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Introduction Digital currencies have emerged as a significant financial innovation, raising complex legal, economic, and regulatory challenges across jurisdictions. While some countries have established comprehensive regulatory frameworks, others, including Jordan, continue to face legal uncertainty due to the absence of clear legislation. This study examines the legal status and regulatory approaches to digital currencies, with particular reference to the German and United Arab Emirates (UAE) models, and evaluates their applicability within the Jordanian legal context. Methods The study adopts a descriptive-analytical and comparative legal methodology. It analyzes legislative texts, institutional reports, and academic literature to assess how different jurisdictions regulate digital currencies. The research focuses on legal classification, regulatory oversight, licensing mechanisms, and compliance requirements, and compares these approaches to identify suitable regulatory solutions for Jordan. Results The findings reveal significant variation in regulatory approaches worldwide. Some jurisdictions recognize digital currencies as financial instruments subject to licensing and regulatory supervision, while others impose restrictions or maintain unclear legal positions. In Jordan, the absence of a comprehensive legal framework has resulted in regulatory gaps, legal uncertainty, and limited investor protection. By contrast, the German model provides legal certainty through classification and licensing, while the UAE model offers effective institutional supervision and regulatory oversight. Discussion The study concludes that digital currencies can be legally integrated into national financial systems when supported by a clear and balanced regulatory framework. Based on the comparative analysis, the research proposes the adoption of a hybrid regulatory model in Jordan, combining legal classification, licensing requirements, and institutional supervision. Such a framework would enhance legal certainty, strengthen investor protection, reduce financial risks, and support sustainable financial and economic development while maintaining regulatory control.