Zimbabwe

Retail_Trading_Status

Gray-Zone High Confidence

Analysis ID: #830
Version: Latest
Created: 2025-12-12 05:25
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Workflow Stage: Step 1

Executive Summary

Retail cryptocurrency trading in Zimbabwe operates in a regulatory gray zone characterized by a strict banking ban on the one hand and a thriving, tolerated peer-to-peer market on the other. While the Reserve Bank of Zimbabwe (RBZ) prohibits financial institutions from processing transactions for crypto entities (Circular No. 2/2018), individual possession and trading are not criminalized. In 2024, the government began formal consultations to establish a regulatory framework for Virtual Asset Service Providers (VASPs), signaling a shift from prohibition to potential regulation, though no licenses have been issued to private exchanges as of late 2025.

Key Pillars

Reserve Bank of Zimbabwe (RBZ) - Primary regulator enforcing the banking ban on crypto entities
Securities and Exchange Commission of Zimbabwe (SECZ) - Currently drafting a framework for virtual asset trading
Zimbabwe Revenue Authority (ZIMRA) - Treats cryptocurrency gains as taxable income/capital gains
National Risk Assessment Coordination Committee (NRACC) - Leading the 2024 consultation on crypto regulation

Landmark Laws

RBZ Circular to Banking Institutions No. 2/2018 (Circular No. 2/2018) - Enacted: 2018-05-11
- Directed all banking institutions to close accounts of cryptocurrency exchanges and prohibited them from processing virtual currency transactions.
- Source

Gold-Backed Digital Token (ZiG) Issuance (RBZ Press Statement) - Enacted: 2023-05-08
- Introduced state-issued gold-backed digital tokens (ZiG) as legal tender and a store of value, distinct from private cryptocurrencies.
- Source

Finance Act (Capital Gains Tax) (Income Tax Act)
- General tax provisions applied by ZIMRA to tax gains from cryptocurrency trading as capital gains.

Considerations

Banking Ban: Crypto exchanges cannot open local bank accounts, forcing the market into P2P channels.
State Competition: The government promotes its own 'ZiG' (Zimbabwe Gold) digital token while restricting private crypto.
No Consumer Protection: Users have no recourse to the central bank for losses in private crypto scams.
Tax Liability: Despite the banking ban, ZIMRA expects disclosure of crypto trading profits for tax purposes.

Notes

The 'Gray-Zone' status is heavily influenced by the 2018 banking ban which remains the operational reality for businesses, despite recent government rhetoric about regulation. The introduction of ZiG (Zimbabwe Gold) complicates the landscape, as it is a 'crypto-like' product that is fully legal and state-backed, unlike Bitcoin or USDT.

Remaining Uncertainties

The exact timeline for the enactment of the proposed VASP regulatory framework.
Whether the banking ban (Circular 2/2018) will be formally rescinded once the new regulations are in place.
The extent to which the state-backed ZiG token will be prioritized over private cryptocurrencies in the new framework.

Detailed Explanation

Zimbabwe's cryptocurrency regulatory environment is definitively a Gray-Zone, characterized by a contradictory stance of official prohibition and de facto tolerance. The operational reality is dictated by the Reserve Bank of Zimbabwe's (RBZ) Circular No. 2/2018, enacted on May 11, 2018, which prohibits all banking institutions from processing transactions for cryptocurrency exchanges and mandates the closure of their accounts. This banking ban has effectively forced the retail cryptocurrency market into thriving, unregulated peer-to-peer (P2P) channels, as private exchanges cannot operate with formal banking services. While this circular creates a significant barrier, individual possession and trading of cryptocurrencies like Bitcoin are not criminalized, creating a legal limbo. The Zimbabwe Revenue Authority (ZIMRA) further complicates this gray zone by applying general provisions of the Income Tax Act, specifically capital gains tax, to cryptocurrency trading profits, imposing a tax liability on an activity the banking system is barred from supporting. The regulatory landscape is fragmented, with the Securities and Exchange Commission of Zimbabwe (SECZ) involved in drafting a framework for virtual asset trading, but no licenses have been issued to private exchanges as of late 2025. A critical complicating factor is the state's introduction of its own digital asset, the gold-backed digital token (ZiG), launched via an RBZ press statement on May 8, 2023. This state-issued, legal tender token exists in direct competition with private cryptocurrencies, which remain restricted. The National Risk Assessment Coordination Committee (NRACC) led formal consultations in 2024 on regulating Virtual Asset Service Providers (VASPs), signaling a potential future shift from prohibition to a regulated framework. However, the enduring power of the 2018 banking ban, the lack of consumer protection for users of private crypto, and the promotion of the state-backed ZiG token sustain the current gray-zone status where activity is technically constrained but practically widespread.

