Crypto and virtual asset service providers (PSAV/VASP) in Argentina

Key rules

Unless stated otherwise, "art." below refers to the CNV Rules (Normas, N.T. 2013 and amendments), Title XIV, Chapter III, in the text substituted by RG 1172/2026 art. 2.

1. The legal definitions

Virtual asset. "A digital representation of value that can be traded and/or transferred digitally and used for payments or investments." Legal tender in Argentina and currencies issued by other countries (fiat) are never virtual assets (Law 25.246 art. 4 bis, added by Law 27.739 art. 4).

PSAV. Any individual or legal person that, as a business, carries out one or more of these activities for or on behalf of another person (Law 25.246 art. 4 bis):

1. exchange between virtual assets and fiat;
2. exchange between one or more forms of virtual assets;
3. transfer of virtual assets;
4. custody and/or administration of virtual assets or of instruments that allow control over them;
5. participation in and provision of financial services related to an issuer's offer and/or sale of a virtual asset.

The CNV categories copy this list (art. 9): Category 1 fiat to crypto exchange; Category 2 crypto to crypto exchange; Category 3 transfer; Category 4 custody or administration, excluding services where the user keeps exclusive control of the assets; Category 5 services to issuers for initial offers or public fundraising through platforms or apps (the mere act of issuing a token is not covered). Individuals may only operate Categories 1 and 2 (art. 9, last paragraph).

2. Who is outside the definition

Art. 2 lists activities that are not PSAV activity:

• individuals or companies that exchange crypto against fiat or against other crypto for their own account, whatever the amount (art. 2(i));
• merchants and service providers that receive or deliver crypto as payment for their goods or services, whatever the amount (art. 2(ii));
• decentralised protocols, provided no individual or legal person exercising control or sufficient influence over their operation provides PSAV services (art. 2(iii)). RG 1172/2026 tightened this: RG 1058/2025 only required that there be no "identifiable provider";
• providers of self custody wallet software or hardware, where the user keeps control of the assets and the means of access, and the provider has no power of custody, administration or disposal (art. 2(iv));
• a foreign parent that holds shares, directly or through a group company, in an Argentine company registered as a PSAV, provided the parent has no direct contractual relationship with clients in Argentina and none of the points of contact in art. 4 applies to it (art. 2, last paragraph).

Under the tokenisation regime, entities that only supply the technology to create digital representations of securities need not register as PSAVs, although anyone performing a PSAV activity must (Title XXII, art. 14, as replaced by RG 1081/2025).

3. Who must register

• Argentine resident individuals and Argentine companies that carry out any PSAV activity must register before starting (art. 1, first paragraph).
• Individuals register only when their aggregate PSAV activity exceeds UVA 35,000 per calendar month, valued at the UVA of the last day of each month (art. 1, third paragraph). RG 1172/2026 now requires an independent accountant's certificate, legalised by the professional council, proving that the individual has acted as a business for third parties above that amount (art. 7(a)(10)). Note the change in wording: under RG 994/2024 and RG 1058/2025 individuals below the threshold were exempt; under RG 1172/2026 registration "proceeds only" above the threshold. In practice an individual below UVA 35,000 a month neither must nor can register (unconfirmed).
• Foreign companies that directly carry out PSAV activity in Argentina under any point of contact in art. 4 must register before operating, and can only do so through an Argentine company in which they hold shares (Law 19.550 art. 123) or a branch or permanent representation registered under Law 19.550 art. 118 (art. 1, second paragraph).
• Anyone not registered must abstain from PSAV activity in Argentina; breaches are sanctioned under Law 27.739 art. 37 (art. 3).

4. Points of contact for foreign providers

A foreign company is deemed to operate in Argentina, and must register, if any one of the following applies (art. 4):

1. it uses any ".ar" domain for its activities;
2. it has commercial agreements with third parties, subsidiaries or affiliates that let it receive funds locally from Argentine residents (on/off ramp services);
3. it shows clear targeting of Argentine residents;
4. it runs advertising clearly aimed at Argentine residents, except where the client contacts the foreign company on the client's exclusive initiative (reverse solicitation);
5. its Argentine business volume exceeds 20% of its total volume in the activities requiring registration.

"Clear targeting" is not defined. Spanish language interfaces, peso pricing, local payment methods and Argentine influencer marketing are the obvious risk factors, but the list is the regulator's to apply.

