Regulatory AlertsUganda: crypto & digital assets regulation
Partially regulatedUganda: No specific crypto license; CMA regulates securities aspects under Fit & Proper framework
- Lead regulator
- Capital Markets Authority Uganda (CMA)
- Also involved
- Bank of Uganda (BoU) (payments/banking) · Uganda Communications Commission (UCC) (telecoms)
- Core law
- Capital Markets Act (Cap 286)
- Entry capital
- —
- Approval timeline
- —
- Customer assets
- No specific custodial regime; general fiduciary duties apply
- Data protection
- Data Protection and Privacy Act 2019 · Office of the Data Protection Officer
- Sandbox
- Yes - EASRA regional sandbox framework
Uganda does not have a dedicated licensing regime for crypto assets or virtual asset service providers (VASPs). The Capital Markets Authority (CMA) is the primary regulator for activities that constitute securities or derivatives. The CMA has adopted regional EASRA frameworks for fit-and-proper assessments and regulatory sandboxes. The Bank of Uganda (BoU) maintains a restrictive stance on crypto as legal tender but has not issued a comprehensive ban on all crypto activities, creating a regulatory gap for non-securities crypto services.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Exchange / trading platform | Uncertainverify with regulator Unclear if spot crypto exchanges are classified as securities dealers | — | — | — |
| Custody of client assets | Uncertainverify with regulator No specific custodian license for crypto; general trust law may apply | — | — | — |
| Token issuance / public offering | LicenceSecurities Dealer License[1][2] If tokens are deemed securities, CMA licensing and prospectus approval required | — | — | CMA |
| Broker-dealer / OTC desk | Uncertainverify with regulator OTC desks may fall under securities dealer rules if trading securities | — | — | — |
| Stablecoin issuance | Prohibited BoU prohibits use of crypto as legal tender; stablecoins face high scrutiny | — | — | BoU |
| Crypto payments acceptance | Restricted BoU restricts crypto payments; traditional payment licenses required for fiat | — | — | BoU |
| Mining / staking services | Unregulatedverify with regulator No specific regulation for mining or staking services | — | — | — |
| Advisory / portfolio management | Uncertainverify with regulator Crypto advisory may require CMA license if involving securities advice | — | — | — |
New — what changed recently
- 2025-06-02EASRA Regional Framework Adoption — Uganda's CMA agreed to regional ESG and carbon credit frameworks, signaling alignment with broader East African fintech standards.[1]
- 2018-07-18EASRA Fit & Proper & Sandbox Agreement — Adoption of regional fit-and-proper criteria and regulatory sandbox framework for fintech and blockchain innovation.[2]
Market-entry checklist
- 1Determine if tokens are securitiesConsult CMA to assess if token issuance falls under the Capital Markets Act requiring a prospectus.
- 2Apply for CMA Fit & ProperEnsure key personnel meet the EASRA regional fit-and-proper assessment criteria for market practitioners.
- 3Engage BoU on paymentsClarify with the Bank of Uganda that crypto is not legal tender and plan fiat on-ramps via licensed banks.
- 4Register with UCCObtain necessary telecommunications and internet service provider licenses from the Uganda Communications Commission.
- 5Implement AML/CFT policiesAdopt robust Anti-Money Laundering and Counter-Terrorism Financing frameworks aligned with FATF recommendations.