Stablecoins for companies in Costa Rica: the legal picture

A company invoicing a Costa Rican client, or a Costa Rican exporter billing a US buyer, eventually runs into the same question once someone proposes settling in USDC instead of wiring dollars: is that allowed on the Costa Rican side, who supervises it, and what new obligation appears. For years the honest answer in Costa Rica was close to a regulatory gap. That is about to change, though not quite the way many expected.

At Soulbit Academy we lay out the framework without dressing it up. Costa Rica has no dedicated crypto-asset market law like the ones already in force elsewhere in the region. What it will have, from 19 September 2026, is an anti money laundering reform that for the first time names and obliges whoever provides services on those assets. Soulbit is a stablecoin payments and treasury rail for businesses, not a bank and not a legal adviser, and by the end of this article you will see precisely what it covers with Costa Rica and what it does not.

Stablecoins for companies in Costa Rica: what Law 10961 changes

Costa Rica regulates virtual assets through the anti money laundering track, not through a dedicated crypto-asset market law. The Legislative Assembly passed, unanimously, in second debate on 25 May 2026 a reform to Law 7786, the Law on Narcotics, Psychotropic Substances, Unauthorized Drug Use, Related Activities, Money Laundering and Terrorist Financing, dating from 1998. The text was published as Law 10961 in the Alcance N.° 78 to La Gaceta N.° 113 on 19 June 2026, and will take effect three months after that publication, around 19 September 2026.

Its relevance to this sector is specific. The reform adds article 15 quater to Law 7786 and creates the virtual asset service provider (VASP) category, covering the exchange of virtual assets for one another or for legal tender, custody or administration of virtual assets on behalf of third parties, transfers, and financial services tied to the issuance or sale of those assets. Whoever provides those services habitually and professionally will become a reporting entity under the anti money laundering regime, alongside the entities already covered by articles 15 and 15 bis of the same law.

It is worth not confusing this with a license. Registration before the Superintendencia General de Entidades Financieras (SUGEF) will not authorise exchange activity or bring it under prudential supervision the way a bank is supervised: it will impose customer identification, due diligence, record keeping and suspicious activity reporting obligations. The background is specific too: the Financial Action Task Force (FATF) flagged Costa Rica in 2024 for the regulatory gap around companies operating with crypto assets, in line with its Recommendation 15. A separate Crypto-Asset Market Law bill, file 23.415, is still sitting in legislative committee and, as of this article, is not yet in force. The full regional picture, including countries that already have a dedicated crypto-asset market law, is in the crypto asset regulatory landscape in Latin America.

Who will supervise: the Central Bank, SUGEF and the ICD's financial intelligence unit

The BCCR, SUGEF and the ICD's financial intelligence unit split the supervision of virtual assets in Costa Rica: monetary policy, anti money laundering control and suspicious activity reporting, respectively. None of the three issues an exchange license. The Central Bank of Costa Rica (BCCR) issues the colón and sets monetary and exchange policy. SUGEF will supervise virtual asset service providers strictly for money laundering, terrorist financing and weapons proliferation financing purposes, on a risk-based approach whose implementing rules fall to the National Council for the Supervision of the Financial System (CONASSIF). Suspicious activity reports will reach the Financial Intelligence Unit (UIF), which sits inside the Costa Rican Drug Institute (ICD) and already receives reports from entities obligated under articles 15 and 15 bis of Law 7786.

What does registration before SUGEF actually authorise a virtual asset service provider to do?

Nothing resembling a license to operate. Law 10961 does not authorise the exchange business or subject it to prudential supervision like a bank or a regulated financial entity: it requires customer identification, due diligence, transaction record keeping and reporting of suspicious operations to the UIF. The sanctions regime sets fines of between 5% and 50% of the transaction amount for certain breaches, and two to one hundred base salaries for failures around registration, due diligence, reporting or internal controls.

The Ministry of Finance is the tax authority and, as of this article, has not issued a specific ruling on how transactions in virtual assets are taxed. For a Costa Rican counterparty, that means the tax treatment of a stablecoin transaction follows the general income tax regime until a dedicated ruling exists, and the conservative approach is documenting every transaction as if it needed to be explained to the tax authority with no room for ambiguity.

The exchange regime: what the Central Bank's organic law allows

The colón is Costa Rica's sole legal tender under the Organic Law of the Central Bank of Costa Rica, Law 7558. The same law states that acts, contracts and obligations denominated in foreign currency are valid, effective and enforceable in the country, but, absent an express exception, can be paid in colones at the payer's option, calculated at the Central Bank's reference exchange rate for foreign exchange market operations.

The law itself recognises exceptions where foreign currency can be agreed and demanded directly: obligations and contracts that must be settled from Costa Rica abroad and vice versa, operations directly tied to imports and exports, and operations carried out with funds originating abroad. That is the legal base behind why the dollar circulates so naturally across much of Costa Rican foreign trade, even though the colón remains the country's only legal tender.

