Ukrainians trade more cryptocurrency per head than anyone else on earth. What they mostly do not do is trade it under Ukrainian law.

Ukraine ranks eighth in the world for the spread of crypto-assets and first once the ranking is adjusted for population, Oleksiy Semenyuk, head of the National Securities and Stock Market Commission (NSSMC), said, citing Chainalysis' Global Crypto Adoption Index. Transactions linked to the country came to roughly $206.3bn over the year, up about 52%, on the blockchain analysis firm's estimates.

The index weights on-chain value at centralised exchanges, retail transfers under $10,000, decentralised finance activity and institutional flows above $1mn, then adjusts for population and purchasing power. On the raw numbers India leads, followed by the US and Pakistan. Adjust for the size of the country and the top three are Ukraine, Moldova and Georgia - three of Europe's poorest states, and three where trust in banks is thinnest.

Semenyuk's argument is that the size of the market has settled the question of whether it is a fringe activity, and left a different question open.

"When a country ranks first in the world for crypto activity per capita, we can no longer talk about virtual assets as a niche phenomenon. The market exists, Ukrainians use it, businesses build products on it. The real question is different: where is this business legally located, where does it pay taxes, and how protected is the Ukrainian user? That is exactly what legislation should answer," he said.

That is the awkward part for Kyiv. Parliament approved a virtual assets law back in September 2021, and the finance ministry was still promising full legalisation by the first half of 2025. Five years on, the licensing and tax framework that would bring the activity onshore has not been finished, so a market that has grown to the size of Ukraine's entire annual GDP several times over sits largely outside the tax base of a state running record deficits.

The war is the reason the ranking moved, not an accident of it. Ukraine was already third in the world on the same index in 2022, when the invasion pushed households and volunteer fundraisers onto crypto rails at speed. What has changed since is scale and permanence: an emergency workaround has become ordinary financial behaviour for a country of roughly 6.5mn crypto holders, and the state has yet to write the rules for it.

Semenyuk also flagged tokenisation of real and financial assets - representing rights to physical or financial instruments digitally - as a separate line the NSSMC thinks could open new routes for raising capital. For a country whose domestic bond market is doing most of the heavy lifting on war financing, that is not an abstract interest.