Sponsorship of events. An unregistered foreign PSAV may sponsor international events in Argentina, and have a stand, only if it warns participants that it is not registered and cannot serve Argentine residents, and refrains from any PSAV activity, including calls to invest in crypto (art. 45).

Enforcement against unregistered providers. Where it suspects an unlawful act by an unregistered PSAV, the CNV may ask the specialised prosecutor or the competent court to block the website URL and social media accounts (art. 41, last paragraph).

5. Excluded and incompatible persons

• CNV registered markets, clearing houses and registered agents (brokers, ALyCs and others) cannot act as PSAVs. A PSAV may integrate its platform with their infrastructure where no rule prohibits it (art. 5(a)). Persons under a specific regulation that does not allow PSAV activity are also excluded (art. 5(b)), which in practice catches banks and wallets subject to the BCRA prohibitions described in section 13 below.
• Companies domiciled in non cooperative jurisdictions for tax transparency (Decree 862/2019 Annex art. 24) and considered by FATF as high risk jurisdictions subject to a call for action cannot register (art. 7, after item (b)(20)). The text uses "and"; it is not clear whether the CNV reads it cumulatively (unconfirmed).
• Directors, statutory auditors, the regulatory compliance officer and local representatives cannot be: persons barred from trading; persons convicted of the crimes in Criminal Code arts. 176 to 180 and 303 to 313, or of crimes for profit or against public faith, or with disqualification penalties, until 10 years after serving the sentence; persons convicted of money laundering, terrorist financing or proliferation financing; persons on UN Security Council terrorist lists; bankrupts until 5 years after rehabilitation; persons disqualified by the CNV under Law 26.831 art. 132(c) (art. 8). The same incompatibilities bar shareholders (art. 7(b)(11)). Supervening incompatibility must be reported immediately and the person must stop acting (art. 8, last paragraph).
• The general CNV rules on fitness, integrity and solvency (Title XI, Section IV) apply to PSAVs, except item 1 of art. 11 of that Section, which does not apply "at this stage" (Title XVIII, Chapter X, art. 4, as replaced by RG 1139/2026) (unconfirmed).

6. Corporate form and capital

• Local companies must be an SA or SRL (art. 7(b)). The corporate purpose must expressly provide for PSAV activity; generic or ambiguous wording that could be read as implicit is not accepted. For a branch or representation of a foreign company, the parent's purpose may cover PSAV activity expressly or implicitly if consistent with its home law (art. 7(b)(3)). The registered, ordered text of the by laws must be published on the AIF and kept current (same item).
• The institutional website must use a ".ar" domain (art. 7(b)(9)).
• Minimum net equity (patrimonio neto mínimo, PNM) (art. 10):

For Categories 1 to 3 the test is volume transacted, for Category 4 volume held in custody, in each case in the last 12 months. A PSAV with several categories meets only the highest requirement (art. 10). Whether a newly formed applicant with no history qualifies for the 50% reduction at registration is not addressed (unconfirmed). * Quality of the equity (art. 10(i) to (iv), added by RG 1172/2026 from former interpretive criteria): share capital fully paid in at registration and at all times; capital registered with the Public Registry; irrevocable capital contributions capitalised and registered before applying; contributions received while registered must be capitalised within 6 months of acceptance by the board. * Branches need assigned capital in Argentina at least equal to the PNM, fully paid and shown in the branch financial statements. A permanent representation that cannot be assigned capital must earmark Argentine assets held by the representation (not the representative) through a guarantee trust, worth at all times at least the PNM (art. 10, last paragraphs). * Equity is measured in US dollars at the BCRA Com. "A" 3500 rate (art. 7(a)(12) and (b)(18)). If annual statements show a shortfall, the PSAV reports a material fact (hecho relevante, HR) and within 10 business days files its recapitalisation plan (art. 11).

7. Governance and key persons

• Regulatory compliance and internal control officer (responsable de cumplimiento regulatorio y control interno): appointed by the board after assessing background; may be a director; reports to the board; controls compliance with the Chapter and the Code of Conduct; checks that complaints are handled; files an annual report within 70 calendar days after year end (art. 22). The board must give the officer resources and access to information (same article).
• Public relations officer (responsable de relaciones con el público) with a direct contact channel published on the website and app (art. 30).
• A board minute declaring that the company has its own adequate administrative organisation (art. 7(b)(19)).
• Changes in directors and statutory auditors must be updated within 10 business days (art. 7(b)(12)); other AIF data within 5 days of the change (art. 40, last paragraph).
• The UIF compliance officer (with a substitute) is a separate appointment under UIF Res. 49/2024 art. 11 (see section 12).

