The Regulatory Spectrum

Last Updated: June 2026

This document maps all 27 studied jurisdictions (including the regional aggregates Southeast Asia, Nordic Countries and Africa (Emerging)) onto a regulatory spectrum and analyzes the outcomes of each approach. All data points are sourced from the country regulation files and verified guidance sections in this repository. See also the Country Comparison Tables for side-by-side data and What Works & What Doesn't for the evidence-based assessment.

The Spectrum

BAN ◄──────────────────────────────────────────────────────────────► STATE MINING

China    India    Kazakhstan   Norway    EU/MiCA    US(TX)   Germany   Georgia   UAE    Paraguay   Bhutan
│        │        │            │         │          │        │         │         │      │          │
Full     Punitive Licensed     Partial   Disclosure Balanced No mining Zero tax  SEZ /  Hydro      Sovereign
ban      taxation (national)   restrict. -based     reg+grid specific  (0% ind.) commerc. surplus   monopoly
                                                    integr.            model     licence  +state    (DHI)
                                                                                          pilot

The five canonical stances across the matrix (N=27) distribute as follows: Ban (2), Punitive (1), Balanced/regulated (17), Permissive (6), State-operated (1). The detailed sections below place each jurisdiction under the structural model that best fits its matrix spectrum_position.

1. PROHIBITION (Complete Ban)

China

• Mechanism: 2021 NDRC industrial-restructuring catalogue ('eliminated' industry) + September 24, 2021 inter-agency notice ('illegal financial activity'). February 6, 2026 eight-agency joint notice ('Ban 2.0', PBoC + CSRC et al.) reaffirmed all crypto business activity illegal and extended controls to OTC trading, offshore yuan-pegged stablecoins, and RWA tokenization.
• Enforcement: Electricity / 'energy-signature' monitoring, AI-assisted transaction-pattern surveillance (incl. P2P bank transfers), blockchain forensics, banking compliance checks, criminal prosecution. Cross-border USDT laundering case 1.182 billion yuan ($166M) unveiled October 28, 2025.
• Outcome:
  • Global hashrate share: Dropped from a pre-ban high toward near-zero, then rebounded to an industry-reported ~14% (Hashrate Index/Luxor ~14%; CryptoQuant 15–20%, methodology-caveated geolocation/pool-IP estimates) — making China the world's third-largest mining hub despite the ban, concentrated in Xinjiang and Sichuan
  • Tax revenue from mining: $0
  • Regulatory oversight: Zero (underground operations invisible to authorities)
  • Investment: Capital fled to
    Kazakhstan, the
    US,
    Russia,
    Canada and others
  • Environmental: Underground miners use cheapest available power, not cleanest — undermining the stated environmental rationale
• Sources: Country file (
  China); China hashrate share is industry-reported (Hashrate Index/Luxor, CryptoQuant), methodology-caveated.

Venezuela (Grid Ban)

• Mechanism: May 2024 grid disconnection order, an administrative MPPEE measure (no enacted prohibiting statute), reaffirmed May 2026 while the national grid (SEN) remains in its contingency phase. Preceded by the SUNACRIP collapse/suspension (March 2023 corruption scandal).
• Enforcement: Militarized grid-protection raids are the operative mode. Maracay 2024 (2,300+ Antminer S19j Pro units); Operación Cazador, May 18 2026 (~4,000 ASIC machines seized, CICPC + military + Ministry of Electric Energy; facility drew 8–10 MW). Disconnecting mining recovered ~500 MW in critical regions (government-reported).
• Outcome: Regulatory vacuum. A well-designed licensing system (registration, national pool) was destroyed by institutional corruption; residential-node hashrate dropped ~65% since the 2024 disconnections (media/network-monitoring data, NOT VERIFIED vs CBECI/CCAF).
• Source: Country file (
  Venezuela).

Key Finding

Outright bans do not eliminate mining. They eliminate tax revenue, regulatory oversight, and legitimate economic activity while the mining continues underground with worse environmental outcomes. China's persistent ~14% underground hashrate — three full years after a comprehensive ban — is the clearest illustration.

