What South Africa, Rwanda and Zimbabwe's latest reforms mean for crypto regulation in Africa

By Lerato Lamola, partner at Webber Wentzel (South Africa), in collaboration with Emmanuel Muragijimana, partner and Tamara Munya Burunga, associate at K-Solutions & Partners (Rwanda) and Nellie Tiyago, partner at Scalen & Holderness (Zimbabwe)

When Webber Wentzel published its Virtual Assets Regulation Across Africa guide, the continent's regulatory landscape was still taking shape. While many jurisdictions had begun considering how to regulate crypto assets, legislative frameworks remained fragmented and, in some cases, uncertain. Since then, several jurisdictions have made meaningful progress. Some have refined existing regulatory frameworks, while others have introduced entirely new regimes designed specifically for virtual assets. Three recent developments illustrate how the landscape is evolving: South Africa's changing approach to exchange control, Rwanda's introduction of a comprehensive virtual asset framework and Zimbabwe's emergence as one of the continent's most comprehensive digital asset regulatory jurisdictions.

Although the three jurisdictions have adopted different regulatory models, they reflect a broader trend across Africa. The conversation has shifted from whether crypto assets should be regulated to how they should be regulated in a way that balances innovation, market integrity and financial stability.

South Africa's evolving regulatory framework

South Africa has been at the forefront of crypto asset regulation on the continent, with crypto assets already recognised as financial products for regulatory purposes. However, one area that has remained uncertain is how crypto assets should be treated under the country's exchange control framework. That uncertainty has become more pronounced following two recent High Court decisions that reached different conclusions on whether crypto assets fall within the existing Exchange Control Regulations. In Standard Bank v South African Reserve Bank (May 2025), the court found that cryptocurrencies are neither "currency" nor "capital" as contemplated in the regulations, adopting a strict interpretation of the legislative wording.

A year later, in Mangundhla v South African Reserve Bank (June 2026), the court reached the opposite conclusion, holding that Bitcoin could constitute both capital and a form of money because of its economic function as a store of value and medium of exchange.

These contrasting judgments highlight the challenges of applying decades-old exchange control legislation to rapidly evolving digital assets. They also create practical uncertainty for businesses involved in cross-border crypto transactions, where similar facts could produce different legal outcomes depending on the interpretation adopted.

The South African Reserve Bank (SARB) has responded by proposing draft Capital Flow Management Regulations that would expressly include crypto assets within the definition of "capital". If adopted, the regulations would provide greater legal certainty by bringing crypto assets squarely within South Africa's exchange control framework. In August 2026, the SARB published the draft Crypto Assets Manual for Cross-Border Activities, which is to be read with the Capital Flow Management Regulations. The draft manual provides practical guidance on the implementation of the draft regulations, in particular the application and adjudication process to conduct the business of an Authorised Crypto Asset Service Provider (CASP), the permissions and conditions applicable to cross-border crypto asset transactions, details of related administrative responsibilities, and reporting requirements to the SARB.

The practical implications could be significant. Cross-border crypto transactions may become subject to exchange control approval requirements or authorised dealer processes, while regulatory enforcement would be supported by a clearer statutory basis.

Based on the draft documents published, it is clear that the SARB views the point at which crypto asset transactions are regarded as cross-border as being when crypto assets are transferred between a domestic Authorised CASP and an offshore CASP, or from a domestic Authorised CASP to a non-custodial wallet, resulting in a cross-border inflow or outflow that must be reported to the SARB. The trigger point means, if published in their current form, that only individuals will be allowed to externalise crypto assets via Authorised CASPs in terms of their single discretionary allowance or foreign capital allowance.

Taken together, these developments suggest that South Africa is moving towards a more integrated regulatory framework. Crypto assets will increasingly be regulated not only as financial products under the Financial Sector Conduct Authority's oversight, but also as assets with exchange control implications where they are used to transfer value across borders.

Rwanda adopts a purpose-built virtual asset regime

While South Africa is adapting existing legislation to accommodate crypto assets, Rwanda has chosen a different path by introducing legislation specifically designed to regulate the sector.

Law No. 023/2026 establishes a comprehensive licensing and supervisory framework for virtual asset service providers. Rather than relying on existing financial legislation, the law creates a dedicated regime governing how virtual asset businesses may operate within Rwanda.

Importantly, the legislation does not recognise crypto assets as legal tender. Instead, it permits their use within a regulated ecosystem where service providers are licensed and subject to ongoing supervision.

The institutional design is equally deliberate. Responsibility for regulating virtual asset service providers rests primarily with the Capital Market Authority, while the National Bank of Rwanda retains oversight of payment systems and monetary stability, and the Financial Intelligence Centre oversees anti-money laundering and counter-terrorism financing compliance.

This allocation of responsibilities reflects Rwanda's policy choice to regulate crypto assets primarily as investment and capital market instruments, rather than as payment mechanisms.

The legislation captures a broad range of virtual asset activities, including exchanges, custody services, trading platforms, transfer services, token issuance and investment management. At the same time, it excludes fully decentralised systems where there is no identifiable operator capable of complying with regulatory obligations, allowing regulators to focus on entities that can realistically be supervised.