8. Systems, cybersecurity and information security

• Procedure manuals for order handling and for custody, administration and transfer; order and trade logs must record date, hour, minute and second, quantity, asset, internal ID or blockchain TXID and client ID (art. 12).
• IT expert report (informe de idóneo informático) filed on the AIF on data integrity, system security, backups and contingency (art. 13). Not public.
• Cybersecurity under a risk based approach covering governance, identification of critical processes (order systems, risk systems, custody of crypto and fiat, information dissemination, client data), protection (client data, interconnections, insider threats, training), detection (continuous monitoring, multi level access controls) and response and recovery (art. 14).
• Information security policy approved by the board, describing wallet categories (vault, transactional, DeFi interaction, liquidity provision), wallet types per category, transaction security protocols, and how access to private keys is granted and revoked (art. 15).
• Annual systems audit signed by an IT expert, Argentine or foreign, covering operation, security, continuity, data integrity, backups and proof of reserves; where smart contracts are used, their security and operation (art. 21, the smart contract sentence is new in RG 1172/2026). The board must transcribe the conclusions and its own response into the minute book (same article). Filed within 70 calendar days after year end (art. 40(c)(1)).
• Confidentiality: no filing may reveal information that exposes the security of the assets or links critical roles to identifiable persons (art. 23).

9. Custody, segregation and use of client assets

These rules apply to Category 4 PSAVs (arts. 16 to 18) and, for fiat and the prohibition on own use, to all PSAVs that hold client funds (arts. 19 and 20).

• Custody architecture filing: own or third party custody (identifying the third party), blockchains used and operational wallet addresses, wallet type (cold, warm, hot), support (software or hardware), key scheme (multisig, MPC, other) (art. 16). Kept updated on the AIF, not public.
• Proof of reserves must be published on the website or app (art. 16, last paragraph).
• Segregation of client crypto: clear, individualised and current separation in internal records, in operational accounts at other PSAVs and in on chain wallets. A PSAV may keep an additional margin of its own crypto in client wallets for liquidity if clearly identified. Client crypto is never an asset of the PSAV and never counts toward its equity; it is booked in memorandum accounts. The deposit regime must be set out in the client contract. Where custody is delegated, the PSAV must use a wallet at the third party used exclusively for client assets (art. 17).
• Key management: different levels of human verification by transaction thresholds, plus one or more of: cold storage, geographically distributed key shards, multisignature with roles, withdrawal whitelists, or an equivalent mechanism (art. 18).
• Client fiat: clearly separated from own funds in internal records; may be held in an account in the PSAV's name for the benefit of clients at a BCRA authorised bank, at a foreign bank meeting standards equivalent to Basel III, or through a BCRA registered payment service provider where BCRA rules do not prohibit it (art. 19).
• No own use: a PSAV may not use client crypto or funds for its own account and may only move them on express client instruction (art. 20).
• Insolvency. The CNV recitals to RG 1069/2025 and RG 1081/2025 take the position that assets held for third parties fall under Law 24.522 art. 138 (restitution of assets delivered under a title not meant to transfer ownership). That is a regulator's view in recitals, not a statutory rule for PSAV insolvency; no court decision applying it to a PSAV is in the sources (unconfirmed).