2. DE FACTO PROHIBITION (Punitive Taxation)

India

• Mechanism: 30% flat tax under Section 115BBH (now Section 194 of the Income-tax Act, 2025) + 4% cess; mined tokens taxed at FMV on receipt with cost of acquisition deemed zero (no electricity, hardware, or infrastructure deduction); 1% TDS under Section 194S on transfers; no loss offset or carry-forward; 18% GST on exchange services.
• Outcome:
  • Industry-reported 60–87% drop in trading volume after the 2022 tax/TDS measures (total VDA trading, not mining-specific)
  • ~$42B traded offshore (Jul 2022–Jul 2023, Esya Centre); ~5 million users migrated to offshore platforms
  • Tax revenue: Minimal — the zero-cost-basis rule taxes revenue rather than profit, destroying the tax base
  • Unchanged through multiple budgets: Union Budget 2026-27 (Feb 1, 2026) retained the 30% VDA tax and 1% TDS and added Section 446 reporting penalties
  • A comprehensive crypto discussion paper was reportedly shelved again (at least the fifth deferral since July 2024)
• Source: Country file (
  India).

Key Finding

Punitive taxation is the worst of both worlds: it doesn't generate meaningful revenue (because it destroys the tax base) and it doesn't provide the clarity of an actual ban. India's zero-cost-basis rule — taxing revenue rather than profit — contradicts basic tax principles and is the single most cited cautionary example globally.

3. STRICT / NATIONAL LICENSING

Kazakhstan

• Mechanism: Law No. 231-VIII of 17 Nov 2025 (in force ~mid-Jan 2026) legalized mining and crypto circulation nationwide beyond the AIFC and repealed the former mandatory-domestic-sales quota (the old Art. 8(4) sales requirement). Mining is now a distinct, separately-classified activity; only Kazakhstan-registered individuals/legal entities may mine (localisation); unlicensed mining illegal. AIFC historically issued 84 licences / ~415,000 machines.
• Outcome:
  • Revenue: 20% CIT (legal entities) / 10–15% for individual entrepreneurs, plus a 2 tenge/kWh digital-mining fee (1 tenge/kWh renewables/off-grid; 25 tenge/kWh penalty for unmetered)
  • Grid: Restrictions/curtailment imposed during national electricity shortages
  • A new mining-pool tax-reporting form (Order No. 119, Feb 2026) requires pools to report distribution of mined assets to tax authorities (implementation ~Apr 2026)
  • The 2025 reform reclassified mining as distinct from digital-asset turnover, removing the sales-quota friction that drove activity underground under the prior AIFC-only regime
• Source: Country file (
  Kazakhstan). Note: the prior "95% outside the legal system" and "120+ shutdowns" figures are NOT VERIFIED against a primary source in the matrix.

Uzbekistan

• Mechanism: NAPP (National Agency of Perspective Projects, reporting to the President) issues mining permits; only legal entities may mine, individual mining is not permitted. Anonymous mining and anonymous crypto-assets prohibited; proceeds must be credited to Uzbek bank accounts and sold via licensed exchanges. Besqala Mining Valley (resolution No. 8146414, 17 Apr 2026) offers a 10-year tax holiday (to 1 Jan 2035; 1% monthly revenue fee instead).
• Outcome: First-ever private mining permit (NexaGrid) granted Jan 19, 2026. Renewable incentives (double tariffs for grid power, peak surcharges) push miners toward solar/wind. Strict AML and legal-entity-only rules raise barriers.
• Source: Country file (
  Uzbekistan).

Nigeria (within Africa Emerging)

• Mechanism: ISA 2025 (virtual assets = securities) + NTAA 2025. SEC license for mining-as-a-service with N500M (~$335K) minimum paid-up capital; total startup N1bn ($670K).
• Outcome: Only 2 companies held provisional licenses as of late 2024. The high barrier effectively excludes small operators and domestic participants.
• Source: Country file (Africa (Emerging)).

Key Finding

Overly strict licensing creates a compliance gap, but the mandate itself can be reformed. Kazakhstan's 2025 law shows a jurisdiction removing a friction point (the mandatory-sales quota) after iterative correction; Nigeria's $670K startup cost still effectively bans all but the largest foreign operators; Uzbekistan's legal-entity-only NAPP regime is restrictive but pairs licensing with a tax-holiday zone.

