Bybit in Uganda: the 2022 circular still decides everything

Updated 2026-09-17

Most guides written for Ugandan readers describe an account that does not exist here. The useful version starts from two documents: Bybit's own fiat restriction list, and a four-year-old circular from the Bank of Uganda that still decides what a Ugandan can and cannot do with a crypto exchange. Everything practical follows from those two.

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What Bybit itself restricts

Uganda is named on Bybit's list of restricted issuing countries for fiat service. That list covers three things by name — fiat deposit, fiat withdrawal and One-Click Buy — and the page carrying it was last updated in July 2026, so it is current policy. Uganda also shows up in two rail-specific sections on the same page, for SWIFT in zlotys and for Zen.com, neither of which a Ugandan would have used anyway.

The framing matters: the restriction attaches to the issuing country of the card or account, not to your residence. A Ugandan-issued card will not fund the account from Kampala or from anywhere else.

Bybit does publish how its peer-to-peer desk works — escrow holding the coins until the seller releases, fees charged to both makers and takers varying by currency and advertiser level, payment provider charges borne by the user on top, and the platform's right to demand extra verification such as a liveness check, photo ID, proof of payment or a bank statement mid-trade. What it does not publish anywhere static is the list of fiat currencies the desk supports, and we could not confirm from a primary source that the Ugandan shilling is one of them. We are not going to tell you it is. The honest instruction is to check the currency selector in the app before you plan around it. What we can say is that verification comes before trading rather than after, which our KYC guide sets out.

The circular, and the court case nobody mentions

On 29 April 2022 the Bank of Uganda issued circular NPSD 306, signed by the then acting director of the national payments system, prohibiting licensed payment service providers from facilitating the conversion of cryptocurrency to and from mobile money. The reasoning was blunt: such a conversion cannot happen without payment providers taking part, and the central bank had licensed nobody to sell or facilitate crypto trade. Within weeks Binance suspended mobile money for Ugandan clients and gave users until 30 May 2022 to pull their shillings out.

An advocate and crypto investor, Silver Kayondo, took the central bank to court over it. In Miscellaneous Cause No. 109 of 2022, decided on 24 April 2023, Justice Ssekaana Musa of the High Court upheld the circular as lawful and rational, holding that cryptocurrencies under the national payment system are not accepted as a general payment instrument. The judge leaned on section 4 of the National Payment Systems Act, 2020 while observing that the Act was not designed with cryptocurrencies in mind — which is the whole problem in one sentence. Crypto transactions sit outside the regulatory framework, and the practical consequence is that a Ugandan doing them has no consumer protection to fall back on. The finance ministry says the same thing in its own public statement: no cryptocurrency is legal tender, no organisation is licensed to facilitate trading, and holders get no government guarantee.

So the mobile money leg of any trade here is not merely inconvenient — it runs against an instruction the central bank gave payment providers and a court has upheld. Nobody has produced a documented case of an individual's wallet being frozen for P2P trading specifically, and we are not going to invent one, but the mechanism is on paper and the policy is live.

Where the policy is heading

It is not frozen in 2022. In November 2025 the Governor of the Bank of Uganda gave a keynote at the Kampala Blockchain Summit and described the restrictions in words worth quoting: not a prohibition but a pause, a deliberate effort to build understanding. He then laid out six pillars for a future regime — licensing with fit-and-proper standards, client asset protection with segregation and capital, anti-money-laundering compliance including the travel rule, cybersecurity and operational resilience, market integrity against wash trading and fraud, and transparency with real-time regulator access.

He was also specific about stablecoins, which is the relevant part for anyone here buying tether: they carry foreign exchange risk and create monetary substitution, where Ugandans hold value in a foreign-pegged digital instrument instead of the shilling. That is the central bank's stated concern, and it explains why the payments-side restriction has outlived four years of pressure to drop it. He pointed at Kenya's Virtual Asset Service Providers Act, in force since 4 November 2025, as the regional benchmark Uganda should match — and announced no date for Uganda to do so.

There is groundwork underneath. Virtual asset providers have been supervised by the Financial Intelligence Authority since December 2020, when an amendment to the Anti-Money Laundering Act made them accountable persons with registration, reporting, record-keeping and staff-training duties. A private member's bill to bring virtual assets under the Capital Markets Authority died in July 2023 when the finance ministry refused the certificate of financial implications, arguing among other things that the business is not legal and most people do not yet understand it. The Capital Markets Authority launched a sandbox in October 2025, but its published checklist limits eligibility to securities-related innovation, and the applications under review by April 2026 were fixed-income platforms, blockchain settlement and crowdfunding — not exchanges.

Mobile money economics, which is where the money actually leaks

MTN publishes its Ugandan tariffs, and they are the numbers that decide whether a trade is worth doing. The minimum transaction is 500 shillings, the maximum single transaction is 5 million, and the wallet cannot hold more than 20 million. Withdrawals are tiered: 12,500 shillings in agent fees on a withdrawal between 500,001 and 1,000,000, 15,000 between one and two million, 20,000 at the top of the range.