The framework also incorporates safeguards aimed at managing systemic risk. Crypto assets cannot be used as a means of payment unless specifically authorised, while certain higher-risk activities, including crypto mixers, ATMs and mining infrastructure, are subject to restrictions.

Perhaps most notably, Rwanda's framework looks beyond today's market by expressly addressing tokenisation, virtual asset offerings and the issuance of stablecoins, subject to regulatory approval. In doing so, Rwanda is signalling an ambition not only to regulate existing market activity but also to create an environment capable of supporting future digital financial products.

These developments position Rwanda as one of the continent's more comprehensive and forward-looking virtual asset jurisdictions.

Zimbabwe builds a comprehensive digital asset ecosystem

While South Africa is refining existing legislation and Rwanda has adopted a dedicated virtual asset law, Zimbabwe has pursued a broader regulatory strategy by introducing a coordinated framework that regulates the full digital asset lifecycle, from issuance and trading to custody, tokenisation and capital markets participation.

Between 2025 and 2026, Zimbabwe enacted a series of legislative and regulatory reforms that formally brought virtual assets, virtual asset service providers (VASPs), tokenised securities and blockchain-based financial infrastructure within its legal framework. The reforms are built on three interconnected pillars: anti-money laundering regulation, securities and capital markets regulation, and the specialised framework of the Victoria Falls International Financial Services Centre (VFIFSC).

The Finance Act, 2025 introduced statutory recognition of virtual assets and VASPs, moving activities such as virtual asset exchanges, custodial services, token issuances and virtual asset transfers from a largely uncertain regulatory position into the mainstream financial services framework. Virtual asset businesses are now required to register with the Financial Intelligence Unit and comply with ongoing anti-money laundering and counter-terrorist financing obligations.

The regulatory framework was further expanded through the Money Laundering and Proceeds of Crime (Virtual Asset Service Providers Registration) Regulations, 2026, which introduced detailed requirements relating to governance, customer due diligence, cybersecurity measures, Travel Rule compliance and regulatory supervision. Significantly, the framework may extend to certain decentralised finance (DeFi) arrangements where operators exercise sufficient control over the relevant platform or protocol.

Zimbabwe has also integrated digital assets into its securities regulatory framework. Virtual token exchanges, token offerings and other token-related activities may require licensing under the Securities and Exchange Act, creating a dual-regulatory model that combines financial crime oversight with securities regulation.

Perhaps the most distinctive aspect of Zimbabwe's approach is the role of the Victoria Falls International Financial Services Centre. Within the VFIFSC, legislation expressly recognises digital asset trading facilities, digital asset custody services, cryptocurrencies, stablecoins, utility tokens and security tokens. The framework also provides legal recognition for smart contracts and distributed ledger technology and introduces dedicated rules for tokenised securities, digital asset funds and digital asset investment markets.

The Victoria Falls Stock Exchange has gone a step further by establishing a dedicated listing regime for digital asset issuers and tokenised securities, creating a pathway for blockchain-based financial instruments to access regulated capital markets.

Taken together, these reforms position Zimbabwe among the more sophisticated digital asset jurisdictions on the continent. Rather than regulating crypto assets in isolation, the framework seeks to create an ecosystem capable of supporting innovation, capital formation and digital financial markets within a supervised regulatory environment.

Different approaches, shared direction across Africa

Although South Africa, Rwanda and Zimbabwe have adopted different regulatory strategies, all three demonstrate that African regulators are moving towards more mature and structured oversight of digital assets.

South Africa is refining existing financial and exchange control laws to accommodate crypto assets within its broader regulatory framework. Rwanda has introduced a dedicated legislative regime centred on licensing, supervision and market conduct. Zimbabwe has taken a broader ecosystem approach, integrating virtual assets into anti-money laundering regulation, securities regulation, fintech frameworks and capital markets infrastructure.

The policy priorities also differ. South Africa's recent developments are focused on clarifying exchange control treatment, Rwanda's framework is aimed at creating a regulated market for virtual asset businesses, and Zimbabwe's reforms seek to support digital asset innovation across the full investment and capital markets value chain.

Despite these differences, all three jurisdictions recognise that regulatory certainty will be increasingly important for investors, financial institutions and digital asset businesses operating across Africa.

Looking ahead

The African crypto asset landscape is entering a new phase. Rather than debating whether regulation is necessary, policymakers are increasingly focused on developing frameworks that provide certainty while supporting innovation and protecting financial systems.

For businesses operating in this space, the quality and practical implementation of regulatory frameworks will become increasingly important. Jurisdictions that offer clear licensing regimes, effective supervision and predictable regulatory outcomes are likely to be better positioned to attract investment and support the growth of digital asset markets.

As more African countries continue to develop their own approaches, the focus will shift from the existence of regulation to its effectiveness. The jurisdictions that strike the right balance between innovation, market integrity and financial stability are likely to shape the next chapter of Africa's digital asset ecosystem.

Click here to read our Virtual Assets Regulation Across Africa guide, with a dedicated update on South Africa and Rwanda.

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