10. Conduct, marketing and products

• Conduct duties (art. 25): act honestly and in clients' best interest; plain language; no misleading practices; manage conflicts; no front running of client orders with own trades in the same asset; publish fees and do not charge abusive commissions; avoid conflicting dual roles of staff; warn clients of risks; email customer service; KYC and source of funds checks; and no services designed to obscure the origin or destination of transactions (art. 25(q)), which reaches mixing type services.
• Code of Conduct published on the website or app (art. 26).
• Market abuse: measures against disruption, misleading signals, artificial prices, false information and insider dealing on the platform (art. 27).
• Operational due diligence: fast and accurate settlement, an auditable electronic ledger of every transaction, monitoring with recovery of damaged or deleted data, and power to suspend or close accounts with reasons given (art. 28).
• Risk management policies (art. 29); complaints procedure and complaints email reported on the AIF (art. 31); transparent fee schedule published prominently (art. 32).
• Advertising may not mislead; the CNV may order changes or suspension. People who promote a PSAV must not promote capital markets activity and vice versa (art. 33). Only registered PSAVs may use names or advertising suggesting PSAV status (art. 34).
• Mandatory legend: "Inscripto bajo el N°…. en el Registro de PSAV de la CNV (República Argentina)" on the website, app and social media (art. 6). The 2024 disclaimer that registration "does not imply a licence or supervision" by the CNV (RG 994/2024, original art. 5) is gone.
• Risk disclosures: a list of twelve warnings to be published, including volatility, total loss, irreversibility, no legal tender status, no CNV review of white papers, cyber risk and key loss (art. 37).
• Token listing: only assets with a white paper or equivalent information on the issuer and project, linked from the platform in Spanish or English. Assets launched less than 90 days earlier may be offered only in a separate section with a specific warning. A PSAV may not offer or intermediate a public offering of tokens that are securities without CNV authorisation; substance over form applies, and tokenised securities follow Title XXII (art. 38).
• Referral agreements: a PSAV may refer clients to and receive referrals from CNV agents, and be referred by third parties including its foreign parent; agreements are reported on the AIF within 5 days (art. 35). RG 1048/2025 lets trading agents (AN) and global investment advisers (AAGI) refer clients to PSAVs under a prior agreement.
• Outsourcing: allowed, including to the parent or group abroad, but the PSAV stays fully responsible; contracts must oblige the provider to supply information to the CNV and other authorities; foreign providers that perform PSAV activities must be regulated in a cooperative jurisdiction and supervised for AML under FATF standards; reported on the AIF within 5 days; termination is a material fact (art. 36).
• Record keeping: accounting records, KYC files, client communications and transaction evidence for 10 years (art. 39). The UIF imposes the same 10 year period (UIF Res. 49/2024 art. 17(a)).

11. CNV reporting

The monthly report uses three blocks: a cover form, and two plain text files ("operated" and "custody") with a defined layout and examples (Annex I, sections II to IV). A PSAV that has not started operating reports that fact as a material fact on form PSAV_015 and starts monthly filings once it begins (Annex I, section I).

12. The UIF layer (anti money laundering)

PSAVs are reporting parties under Law 25.246 art. 20(13). Their rulebook is UIF Res. 49/2024 (BO 25 March 2024, in force the next day, art. 41). The full framework is on the AML and KYC page; the PSAV specific points are:

• The UIF resolution applies to PSAVs registered with the CNV (art. 2(v)); PSAVs must register as reporting parties with the UIF under UIF Res. 50/2011 (art. 42, transitional, gave existing PSAVs 30 days from CNV registration).
• Risk based system: self assessment report updated annually and filed before 30 April each year, with a risk tolerance statement (arts. 5 and 6); board responsibilities (art. 10); compliance officer and substitute, registered with the UIF, with a domicile in Argentina (art. 11); prevention committee (art. 14); training (art. 18).
• Independent external review with an annual report filed within 120 calendar days after the self assessment deadline (art. 19(a)), that is, by about 28 August [computed: 30 April plus 120 days].
• KYC: identification and verification rules (arts. 21 to 25), risk rating (art. 26), simplified, medium and enhanced due diligence (arts. 27 to 29); foreign PEPs and clients linked to FATF call for action jurisdictions are automatically high risk (art. 29). The resolution defines arbitrageurs (arbitrajistas): clients who habitually exchange across PSAVs or peer to peer (art. 2(b)) (unconfirmed).
• Blockchain analytics: the resolution defines "traceability tools" (art. 2(n)) and self custodied wallets (art. 2(e)) (unconfirmed).
• Unusual operations register (art. 35) and suspicious transaction reports within 24 hours of concluding the operation is suspicious, and in any case within 90 calendar days of the operation for money laundering; within 24 hours of the operation for terrorist or proliferation financing (art. 36).
• Travel rule: identify originator and beneficiary of transfers between PSAVs per FATF standards "in the manner the UIF establishes" (art. 37) (unconfirmed).
• Cash deposits of 6 SMVM or more: identify the depositor and whether acting for a third party (art. 38).
• Systematic reports through the UIF website: (a) all crypto operations of 6 SMVM or more, and (b) client additions and terminations with PEP status, both between the 1st and 15th of each month for the previous month; (c) an annual systematic report between 2 January and 15 March (art. 39).
• Penalties: Law 25.246 art. 24: warning; published warning; fine of 1 to 10 times the value of the operation for missing or late suspicious transaction reports; 15 to 2,500 modules for other breaches, per breach and cumulative; up to 5 years' disqualification of the compliance officer; directors jointly liable. The module was raised to ARS 54,140 by UIF Res. 95/2025 (BO 23 June 2025) (Law 25.246 art. 24, Infoleg note) (unconfirmed). That gives ARS 812,100 (US$ 519.28) to ARS 135,350,000 (US$ 86,546.45) per breach. Actions prescribe in 5 years (art. 24 bis).