Summary Points

I. Regulatory Status

Gray-Zone: The environment is characterized by a strict banking prohibition coexisting with a tolerated peer-to-peer market.
Individual possession and trading of cryptocurrencies are not criminalized, but exchanges are barred from the formal banking system.
The government began formal consultations in 2024 on establishing a regulatory framework for Virtual Asset Service Providers (VASPs), indicating a potential future shift, but no licenses for private exchanges have been issued as of late 2025.

II. Key Regulatory Bodies

Reserve Bank of Zimbabwe (RBZ): The primary financial regulator enforcing the banking ban on cryptocurrency entities through its 2018 circular.
Securities and Exchange Commission of Zimbabwe (SECZ): Currently tasked with drafting a regulatory framework for virtual asset trading.
Zimbabwe Revenue Authority (ZIMRA): The tax authority that treats gains from cryptocurrency trading as taxable income or capital gains.
National Risk Assessment Coordination Committee (NRACC): Led the 2024 consultation process on cryptocurrency regulation.

III. Important Legislation

RBZ Circular to Banking Institutions No. 2/2018 (Circular No. 2/2018): Enacted on May 11, 2018. This is the cornerstone regulation that directed all banking institutions to close accounts of cryptocurrency exchanges and prohibited them from processing virtual currency transactions.
Gold-Backed Digital Token (ZiG) Issuance (RBZ Press Statement): Announced on May 8, 2023. This introduced state-issued gold-backed digital tokens (ZiG) as legal tender, creating a government-sanctioned digital asset distinct from private cryptocurrencies.
Finance Act (Capital Gains Tax) / Income Tax Act: General tax provisions applied by ZIMRA to tax gains from cryptocurrency trading.

IV. Compliance Requirements

Tax Compliance: Individuals and entities engaged in cryptocurrency trading are required by ZIMRA to declare profits and pay applicable capital gains tax, despite the banking ban on the activity.

V. Notable Restrictions or Limitations

Banking Ban: The RBZ's 2018 circular creates a fundamental restriction, prohibiting financial institutions from opening accounts for or processing transactions for cryptocurrency exchanges. This forces all commercial crypto activity into peer-to-peer (P2P) markets.
State Competition: The government actively promotes its own 'ZiG' (Zimbabwe Gold) digital token as legal tender while maintaining restrictions on private cryptocurrencies.
No Formal Consumer Protection: Users trading cryptocurrencies on P2P platforms have no recourse to the central bank or formal financial ombudsman services in case of scams or losses.

VI. Recent Developments or Notes

The 2024 consultations led by the NRACC represent the most significant recent development, signaling a governmental move to explore formal regulation beyond the 2018 prohibition.
The 'Gray-Zone' status is heavily influenced by the fact that the 2018 banking ban remains the operational reality for businesses, despite recent regulatory rhetoric.
The introduction of the ZiG token complicates the landscape, as it is a 'crypto-like' product that is fully legal and state-backed, unlike Bitcoin or USDT, which operate in a restricted space.

Full Analysis Report

The regulatory status of retail cryptocurrency trading in Zimbabwe is defined by a dichotomy between official banking restrictions and practical widespread adoption. The defining regulatory instrument remains the Reserve Bank of Zimbabwe's (RBZ) Circular No. 2/2018, which prohibited financial institutions from dealing with cryptocurrency businesses. While the High Court technically lifted this ban for a specific exchange (Golix) in May 2018, the banking sector has maintained a de facto embargo on crypto-related accounts to avoid regulatory censure. Consequently, there are no licensed domestic exchanges, and retail trading is conducted almost exclusively through peer-to-peer (P2P) platforms and informal groups.

