbabwe has also integrated digital assets into its securities regulatory framework. Virtual token exchanges, token offerings and other token-related activities may require licensing under the Securities and Exchange Act. This creates a dual-regulatory model that combines financial crime oversight with securities regulation.
Perhaps the most distinctive aspect of Zimbabwe’s approach is the role of the Victoria Falls International Financial Services Centre.
Within the VFIFSC, legislation expressly recognises digital asset trading facilities, digital asset custody services, cryptocurrencies, stablecoins, utility tokens and security tokens. The framework also provides legal recognition for smart contracts and distributed ledger technology.
Furthermore, it introduces dedicated rules for tokenised securities, digital asset funds and digital asset investment markets.
The Victoria Falls Stock Exchange has gone a step further. It has established a dedicated listing regime for digital asset issuers and tokenised securities. This creates a pathway for blockchain-based financial instruments to access regulated capital markets.
Taken together, these reforms position Zimbabwe among the more sophisticated digital asset jurisdictions on the continent. Rather than regulating crypto assets in isolation, the framework seeks to create an integrated ecosystem. This ecosystem can support innovation, capital formation and digital financial markets within a supervised regulatory environment.
Zimbabwe’s approach also broadens the scope of crypto regulation in Africa. It demonstrates how countries can integrate digital assets into existing financial structures while developing specialised regulatory mechanisms.
Different approaches, shared direction across Africa
Although South Africa, Rwanda and Zimbabwe have adopted different regulatory strategies, all three demonstrate that African regulators are moving towards more mature and structured oversight of digital assets.
South Africa is refining existing financial and exchange control laws to accommodate crypto assets within its broader regulatory framework. Rwanda has introduced a dedicated legislative regime centred on licensing, supervision and market conduct.
Zimbabwe, meanwhile, has taken a broader ecosystem approach. It integrates virtual assets into anti-money laundering regulation, securities regulation, fintech frameworks and capital markets infrastructure.
The policy priorities also differ. South Africa’s recent developments focus on clarifying exchange control treatment. Rwanda’s framework aims to create a regulated market for virtual asset businesses. Zimbabwe’s reforms seek to support digital asset innovation across the full investment and capital markets value chain.
Despite these differences, all three jurisdictions recognise the growing importance of regulatory certainty. Investors, financial institutions and digital asset businesses operating across Africa will increasingly depend on predictable regulatory environments.
Ultimately, these developments demonstrate that crypto regulation in Africa is moving beyond fragmented policy discussions. Countries are increasingly establishing practical frameworks that define market participation, institutional responsibilities and compliance requirements.
Looking ahead
The African crypto asset landscape is entering a new phase. Policymakers are no longer debating whether regulation is necessary. Instead, they are increasingly focused on developing frameworks that provide certainty, support innovation and protect financial systems.
For businesses operating in this space, the quality and practical implementation of regulatory frameworks will become increasingly important. Jurisdictions that offer clear licensing regimes, effective supervision and predictable regulatory outcomes are likely to be better positioned to attract investment and support digital asset market growth.
As more African countries continue developing their own approaches, the focus will shift from the existence of regulation to its effectiveness. Businesses must therefore monitor legislative developments and assess how regulatory changes affect their operations across different jurisdictions.
The jurisdictions that strike the right balance between innovation, market integrity and financial stability are likely to shape the next chapter of Africa’s digital asset ecosystem.
| Lerato Lamola | Partner (South Africa) | Webber Wentzel | mail me | |  |
| Emmanuel Muragijimana | Partner (Rwanda) | K-Solutions & Partners | mail me | |  |
| Tamara Munya Burunga | Associate (Rwanda) | K-Solutions & Partners | mail me | |  |
| Nellie Tiyago | Partner (Zimbabwe) | Scalen & Holderness | mail me | |  |