4. PARTIAL RESTRICTIONS

Nordic Countries (Norway / Sweden / Iceland)

• Mechanism (Norway): Data Centre Regulation (registration with Nkom, in force 1 Jan 2025). On 12 March 2026 the Storting asked the Government to return with a formal legislative proposal for a ban on crypto-mining data centres and rejected the proposed national licensing/concession regime — no ban is yet in force (it remains under government assessment).
• Mechanism (Sweden): Data-centre electricity-tax break removed (raised SEK 0.006 → SEK 0.36/kWh, ~6,000%, Jul 2023); crypto mining is not a VAT-deductible activity. Skatteverket audited 21 data-centre firms (2020–2023); 18 concealed mining to wrongly claim VAT deductions and were assessed SEK 990M ($91M) in VAT adjustments + surcharges.
• Mechanism (Iceland): No statute; Landsvirkjun (national utility) commercially refuses/curtails new energy-intensive load. ~120 MW mining power allocation (2024, industry-reported, exact current capacity NOT VERIFIED).
• Outcome: 68% of surveyed Swedish miners planned to relocate out by 2026 (2024 industry survey, methodology not independently verified). Environmental goals advanced; activity and tax base at risk. Norway's outcome is pending the requested ban bill.
• Source: Country file (Nordic Countries).

British Columbia,

Canada

• Mechanism: British Columbia to permanently ban new crypto-mining grid connections (Energy Statutes Amendment Act, announced Oct 20, 2025), escalating the earlier 18-month freeze; Quebec capacity allocation suspended since Jan 2023 with punitive Rate CB at 18.078¢/kWh (effective Apr 1, 2026) and a proposed average ~19.5¢/kWh pending Régie approval (H2 2026); Alberta remains the most open (deregulated market).
• Outcome: No new mining grid connections in BC; provincial patchwork ranges from Alberta (open) to BC (most restrictive). Federal capital-gains inclusion-rate increase to 66.67% was cancelled (Mar 21, 2025) — rate remains 50%.
• Source: Country file (
  Canada).

Key Finding

Partial restrictions are effective at controlling growth but may drive investment to jurisdictions with dirtier energy — undermining the environmental rationale. Sweden's experience (68% planning to leave; ~SEK 990M clawed back from miners disguising as data centres) shows heavy restrictions don't just control growth, they trigger exodus and enforcement litigation.

5. DISCLOSURE-BASED REGULATION

EU (MiCA)

• Mechanism: MiCA Regulation (EU) 2023/1114. PoW ban rejected by the ECON Committee (30–23 vote, March 2022). Instead: mandatory sustainability disclosures (Art. 19) — energy consumption, GHG emissions — with enhanced disclosure above 500,000 kWh/year. EU Taxonomy classification for mining remains undelivered (a March 2026 Taxonomy revision consultation did not add crypto mining). DAC8/CARF tax reporting from 1 Jan 2026. MiCA transitional period ends 1 July 2026 — a hard stop reconfirmed by ESMA (Apr 17, 2026) with wind-down/client-migration expectations.
• Outcome: Mining continues under transparency requirements. No ban-driven capital flight. ~199 CASPs authorized (12 Apr 2026), ~204 (22 May 2026) across ~23 EEA states (top: Germany ~53, Netherlands ~25). Environmental data collected for evidence-based future policy.
• Source: Country file (
  European Union).

Key Finding

"Transparency over prohibition" is emerging as the most sophisticated approach. MiCA gives regulators data for evidence-based decisions while preserving economic activity. The 30–23 vote rejecting a PoW ban reflected a deliberate choice for this approach — though the still-undelivered Taxonomy classification and Nordic restrictions create an increasingly challenging environment for energy-intensive mining within the bloc.

6. BALANCED REGULATION (Registration + Grid Integration)

Texas (US)

• Mechanism: SB 1929 / PURA: PUCT registration for >75 MW or ≥10% interruptible load. Classification as "large flexible loads" eligible for ERCOT demand response. Penalties up to $25,000 per violation per day. At the federal level, the CLARITY Act (H.R.3633) cleared Senate Banking 15-9 (May 14, 2026) framing mining/staking as "administrative or ministerial"; a Jan 23, 2025 EO affirms the right to mine; SEC Staff confirmed (Mar 2025) PoW mining is not a securities activity. FERC large-load interconnection rulemaking RM26-4-000 (>20 MW) is pending (action target end-June 2026).
• Outcome:
  • Miners participate in grid curtailment during stress events; mining converted from grid liability to grid reliability asset
  • US hashrate share is disputed (industry-reported): CCAF 2025 ~75.4% of surveyed activity (CCAF itself flags this as overstated); Hashrate Index ~37.5% on-chain — the country file asserts no single figure
  • Bottom-up energy ~70 TWh (~2.3% of 2023 US demand) per CRS report R48914 (Apr 2026)
  • No federal mandatory miner energy reporting (the 2024 EIA emergency survey was blocked)
• Source: Country file (
  United States).