Despite the banking blockade, the Zimbabwean government has not criminalized the ownership or trading of cryptocurrencies by individuals. In fact, in a significant policy shift during 2024, the government established a committee involving the RBZ and the Securities and Exchange Commission of Zimbabwe (SECZ) to consult on a regulatory framework. This move, driven by the need to combat money laundering and tax evasion, suggests a transition towards an 'Allowed-Regulated' status in the future, but as of late 2025, no such framework has been enacted, and no licenses have been issued.

A unique feature of the Zimbabwean landscape is the introduction of the 'Zimbabwe Gold' (ZiG) digital token by the central bank. Unlike private cryptocurrencies like Bitcoin, ZiG is a government-issued, gold-backed digital asset granted legal tender status for domestic transactions. The government actively promotes ZiG as a stable alternative to the volatile local currency, effectively positioning it as a state-sanctioned competitor to private crypto assets. This creates a dual environment where state digital assets are fully regulated and promoted, while private crypto assets remain in a regulatory gray zone—tolerated but financially ostracized.

Taxation adds another layer of complexity. The Zimbabwe Revenue Authority (ZIMRA) asserts that income or capital gains derived from cryptocurrency trading are taxable, despite the lack of a formal licensing regime for the platforms generating these gains. Traders are expected to voluntarily declare profits, creating a paradoxical situation where the activity is recognized for tax purposes but effectively unbanked by the financial regulator.

The regulatory status of retail cryptocurrency trading in Zimbabwe is defined by a dichotomy between official banking restrictions and practical widespread adoption. The defining regulatory instrument remains the Reserve Bank of Zimbabwe's (RBZ) Circular No. 2/2018, which prohibited financial institutions from dealing with cryptocurrency businesses. While the High Court technically lifted this ban for a specific exchange (Golix) in May 2018, the banking sector has maintained a de facto embargo on crypto-related accounts to avoid regulatory censure. Consequently, there are no licensed domestic exchanges, and retail trading is conducted almost exclusively through peer-to-peer (P2P) platforms and informal groups.

Despite the banking blockade, the Zimbabwean government has not criminalized the ownership or trading of cryptocurrencies by individuals. In fact, in a significant policy shift during 2024, the government established a committee involving the RBZ and the Securities and Exchange Commission of Zimbabwe (SECZ) to consult on a regulatory framework. This move, driven by the need to combat money laundering and tax evasion, suggests a transition towards an 'Allowed-Regulated' status in the future, but as of late 2025, no such framework has been enacted, and no licenses have been issued.

A unique feature of the Zimbabwean landscape is the introduction of the 'Zimbabwe Gold' (ZiG) digital token by the central bank. Unlike private cryptocurrencies like Bitcoin, ZiG is a government-issued, gold-backed digital asset granted legal tender status for domestic transactions. The government actively promotes ZiG as a stable alternative to the volatile local currency, effectively positioning it as a state-sanctioned competitor to private crypto assets. This creates a dual environment where state digital assets are fully regulated and promoted, while private crypto assets remain in a regulatory gray zone—tolerated but financially ostracized.

Taxation adds another layer of complexity. The Zimbabwe Revenue Authority (ZIMRA) asserts that income or capital gains derived from cryptocurrency trading are taxable, despite the lack of a formal licensing regime for the platforms generating these gains. Traders are expected to voluntarily declare profits, creating a paradoxical situation where the activity is recognized for tax purposes but effectively unbanked by the financial regulator.

Source Evidence

Primary and secondary sources cited in this analysis

Circular to Banking Institutions No. 2/2018: Virtual Currencies primary (regulator)

2018-05-11

"Banking institutions are required to... ensure that they do not use, trade, hold and/or transact in any way in virtual currencies."

Press Statement on Issuance of Gold-Backed Digital Tokens primary (regulator)

2023-05-04

"The gold-backed digital tokens will be used both as a means of payment and a store of value."

Securities and Exchange Commission of Zimbabwe Website primary (regulator)

2024-06-19

"SECZ is collaborating to develop a framework for virtual asset trading."

Zimbabwe will introduce crypto regulation in major policy turnaround secondary (news)

2024-09-10

"Zimbabwe is working on its first-ever crypto regulation... In May 2024, the government-appointed National Risk Assessment Coordination Committee (NRACC) began consultations."

Zimbabwe Opens Consultation on Cryptocurrency Regulation secondary (news)

2024-06-12

"The government has established a committee to consult with operators and compile their comments by June 26."