Crypto assets and the technologies behind them are transforming the global financial system. At the same time, their legal nature, their economic effects and the risks they create for financial stability have led states to take very different regulatory paths. The member states of the Cooperation Council for the Arab States of the Gulf (the Gulf Cooperation Council or "GCC") have similar economic structures and share the goal of becoming financial hubs, yet they have not adopted a common regulatory framework for crypto assets. They have instead built multi-layered and fragmented regimes reflecting different policy priorities.
This fragmentation continues as of the first half of 2026, although licensing regimes now cover a wider range of activities and dedicated frameworks have appeared for tokenization and payment tokens.
Development of Crypto Asset Regulation in Türkiye
Türkiye has regulated crypto assets step by step, driven mainly by concerns about financial stability and the fight against money laundering and terrorist financing. At first, crypto assets were not recognised as fiat currency, electronic money, payment instruments or capital markets instruments, and their use in payment transactions was banned outright, which in practice kept them out of the payment system.
As the market grew, policy moved from restricting retail use to placing market infrastructure under regulatory supervision. By 2024, capital markets legislation had defined the core concepts of crypto assets, crypto asset service providers, trading platforms and custody services, thereby establishing the legal foundation of the sector. Compliance obligations were expanded at the same time under the regulations of the Financial Crimes Investigation Board (MASAK). In 2025, several measures followed in quick succession. The "transfer rule", which requires the sender's and recipient's data to be recorded and transmitted in crypto transfers, became mandatory. Detailed requirements were introduced on minimum capital, organisational structure, internal controls and risk management, operational obligations were set out in detail, and supervisory mechanisms were reinforced. Account suspension and seizure regimes further widened the power of administrative authorities to intervene directly in the market and made the sanctions regime stricter. As a result, the Turkish crypto market has moved from a largely unregulated environment to one under comprehensive and strict regulatory supervision.
In 2026, the minimum capital requirements for obtaining a licence from the Capital Markets Board (CMB) were increased, and custody services were made subject to security standards comparable to those in the banking sector. The transition period requiring unlicensed platforms to wind down their operations ended on 30 June 2026, which consolidated the market around licensed and supervised entities.
Beyond licensing and conduct requirements, MASAK regulations have tightened the system further through additional operational restrictions, including waiting periods for transfers, limits on the use of stablecoins and enhanced KYC and AML obligations. On taxation, a legislative proposal on the taxation of crypto assets was submitted to Parliament in March 2026 and later withdrawn. As of mid-2026, no crypto-specific tax regime is in force, although preparatory work continues.
Legal Approach to Crypto Assets in the GCC Countries
Regulatory approaches in the GCC countries have been shaped mainly by the aims of preserving financial stability, combating money laundering and protecting the banking system. Because of their speculative nature and persistent legal uncertainty, crypto activities were first limited through public warnings and de facto bans. Over time, however, growing recognition of the potential of blockchain in financial infrastructure has led to more flexible and selective regulatory approaches.
This trend became more visible in 2026 and has produced a dual policy structure across the region. Private sector crypto activities remain restricted, while state-controlled digital currency (CBDC) initiatives and tokenized financial instrument projects are actively encouraged. Within this context, three main regulatory models have developed in the GCC region.
Bahrain
Under the regime set up by its Central Bank, Bahrain subjects crypto asset service providers to requirements on minimum capital, risk management, protection of client assets, technology standards and cybersecurity. Digital token offerings are also regulated, which further strengthens investor protection. Crypto assets are not recognised as legal tender, but activity continues in a controlled way through regulatory sandboxes and cooperation with banks. In 2025 and 2026, Bahrain extended its regulatory framework to stablecoins and tokenized financial products and strengthened its ambition to be a regional financial hub by licensing international crypto exchanges.
United Arab Emirates
The United Arab Emirates (UAE), and Dubai in particular, has created a comprehensive legal framework aimed at becoming a global crypto hub. The Virtual Assets Law introduced licensing requirements for crypto asset service providers and appointed the Dubai Virtual Assets Regulatory Authority (VARA) as the competent administrative authority, while the Dubai International Financial Centre has its own separate regime. Crypto transactions by individual investors are generally allowed, but businesses are subject to strict anti-money laundering and reporting obligations. Tax advantages and regulatory clarity have contributed to high rates of crypto adoption.
In 2026, the regulatory landscape in the UAE became considerably more complex. At the federal level, the capital markets authority (CMA) reorganised crypto-related activities into eight separate licensing categories. VARA published guidance on token issuances, introduced specific rules for derivative products and provided for the supervision of DeFi and payment tokens by the Central Bank. The outcome is a multi-layered structure in which five different administrative authorities hold concurrent powers, so market participants may need several licences depending on the scope of their activities.
Qatar
Qatar keeps its ban on cryptocurrencies while allowing the tokenization of capital markets instruments, and draws a clear line between the two. Its digital bond issuances reflect this approach. Cryptocurrencies remain restricted, while the tokenization of capital markets instruments and distributed ledger technologies are welcomed. Under the "excluded token" approach adopted after 2024, conventional crypto assets remain prohibited, whereas tokenized financial instruments are treated as a regulated market activity.
Saudi Arabia
Saudi Arabia is cautious about public crypto markets and gives priority to central bank digital currency initiatives and institutional blockchain projects. This is a dual-track policy focused on state-controlled and permissioned digital finance solutions.
Kuwait
Kuwait applies one of the strictest regimes in the region. Crypto assets have no legal status and may not be used for payment or investment purposes. Banks and regulated entities are prohibited from engaging in crypto-related activities altogether. In 2025 and 2026, this approach became even stricter, with heavier sanctions on crypto mining and significant operational restrictions prompted by concerns over energy consumption.
Oman
Oman does not impose an outright ban but follows a cautious and gradual regulatory strategy based on public warnings and registration requirements.
Comparative Assessment
Legal approaches in the GCC do not converge on a single model and instead vary according to the risk perceptions and strategic goals of each country. Türkiye, on the other hand, represents a distinctive transitional model built on licensing, supervision and compliance obligations.
As of 2026, the main difference between Türkiye and the GCC is structural. Türkiye is moving toward a centralised and uniform licensing regime, whereas regulatory authority in the GCC is still spread across several administrative bodies and fragmented structures remain. Even so, both regions follow a shared trend of imposing bank-like obligations on service providers and excluding unlicensed actors from the system.
Although private crypto activity is still restricted throughout the GCC, state-backed digital currency and tokenization initiatives receive strong emphasis. In Türkiye, by comparison, developments in this field are still at an early stage.
In both the GCC and Türkiye, crypto regulation is moving away from outright prohibition toward a risk-based and incremental approach to lawmaking. Tokenization initiatives and CBDC projects are likely to stay at the centre of the regulatory agenda, which places Türkiye's regulatory direction broadly in line with global developments.