Stablecoins such as USDC and USDT sit outside Costa Rica's institutional exchange market and outside any dedicated digital asset regime. Their use between companies rests on general contract freedom and, where the transaction is foreign trade related, on the exceptions Law 7558 already allows for agreeing and paying directly in foreign currency.

What changes in the day to day of a company operating with Costa Rica

What changes day to day is the collection and payment circuit against a counterparty that today depends on an international wire. USDC is a digital dollar issued by Circle, backed by cash reserves and US Treasury bills, and USDT is issued by Tether; both are the two stablecoins Soulbit V1 supports. With a USDC collection, the counterparty shares a payment link or a QR tied to the invoice, the buyer pays, and the transaction settles in minutes, with no correspondent bank chain slowing down a traditional international transfer.

Operation	Traditional banking route with Costa Rica	Route with stablecoins
Collect from an overseas client	International transfer, 1 to 5 business days	Payment link or QR, settlement in minutes
Pay a Costa Rican supplier	Bank order through a correspondent chain	Transfer from the stablecoin balance
Pay contractors across several countries	One transfer per person	Batch payment from a single balance
Hold treasury in dollars	Dollar account tied to local banking	USDC or USDT balance under institutional custody
Move into colones on the Costa Rican side	Bank conversion at the reference exchange rate	Handled by the counterparty with its own bank, no local rail in V1
Trace each movement	Bank statement arriving late	On-chain identifier verifiable immediately

Compliance: KYB, reporting to the UIF and international exchange under the CARF

KYB is the process that validates the Costa Rican entity, its line of business and its ultimate beneficial owners before the operating account is opened, regardless of whether the counterparty qualifies as a VASP. Before operating on any platform, a KYB process validates the company, its business activity and its ultimate beneficial owners, and assembling it with up to date corporate documents saves weeks once the relationship needs to open.

Will a Costa Rican counterparty collecting in USDC have to report suspicious operations to the ICD's UIF?

In principle no, unless it provides the regulated service to third parties. Law 10961's reporting obligation falls on the virtual asset service provider, not on whoever simply uses the asset to collect its own invoices and pay its own team. It is the same difference as between holding an account and being the entity that runs it. That said, every transaction still sits under monitoring of the origin and destination of funds, the same logic behind the Travel Rule the Financial Action Task Force expects for virtual asset transfers, covered in detail in what the FATF Travel Rule means for crypto payments.

That same international monitoring is reinforced by the OECD's Crypto-Asset Reporting Framework (CARF), the automatic exchange of information standard for crypto assets between tax administrations. Costa Rica signed the CARF multilateral competent authority agreement on 26 November 2024, with data collection planned during 2026 and the first automatic exchange between jurisdictions in 2027. The full picture of what it requires and from whom is in CARF: the OECD's Crypto-Asset Reporting Framework. Good practice, obligation or not, is keeping the contract, invoice, on-chain identifier, gross amount, network fee and any conversion quote in one file per transaction, a record that supports both accounting and any future review by the tax authority or the UIF.

What Soulbit V1 delivers with Costa Rica and what it does not

Soulbit V1 has one concrete limit with Costa Rica worth stating early: there is no local banking rail.

Need when operating with Costa Rica	Covered by V1?	How it is resolved
Collect from abroad in USDC or USDT	Yes	Payment links and QRs tied to each invoice
Hold treasury in digital dollars	Yes	Business account with institutional custody
Pay payroll or suppliers across several countries	Yes	Recurring payroll and batch payments
Convert to fiat	Yes, in USD, EUR and GBP	Conversion by quote on request
Deposit in Costa Rican colones	No	The only local banking rail in V1 is Colombia
Cards, yield, token or native app	No	Outside the scope of V1

The honest reading is that V1 covers the dollar layer of business with Costa Rica, useful for anyone collecting from or paying into the country, and it does not cover the colón layer, which still depends entirely on each counterparty's own local bank and on the exchange regime Law 7558 sets out. The same limit exists today with Guatemala, whose virtual asset framework we cover in stablecoins for companies in Guatemala: neither country has a local banking rail in V1 yet, even though each regulates the asset under a different legal architecture.

Where to start

Three steps organise the decision without committing to anything. First, review with Costa Rican legal counsel whether the intended operation sits in the use of the asset or edges into providing a VASP service, especially if funds on behalf of third parties would ever be involved. Second, prepare the corporate file for KYB before it is needed. Third, pick a narrow pilot: one overseas counterparty, one invoice, one full cycle of collection and reconciliation. Country level detail sits in the crypto payments guide for Costa Rica.

The pilot is worth measuring with concrete criteria rather than impressions. How long the collection took from the moment the invoice was approved. How much was deducted along the way. How many minutes it took to leave the transaction reconciled with its identifier. And whether the accountant could review the file without asking for extra explanations. With those four data points, expanding the pilot stops being a matter of opinion and becomes a decision backed by the company's own numbers.