Rwanda's Virtual Asset Law takes effect with no licensing framework in place

Rwanda's Law No. 023/2026 governing virtual asset business entered into force on 28 May 2026 without a transitional period. From that date, businesses providing virtual asset services became subject to criminal liability for operating without a licence, even though no licensing framework has yet been issued.

The Law creates six criminal offences related to virtual asset business. Among them, providing virtual asset services without a licence is punishable by a fine of FRW 70 million to FRW 100 million, while issuing a virtual asset without prior approval carries a fine of FRW 120 million to FRW 150 million.

As of 25 August 2026, however, there is still no implementing regulation establishing how firms can apply for or obtain a licence.

A review of every Official Gazette published after the Law took effect shows no implementing regulations for Law No. 023/2026. The Capital Market Authority's published regulations, guidelines, and directives also contain no virtual asset licensing framework, with the latest documents in each category predating the Law.

The result is a regulatory gap: the offences created by the Law are already in force, but the administrative mechanism needed to comply with the licensing requirement has not yet been introduced.