With the minimum wage at ARS 391,200 from 1 October 2026 and ARS 398,800 from 1 November 2026 (CNEPYSMVM Res. 4/2026 arts. 1(b) and (c)), 6 SMVM is ARS 2,347,200 (US$ 1,500.86) in October 2026 and ARS 2,392,800 (US$ 1,530.02) in November 2026. UIF Res. 49/2024 art. 2(u) uses the SMVM "at the time of the operation".

13. Banks, wallets and exchange controls

• Banks: "financial entities may not carry out or facilitate to their clients operations with digital assets, including crypto assets and assets whose returns depend on their variations, that are not authorised by a competent national regulatory authority or by the BCRA" (BCRA Com. "A" 7506, 5 May 2022, inserted in Servicios complementarios de la actividad financiera y actividades permitidas, point 1.1). Whether the current ordered text keeps this wording could not be checked because the BCRA ordered text URL returned an error page on 26 October 2026 (unconfirmed). Note the open question: registration of a PSAV with the CNV is not an "authorisation" of any digital asset, so the rule still bars bank crypto trading for clients; whether a CNV authorised tokenised security under Title XXII counts as "authorised" is untested (unconfirmed).
• Wallets (PSPCP): the same prohibition applies to payment service providers offering payment accounts (BCRA, Proveedores de servicios de pago, point 4.6, version under Com. "A" 8454, ordered text at 2 October 2026). See Banking and payments.
• Client money at banks: nothing in these rules prevents a registered PSAV from having its own bank account for client funds, and RG 1172/2026 art. 19 expressly contemplates it. Bank onboarding remains a risk based decision of each bank (unconfirmed).
• Exchange controls: in the BCRA "Exterior y Cambios" rules, crypto assets count as liquid foreign assets for the US$ 100,000 test in the access declarations (point 3.16.2.1), and a client accessing the official FX market must declare that it has not delivered pesos or local assets in exchange for crypto assets, among other assets, in the previous 90 days and will not for the next 90 days (points 3.16.3.1(vii) and 3.16.3.2). Card issuers need BCRA prior approval to pay abroad for card purchases of crypto (point 4.1.4.5) (BCRA Com. "A" 8481, ordered text at 14 September 2026). See Exchange controls for who is still subject to these declarations.
• Capital markets on ramps: under RG 1108/2026 and RG 1139/2026, CNV regulated agents may receive assets from individuals in the simplified income tax return regime by transfer of crypto from a CNV registered PSAV account held by the client (Title XI, Section VI, arts. 16(3) and 17(4), added by RG 1108/2026).

14. Tokenised securities sandbox

RG 1069/2025 (BO 13 June 2025) created Title XXII, a regulatory sandbox for digital representations of securities, rewritten by RG 1081/2025 (BO 21 August 2025) and amended by RG 1087/2025 and RG 1150/2026. Only PSAVs registered in all five categories may participate (Title XXII, art. 14). The RG 1081/2025 recitals state the sandbox runs until 21 August 2026 inclusive, after which no new digital representations may be generated unless the CNV extends it (unconfirmed). Up to five PSAVs may be designated per issue under RG 1150/2026 (unconfirmed). This page does not cover tokenisation in depth.

15. Tax

Income tax, individuals.