Russia

• Mechanism: Legal since 1 November 2024 under Law No. 221-FZ; mining is a regulated economic activity with a mandatory national mining registry (FTS). Individuals may mine unregistered below 6,000 kWh/month, above which they must register as a business. Government Decree No. 556 requires IP-address data from miners and infrastructure operators (from 30 May 2026).
• Outcome:
  • Active mining farms grew ~44% in 2025 to ~196,900 (FTS AI energy-monitoring count; industry/state-reported, not independently audited) — among the world's largest jurisdictions
  • Registration gap: only ~30% of miners were registered mid-2025 (~70%, est. 140,000–200,000 farms, unregistered)
  • Seasonal Siberian bans: Irkutsk + Buryatia/Zabaikalsky Krai bans imposed 15 Nov 2025 expired 15 Mar 2026; a permanent five-year ban was discussed but unimposed, and Russia signaled no new regional bans in 2026 (citing flat 2025 electricity consumption)
  • Enforcement tightening: BitRiver founder Igor Runets under house arrest (31 Jan 2026) on tax-evasion charges; FTS bankruptcy petition against BitRiver-B
• Source: Country file (
  Russia).

Paraguay (Hydro-Surplus + Registration)

• Mechanism: Legal and actively supported but no comprehensive mining law (the 2022 bill was vetoed) — a piecemeal framework via resolutions/enforcement. Mandatory miner registration (Dec 2024) with MIC and SEPRELAD (miners are "Obligated Subjects"); up to 10 years' imprisonment for electricity-theft mining (Jul 2024 law). ANDE's GCIE tariff category formalizes mining while raising costs. DNIT Resolution 47/26 mandates wallet-level reporting for transactions >$5,000/year (covers mining).
• Outcome:
  • ~4.3% of global Bitcoin hashrate (~43 EH/s), Q2 2026 (industry-reported, Hashrate Index)
  • Over $1.5B sector investment, 60+ sites; ~391 MW contracted (projected 821 MW); ANDE ~$12M/month revenue (ANDE-reported)
  • 100% hydroelectric (Itaipu/Yacyretá), but tariffs rose ~$0.051 → ~$0.06/kWh, with an 8% network-loss charge, a 3-month deposit (~$4.5M/40MW), and a Dec 31 2027 contract cliff
  • Market bifurcating: Bitfarms completed its Latin America exit in Jan 2026 (final Paso Pe site sold to Sympatheia Power Fund for up to $30M); HIVE Digital scaling (~18.87 EH/s, 400 MW)
• Source: Country file (
  Paraguay).

Other balanced jurisdictions

The matrix classifies a further set of jurisdictions as balanced — lawful mining with no mining-specific prohibition, layered over general tax/AML/energy law and (often) emerging VASP frameworks:

• Argentina — lawful; energy-market deregulation (Decretos 450/451/452/2025) enables dollar-denominated bilateral PPAs; hashrate reported down ~42% YoY to ~1 EH/s (driven by a single Bitfarms/Keel ~40MW shutdown).
• Brazil — mining legal and unregulated as such; 0% import duty for high-efficiency miners (Resolução GECEX 861) but escalating electricity-theft enforcement (São Paulo May 2026: ~1,400 rigs seized).
• Japan — legal, no mining-specific restriction; tax reform staged from ~55% toward a ~20% flat separate-taxation regime (enacted Mar 31, 2026, effective Jan 1, 2028), improving competitiveness.
• Southeast Asia (aggregate) — mostly legal with no mining-specific regime, ranging from permissive/unaddressed (Thailand, Vietnam, South Korea) to enforcement-heavy on electricity theft (Malaysia ~RM700M/yr) and licensing freezes (Philippines BSP VASP moratorium from 1 Sep 2025).
• France — legal; tax certainty via BNC classification (rising disposal flat tax to 31.4%); a surplus-nuclear mining experiment was proposed (Jul 2025) but not enacted; EDF/Exaion majority stake sold to MARA (~$168M, Feb 2026).
• United Kingdom — mining freely permitted, clear HMRC treatment, but a regulatory gap as the FSMA 2026 regime omits mining; CARF from 1 Jan 2026; hostile banking access.
• Africa (Emerging) (aggregate) — frameworks span high-barrier licensing (Nigeria), general VASP regimes (Kenya VASP Act 2025), and a permissive-then-restricting energy posture (Ethiopia — GERD-powered low-cost mining at ~2.6% of global hashrate, now under an Aug 2025 EEP permit freeze and state capture via EIH).
• Saudi Arabia — functionally an ambiguity case: regulatory silence/gray zone (the only binding 2018 instrument addresses trading/dealing, not the act of mining), which deters legitimate investment while providing no enforcement mechanism.
• South Africa — mining legal and unregulated; general tax/AML/CARF context, with an in-development Eskom-Nersa surplus-power demand-response framework (Bitmach, up to 5 GW company-reported) but no enacted mining-specific energy policy.

Key Finding

Grid integration is the single most successful regulatory model studied. Texas demonstrates that mining, when properly integrated into the energy system, becomes a tool for grid management rather than a threat. This model requires an electricity market with real-time pricing and demand response — which is why South Africa's Eskom-Nersa proposal and Brazil's curtailed-renewable monetization are watched as the next test cases. Russia and Paraguay show the harder edge of "balanced": a registry and tariffs can coexist with ~70% unregistered activity or a looming contract cliff.

7. MINIMAL REGULATION

Germany

• Mechanism: No mining license, no specific restrictions; general business/tax law applies. 1-year holding exemption for capital gains (§23 EStG), €256/year tax-free threshold (Freigrenze). DAC8/CARF reporting from 1 Jan 2026. BMF letter of 6 March 2025 remains the governing tax guidance.
• Outcome: Mining permitted without friction. No reports of grid issues. Tax treatment clear and favorable for long-term holders; main weakness is the lack of a dedicated mining framework and trade-tax (Gewerbebetrieb) ambiguity.
• Source: Country file (
  Germany).

Australia

• Mechanism: No mining prohibitions; standard business tax treatment. 50% CGT discount after 12 months. GST registration if turnover ≥ A$75K. The Corporations Amendment (Digital Assets Framework) Act 2026 (Royal Assent 8 Apr 2026, commences 9 Apr 2027) creates AFSL-based licensing for platforms and custody, not miners; AML/CTF travel-rule (IVTS) obligations commenced 31 Mar 2026.
• Outcome: Mining operates under the general business framework without sector-specific issues.
• Source: Country file (
  Australia).

Key Finding

Minimal regulation works in countries with ample grid capacity and robust existing business/tax law. However, this approach provides no early-warning mechanism for grid strain and no mining-specific data for policymakers.

8. ZERO-TAX / TAX HAVEN

Georgia (Country)

• Mechanism: 0% individual crypto tax (foreign-source exemption), 0% VAT, Estonian-model corporate tax (0% while reinvested, 15% on distribution). Individual miners and mining-pool participants explicitly exempt from VASP registration; tax residency = 183 days.
• Outcome: Strong investment attraction; near-zero government revenue from the sector. Mining electricity use tripled to ~752M kWh in 2025 (~5% of national consumption) — regulator-reported (GNERC) — straining the grid (Mestia ~133M kWh, ~13× a comparable municipality). This triggered the June 2026 Svaneti/Mestia crackdown on illegal (unmetered/grid-stealing) mining (smart meters + free electricity up to a threshold; est. GEL 20–25M/yr losses) — enforcement against illegal use, not emissions.
• Source: Country file (
  Georgia).

Singapore

• Mechanism: 0% capital gains tax. Mining as a hobby = untaxed; business mining = standard income tax. No mining-specific regulation; pure solo mining is unlicensed but DPT-service activity triggers PSA/FSMA licensing.
• Outcome: Favorable for holding; negligible actual mining — ~S$0.27/kWh electricity (3–5× major hubs), land scarcity, tropical climate, and a S$45/tCO2e carbon tax make it structurally unsuitable.
• Source: Country file (
  Singapore).