On top of that sits 0.5% excise duty on every cash withdrawal, deducted automatically — MTN says so in plain words on its own tariff page. On a 500,000 shilling withdrawal that is 2,500 shillings, a figure Parliament's finance committee used in its own record. In April 2026 MTN and Airtel went to that committee asking for the rate to be halved to 0.25% with a 5,000 shilling cap, arguing it would grow volumes and collections. The government rejected it. The 0.5% stands.

One more thing to put in the calendar: in June 2026 the Bank of Uganda circulated cash withdrawal caps taking effect on 1 January 2027 — 50 million shillings a day and 250 million a week for individuals, 500 million and 2.5 billion for businesses — framed as part of its push for a cash-lite economy. If your plan involves converting large P2P proceeds into cash, that ceiling arrives soon.

Tax: no regime, but an active unit

Uganda has no crypto-specific tax. Five tax amendment acts were assented to on 18 May 2026 and took effect on 1 July; none of them mentions virtual assets. A proposed provision on income from the disposal of a non-business asset did not survive the process, so no clean statutory handle for individual crypto disposals was created either.

That is not the same as nobody looking. The Revenue Authority has built a cyber intelligence unit, trained with the UK's HMRC, and its commissioner for tax investigations has said publicly that it is now equipped to track and recover funds, citing two cryptocurrency cases and roughly a billion shillings recovered. The same authority has been pulling third-party payment data and issuing notices about offshore holdings and foreign-sourced income. A Ugandan tax resident's balance on an offshore exchange is not automatically invisible, and the gap in the law is a gap the authority is openly asking the finance ministry to close.

What the risk actually looks like here

Uganda's crypto losses have historically come from schemes rather than from exchanges. Dunamiscoins Resources, out of Masaka, is the case everyone remembers: two directors charged with 65 counts of obtaining money by false pretence, over four thousand complaints, roughly 2.7 million dollars gone, and a promised return of 30% in 21 days that should have ended the conversation. Global Crypto Currencies took about 11.2 billion shillings from some 800 clients in 2020 and is the only crypto entry in Daily Monitor's catalogue of the country's eleven biggest Ponzi schemes. In 2026 the police opened enquiries into an online investment scheme trading on the name of a real listed miner, with investors unable to withdraw.

The broader numbers are not comforting either. The police annual crime report for 2025, launched in April 2026, put property losses to criminals at 2.5 trillion shillings against 1.4 trillion the year before, with 57 billion recovered — about 2.3%. Cyber fraud losses tracked by the criminal investigations directorate went from 600 million shillings in 2018 to 15.9 billion in 2020, and a single intrusion at a payment aggregator in October 2020 took roughly 11 billion, of which 41 million came back.

None of that is an argument that trading is doomed. It is an argument for where to be careful: the danger in Uganda has consistently been the promise of a return, not the mechanics of an order book.

A fair comparison

If you want a locally accountable counterparty, there is one verifiable difference worth knowing. Yellow Card operates a registered Ugandan entity, Yellow Card Financial Uganda Limited, registration number 80020002060059, registered with the Financial Intelligence Authority for financial-crime reporting. That is an anti-money-laundering registration rather than an operating licence from the central bank, and its Ugandan fees and limits are not published anywhere we could find, so we are not quoting any. But a named local entity with a registration number is an accountability anchor that an offshore exchange does not offer Ugandans.

The rest of the comparison is what it is: the rail under both options is mobile money, carrying MTN's published agent fees plus the 0.5% duty, under a circular that tells licensed providers not to facilitate crypto conversion at all.

For the wider picture of which countries are open and which are closed, see our availability guide; the desk mechanics are in the P2P guide, the exit route in the withdrawal guide, and the neighbouring markets are covered in Kenya and Nigeria.

Frequently asked questions

Can I fund a Bybit account with a Ugandan card or bank account?
No. Uganda appears on Bybit's list of restricted issuing countries for fiat service, which covers fiat deposit, fiat withdrawal and One-Click Buy, and that page was last revised in July 2026. The restriction is written against the country that issued the card or account, not against where you happen to be sitting.
Is holding crypto illegal in Uganda?
Holding is not what the rules address. What exists is a 2022 Bank of Uganda circular barring licensed payment providers from converting crypto to and from mobile money, upheld by the High Court in 2023, plus a finance ministry statement that no cryptocurrency is legal tender and nobody is licensed to facilitate trading. Individuals are left unprotected rather than prosecuted.
What is the mobile money withdrawal tax?
0.5% excise duty on cash withdrawals, deducted automatically as part of the transaction. On a 500,000 shilling withdrawal that is 2,500 shillings, on top of the operator's own agent fee. MTN and Airtel asked Parliament in April 2026 to halve it to 0.25% with a 5,000 cap; the government rejected the proposal.
Are there limits on how much I can move?
On MTN, a single transaction cannot exceed 5 million shillings and the wallet cannot hold more than 20 million. Separately, from 1 January 2027 the Bank of Uganda caps cash withdrawals at 50 million shillings a day for individuals and 500 million for businesses, as part of its cash-lite push.

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