Madagascar Cryptocurrency Regulation: Legal Definitions, Licensing Gaps and AML Risk
Explore Madagascar’s statutory crypto definitions, SAMIFIN’s April 2026 licensing-gap findings, enforcement work and the limits of verified capital evidence.
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Madagascar’s law defines virtual assets and their service providers. That does not mean the country has a complete operational VASP licensing regime.
SAMIFIN’s April 2026 risk assessment makes the distinction explicit. It identifies a general legal reference alongside gaps in licensing, supervision and sector-specific controls.
The practical question is which permissions and obligations apply to the service a business plans to offer.
See our Africa cryptocurrency regulation directory for the wider comparison.
What did the AML amendment add?
Law No. 2023-026, promulgated on 1 February 2024, amends the existing AML/CFT law. Article 5 inserts definitions into Article 4 of the underlying law.
The virtual-asset definition appears at new point 33. It concerns a digital representation of value that can be digitally traded or transferred and used for payment or investment. It excludes specified representations already governed by other financial rules.
New point 36 defines a VASP by commercial activity performed for or on behalf of a customer.
| Activity covered by the definition | Why the distinction matters |
|---|---|
| Fiat-to-virtual-asset exchange | A commercial conversion service differs from a price calculator |
| Exchange between virtual assets | A service can raise regulatory questions without touching ariary |
| Transfers | Moving assets for customers differs from describing blockchain technology |
| Custody or administration | Control of customer assets raises separate responsibilities |
| Specified issuer-related financial services | A token offer needs analysis beyond ordinary company registration |
These are statutory definitions. They do not, on their own, identify a functioning application portal or establish approval for any exchange.
SAMIFIN’s official glossary also discusses the terminology. For article numbering, the enacted amendment is the controlling source used here.
What does the April 2026 assessment say?
SAMIFIN’s risk-assessment page links its VA/VASP assessment dated April 2026. The report’s pages 7–8 distinguish the legal definition from an operational sector framework.
Its discussion of government measures on page 29 identifies the absence of a dedicated licensing or prior-approval mechanism and a designated VASP supervisor at the time assessed.
The recommendations on page 33 call for a specific framework, an authorisation regime and a competent supervisory authority. Recommendations are not already-issued provider licences.
The report is an official assessment snapshot. We did not establish a later operational VASP register or provider-specific Malagasy authorisation in the sources reviewed.
Is cryptocurrency legal tender?
The assessment records the central bank’s 5 October 2021 public notice that cryptocurrencies are not legal tender. It discusses this in the context of the central bank’s statutory framework.
Not being legal tender is different from a universal prohibition on passive possession. Conversely, the absence of a dedicated licence identified by an assessment is not a general clearance for every activity.
A particular transaction can also raise payment, foreign-exchange, investment, fraud or financial-crime issues. Those questions need assessment against the actual facts and applicable rules.
The ariary remains the local-currency reference for this guide. A website expressing a Bitcoin price in MGA does not establish that it accepts ariary or can pay it out.
Who handles financial-crime concerns?
SAMIFIN is Madagascar’s financial intelligence unit. Its role in receiving and analysing financial intelligence should not be confused with issuing a general crypto-exchange licence.
In August 2026, SAMIFIN described an investigation and asset-recovery training programme involving public institutions and international support. It covered capabilities such as identification, tracing, investigation and recovery.
This is evidence of enforcement-capacity work. It does not establish that the participating institutions approved a retail exchange or that a dedicated licensing regime had commenced.
The distinction matters for a provider claiming that contact with an authority makes it regulated. Ask which authority issued which permission for which service.
How should a business approach AML obligations?
The amended law supplies relevant definitions and the wider AML framework. On page 29, SAMIFIN’s April assessment states that VASPs were not expressly recognised as reporting entities and identifies gaps in formal customer due-diligence and counterparty obligations. This finding concerns the framework assessed at that date.
The report recommends a dedicated authorisation regime and a designated supervisor. These remain recommendations in that document. A business should check subsequent legislation and any other regulated activities it performs.
A business should map its entity, customer role, assets, payment flows and custodial powers to the applicable provisions. It should obtain a legal assessment of its actual obligations rather than treat the report as an exemption.
Customer identification, beneficial ownership, monitoring, records and suspicious-transaction handling deserve explicit review. These are practical control topics, not a statement that this article has verified a complete VASP rulebook.
An ordinary company-registration certificate is not evidence that a specialist financial-service permission has been issued.
Is there a minimum VASP capital requirement?
A universal Malagasy VASP minimum capital figure was not independently established in this review.
That does not justify advertising a zero-capital licence. A licence cannot be priced or promised merely by borrowing the registration requirements of an ordinary company.
| Question | What the evidence supports |
|---|---|
| Does the law define VASPs? | Yes, through the 2023-026 amendment |
| Does the April assessment identify an operational licensing regime? | No, it describes a gap at that time |
| Was a later operational register established in this review? | No |
| Is a universal VASP capital amount verified? | No |
| Does this mean all other financial rules disappear? | No |
If a consultant quotes a capital amount, ask for the current enacted rule, the service category, the authority and the application route. Distinguish regulatory own funds from operating money and customer balances.
What should a consumer verify?
Start with the company that owes you a withdrawal or refund. A familiar brand can use different entities or third-party payment arrangements.
Then ask which country’s law governs the account, whether your residence is eligible and how the intended asset can be withdrawn. A foreign authorisation does not establish Malagasy supervision.
Our Madagascar exchange review and MGA withdrawal evidence explains why converter pages and card-country tables answer narrower questions.
The Mozambique VASP registration and AML guide and Malawi crypto regulation analysis provide regional comparisons. Their findings should not be imported into Madagascar.
What would change this assessment?
A later enacted sector framework, a formal supervisory designation, operational application instructions or an official provider register would require a fresh review.
A workshop, a draft proposal or a platform marketing page is a different kind of development. Record its date and purpose before treating it as a legal change.
Research scope
Research checked 5 November 2026. The enacted amendment, the official risk-assessment document and SAMIFIN’s public notices form the core sources.
The April report describes conditions at its assessment date. No later complete operational licensing framework, universal VASP capital amount or individual provider approval was independently established. Tax rates and the legal treatment of a specific transaction require separate analysis.