Key Finding

Zero-tax attracts investment but generates no fiscal revenue from the sector. Sustainable only if the country has broader strategic objectives (tech-hub positioning, financial-services diversification) — and, as Georgia shows, a 0% rate can still produce grid strain and illegal-use enforcement even without a tax-revenue motive.

9. SPECIAL ECONOMIC ZONES / COMMERCIAL LICENSING

UAE (VARA / Free Zones)

• Mechanism: Mining is not a regulated financial service but a licensable commercial activity (mainland LLC or free-zone, e.g. DMCC Crypto Centre). VARA (Dubai); the federal Capital Markets Authority (CMA, replaced SCA 1 Jan 2026); ADGM/FSRA. 9% corporate tax (or 0% in free zones with substance); 5% VAT on mining income. VARA fully implemented the Travel Rule for all VASPs (Feb 2026). Q2 2026: FSRA (ADGM) clarified crypto mining is not a regulated financial service but a licensable commercial activity.
• Outcome: Strong investment attraction; purpose-built crypto regulation, fragmented across emirates. MARA/Zero Two JV planned 250 MW (Abu Dhabi); MARA Abu Dhabi ~1.2 EH/s energized compute (industry-reported).
• Source: Country file (
  UAE).

Bhutan (GMC — Private Tier)

• Mechanism: RMA April 30, 2025 notice: private mining/exchanges exclusively permitted within Gelephu Mindfulness City (GMC). On-ramping through domestic banks restricted; crypto not legal tender.
• Outcome: Controlled private participation. State (DHI) operations continue outside the GMC framework (see §10). The two-tier system raises fairness concerns.
• Source: Country file (
  Bhutan).

Key Finding

SEZ / commercial-licensing models concentrate activity in areas with appropriate infrastructure and oversight. They work best when the zone has clear advantages (tax, regulatory clarity, infrastructure) and the rest of the country has a clear framework. The UAE's parallel emirate + federal CMA structure shows both the appeal (multiple competing zones) and the cost (fragmentation) of this model.

10. STATE-OPERATED MINING

Bhutan (Sovereign Model)

• Mechanism: Druk Holding & Investments (DHI) sovereign mining; 600 MW total mining capacity (more energy than the rest of the nation combined) across facilities at Gedu (100 MW) and Jigmeling/Sarpang (500 MW). 100% hydroelectric. Seasonal model (monsoon surplus → mining; winter shutdown during scarcity). Bitdeer Technologies (NASDAQ: BTDR) is the primary mining partner (Phase 2 up to $500M).
• Outcome:
  • Over 13,000 BTC mined since 2019 (industry/operator-reported); revenue funds government salaries
  • Strategy shift from accumulation to treasury management: holdings fell from the Oct-2024 stack — ~5,400 BTC by Mar 10, 2026 (58% below peak; ~$42.5M of 2026 outflows), then 3,954 BTC ($280.6M) by Apr 11, 2026 (~70% of the stack sold over 18 months), with no mining inflow >$100K in over a year — mining may be halted (industry-reported, Arkham/CoinDesk). DHI's CEO disputed the sale narrative (May 16, 2026)
  • July 2025: Bhutan sold 512.84 BTC for $59.47M over four days
  • December 2025 Bitcoin Development Pledge: up to 10,000 BTC (~$1B) for GMC; TER sovereign gold-backed token launched on Solana
  • India hydropower-export revenue fell (27,523M in 2020 → 16,675M in 2023) as power was diverted to mining
• Source: Country file (
  Bhutan).

Paraguay (State Pilot)

• Mechanism: ANDE-Morphware MOU (signed Mar 4, 2026) for a state-run Bitcoin-mining pilot using ~1,500 of ~30,000 seized rigs, powered by surplus Itaipu hydroelectric energy. See Economic Outcomes Analysis for revenue projections.
• Outcome: Pilot phase. Revenue potential unclear. A novel approach: turning seized illegal equipment into state revenue, layered on top of Paraguay's larger private hydro-mining sector (§6).
• Source: Country file (
  Paraguay).

Key Finding

Sovereign mining can generate significant revenue for countries with cheap surplus renewable energy. However, Bhutan's 2025–2026 pivot — selling ~70% of its stack over 18 months, with mining inflows apparently halted — shows the model's concentration and treasury-management risk in sharp relief: a sovereign accumulator can become a sovereign seller quickly, and the World Bank flagged proximity-to-hydro-infrastructure and macro concentration concerns in its Bhutan Development Update.