• Gains from the sale of digital currencies are taxable for individuals regardless of habituality (ITL art. 2, point 4). "Sale" includes exchange and swap (ITL art. 3), so a crypto to crypto swap is a disposal (unconfirmed).
• Source: gains from holding and selling digital currencies are Argentine source when the issuer is domiciled in Argentina (ITL art. 7). The law does not say what happens when there is no issuer (bitcoin) or the issuer is abroad (USDT, USDC). Practitioners read the rule either way; there is no regulation in the sources resolving it (unconfirmed). This matters because the special deduction below applies only to Argentine source gains.
• Argentine source rate: 15% for "digital currencies" (ITL art. 98(b)). Digital currencies appear only in paragraph (b), which covers instruments "in national currency with adjustment clause or in foreign currency". Gain equals price minus acquisition cost, and "updates and exchange differences are not part of the gross gain" for these assets (ITL art. 98, rule (i)). How you measure an "exchange difference" on a token is not defined (unconfirmed).
• Special deduction: residents may deduct an amount equal to the art. 30(a) non taxable minimum against Argentine source art. 98(a) and (b) gains (ITL art. 100). For the annual period 2026, ARCA's table shows ARS 6,019,671.36 (US$ 3,849.14) (unconfirmed). No loss may be created and no carry forward of unused deduction.
• Foreign source rate: 15%, in the general return (ITL art. 94, third paragraph). Foreign source losses on digital currencies are specific and offset only against gains of the same source and type, for 5 years (ITL art. 132). Foreign currency operations are converted at the Banco Nación rate on the day of the operation (ITL art. 155) (unconfirmed).
• Cost: FIFO by law for digital currencies (ITL art. 67, second paragraph: the oldest acquisitions of the same kind are deemed sold first, with no evidence to the contrary admitted).
• Companies: crypto is not inventory (bienes de cambio) for tax purposes (ITL art. 56, last paragraph); gains form part of business income at the corporate rate. Losses on sales of digital currencies are of a specific nature for companies (ITL art. 25, list of specific losses for art. 53 subjects, item (a)) and, if foreign source, offset only against gains of the same source and type for 5 years (ITL art. 132).
• Losses of individuals: a loss on schedular investments, including digital currencies, is specific and offsets only future gains of the same source and class, "class" meaning each article of the schedular chapter (ITL art. 25, as amended by Law 27.743 art. 68).

Tax amnesty 2024 (Law 27.743, Title II). Crypto could be regularised (art. 24.1(h)). It counted as located in Argentina only if held in custody or administration of a CNV registered PSAV at the regularisation date, 31 December 2023 (Decree 608/2024 art. 12; Law 27.743 art. 24.4). Crypto not held at a qualifying custodian could only enter if transferred to one before the deadline for Stage 1 (Decree 608/2024 art. 12). Value: market value or acquisition value, whichever higher; the law says market value "at the date of registration in the Regime" (Law 27.743 art. 27.1(h)), the decree says market value at 31 December 2023 (Decree 608/2024 art. 12) (unconfirmed). Special tax: 0% up to US$ 100,000, then 5%, 10% or 15% of the excess by stage (art. 28). After the extensions noted by Infoleg (Decree 977/2024), Stage 3 closed on 7 May 2025 with returns due 6 June 2025 (art. 23, Infoleg note). Proof of title for crypto: the PSAV account statement or the wallet with its public key (ARCA RG 5536/2024, point (h)). PSAVs had to give clients the information to prove holdings (CNV Title XIV Section IV art. 13 as added by RG 1010/2024). The regime is closed; the practical legacy is that the regularised value is the tax cost from 1 January 2024 (Decree 608/2024 art. 13).

Personal assets tax. The Personal Assets Tax Law (Law 23.966, Title VI) does not mention crypto expressly in the source text. Location (Argentine or foreign) and valuation rules for crypto are therefore applied by analogy (unconfirmed). The 2025 non taxable minimum is ARS 384,728,044.57 and rates are 0.50% to 1.00% (ARCA, Bienes personales, alícuotas, period 2025). See Personal income and personal assets tax.

Tax on bank debits and credits. Accounts used exclusively by CNV registered PSAVs for their specific operations are exempt, if registered in the ARCA registry under RG 3900 (Decree 380/2001 Annex art. 10, unnumbered item added by Decree 475/2026 art. 5, in force 18 June 2026). See Tax on bank debits and credits.

VAT and gross income tax. No source in the file addresses VAT on PSAV commissions or on crypto sales (unconfirmed). Gross income tax is provincial; no provincial code is in the sources. ARCA's activity classifier now has codes 649992 (buying and selling crypto for own account, including through a PSAV or P2P), 661993 (services facilitating crypto transfers, trading, investment or exchange through electronic platforms, which "includes the activity of PSAVs") and 631123 (crypto custody services) (ARCA RG 5607/2024, point 4). PSAVs may issue a monthly electronic invoice per client instead of one per operation, from 1 July 2026 (ARCA RG 1415 Annex IV, point 16, added by RG 5866/2026 art. 1(g), item 16.1(e)).