Comparative Outcomes Matrix

Distribution Across the Spectrum (N=27)

Using the matrix's five canonical stances:

The mass of the distribution sits in the balanced/regulated band (17 of 27), confirming that most jurisdictions converge on lawful-but-conditioned mining rather than either extreme. Only 2 of 27 maintain outright bans, and only 1 of 27 (India) relies on de-facto-prohibition-by-taxation. At the permissive end, 6 of 27 impose no mining-specific burden, and a single state (

Bhutan) operates a sovereign program. El Salvador sits at the permissive end (Bitcoin-friendly, 0% tax DASP regime, pioneer of government geothermal mining) but is constrained by an IMF non-accumulation condition — and its Bitcoin legal-tender status was repealed (Jan 29, 2025) as an IMF EFF condition, so it is no longer a legal-tender case.

The Optimal Zone

Based on the evidence, the optimal regulatory zone lies between positions 5 and 6 on the spectrum — disclosure-based regulation with grid integration. This combines:

• MiCA's transparency approach (data for evidence-based policy without prohibiting activity)
• Texas's demand response model (converting miners from grid threat to grid asset)
• A proportionate tax framework (moderate rates with full deductions — unlike India; with revenue unlike Georgia)
• Tiered licensing (scale-appropriate requirements — and Kazakhstan's 2025 repeal of its mandatory-sales quota shows even a strict regime can be corrected toward proportionality)

Countries with surplus renewable energy (Profile A in the Guidance) may also benefit from adding elements of the sovereign mining model (

Bhutan/

Paraguay), with strict treasury risk management — Bhutan's 2025–2026 pivot from accumulator to net seller is the cautionary case. South Africa's Eskom-Nersa demand-response proposal and Brazil's curtailed-renewable monetization are the jurisdictions to watch as the grid-integration model spreads. See the Implementation Guide for a step-by-step roadmap.

Verification Notes

• Source of truth: All 27 jurisdictions and their placements mirror .claude/crypto-mining-fact-matrix.json (canonical per-jurisdiction spectrum_position fields). This is a refresh synthesis — no new jurisdictions were added this run and no facts were introduced beyond the matrix or the prior version of this file.
• N=27 comprises 24 single jurisdictions plus the three regional aggregates Southeast Asia, Nordic Countries, and Africa (Emerging).
• Industry-reported figures are flagged as such. Hashrate/energy figures (China ~14%, Paraguay ~4.3%, Ethiopia ~2.6%, US share-disputed, Russia ~196,900 farms, Georgia ~752M kWh, Bhutan 13,000+ BTC, Iceland ~120 MW) carry their methodology source (Hashrate Index/Luxor, CryptoQuant, CCAF/CBECI, FTS AI monitoring, GNERC, Arkham) and are not treated as audited primary statistics.
• "NOT VERIFIED" preserved honestly: the prior Kazakhstan "95% outside the legal system / 120+ shutdowns" figures and Venezuela's residential-hashrate drop are not asserted as verified primary facts.
• Corrections applied this refresh (vs. the March 2026 version): China hashrate share standardized to industry-reported ~14% (third-largest hub) with the Feb 6, 2026 eight-agency notice and the Nov 2025 PBoC reaffirmation; Kazakhstan's mandatory-domestic-sales quota recorded as repealed by Law No. 231-VIII (Nov 2025, nationwide legalisation); Russia registered-miner counts (~196,900 farms, ~30% registered) and seasonal Siberian bans (15 Nov 2025–15 Mar 2026, no new 2026 bans) added; El Salvador's Bitcoin legal-tender status recorded as repealed (Jan 29, 2025); Paraguay's Bitfarms exit (Jan 2026) and the ANDE-Morphware/Yguazú-region seized-rig state pilot reflected.
• Tags: uses the canonical type/analysis tag only. Region mapping to the canonical 5-region set (americas, asia-pacific, europe, middle-east-africa, international-frameworks) is honored via the wikilink path prefixes.
• Wikilinks: all cross-domain links use the deep-research/ path prefix and correct file slugs (note Georgia is georgia-country); no relative Markdown links.