ARCA reporting by platforms (RG 4614). Entities that manage or process movements of assets on electronic platforms for residents and non residents, including payment providers offering payment accounts, report monthly the account list and the peso totals of inflows, outflows and closing balances of users whose monthly flows or closing balance reach ARS 50,000,000 (individuals; US$ 31,971.35) or ARS 30,000,000 (legal persons; US$ 19,182.81). Crypto balances are converted at the platform's own last buy quote of the month (RG 4614 art. 3, as replaced by RG 5804/2025 art. 1). The RG 5804/2025 title describes RG 4614 as the information regime for "tools and/or IT applications related to movements of virtual assets". ARCA updates the thresholds every 6 months by CPI (RG 4614 art. 3, as amended by RG 5699/2025) (unconfirmed). The new content of the monthly report (account holders, CBU/CVU, movement types) applies to returns due from May 2026 (RG 5804/2025 art. 2). (unconfirmed)

Step by step

A. Registering an Argentine company as a PSAV

1. Decide categories. Map every product to Categories 1 to 5 (art. 9). A custodial exchange normally needs 1, 2, 3 and 4. Registration in all five is required to join the tokenisation sandbox (Title XXII art. 14).
2. Form or adapt the company. SA or SRL with an express PSAV purpose (art. 7(b)(3)). A foreign group either subscribes shares (registering the foreign shareholder under Law 19.550 art. 123) or registers a branch or representation (art. 118). See SRL and SA and SAU.
3. Capitalise. Pay in and register capital at least equal to the PNM; capitalise and register any irrevocable contributions before applying (art. 10).
4. Tax and banking. Obtain CUIT, register activity codes 661993 and, where relevant, 631123 (ARCA RG 5607/2024), register the exclusive accounts with ARCA under RG 3900 for the bank tax exemption (Decree 475/2026 art. 5), open the client money account (art. 19).
5. Build the file. Items in art. 7(b)(1) to (20): by laws, ".ar" website, shareholder register, board and auditors with criminal record certificates and AML sworn statements, compliance and public relations officers, audited financial statements (plus an accountant's PNM certificate if older than 8 months, with equity measured at most 2 months before filing), board minute on adequate organisation, IT expert report, custody system detail, outsourcing agreements, sworn statement of full compliance, AIF sworn statement (art. 7(b)).
6. Prepare the policies. Procedure manuals, cybersecurity, information security, custody and key management, Code of Conduct, conflicts, complaints, risk disclosures, fee schedule, token listing policy (arts. 12 to 38). The UIF manual, self assessment methodology and KYC procedures (UIF Res. 49/2024 arts. 3 to 9).
7. File online. Start "Proveedores de Servicios de Activos Virtuales: Solicitud de inscripción" on the TAD platform (Title XVI, Chapter I, art. 7(i), as replaced by RG 1112/2026) and load the AIF forms PSAV_001 to PSAV_018 (Title XV, Chapter I, Section IV, art. 11(S)). The decision is delegated to the CNV Registration and Control Department (Title XVI, Chapter II, art. 4 and Annex IV, item 3, RG 1112/2026). No fee for registration appears in the current CNV fee annexes (MECON Res. 1/2026, Annexes I and II).
8. Answer CNV requests. The CNV may ask for any complementary information (art. 7, last paragraph). No maximum decision time appears in the rules (unconfirmed).
9. After registration. Publish the legend (art. 6); register with the UIF as a reporting party under UIF Res. 50/2011 and register the compliance officers (UIF Res. 49/2024 arts. 11 and 42) (unconfirmed); report the start of operations as a material fact (art. 40(d)(ii)); pay the CNV fee for the year of registration (unconfirmed).
10. Run the calendar. Monthly CNV and UIF reports, annual audits and reports, annual fee (see the deadlines table).

B. Individual operating as a PSAV

1. Check that third party activity exceeds UVA 35,000 in a month, valued at the UVA on the last day of that month (art. 1).
2. Obtain the accountant's certificate of that fact (art. 7(a)(10)), criminal record certificate, a certified statement of assets proving the PNM (art. 7(a)(12)), the IT expert report and the AML sworn statement (art. 7(a)).
3. Register for Categories 1 and/or 2 only (art. 9).
4. Same UIF registration and reporting as a company; annual certified statement of assets within 90 days of year end (art. 40(c)(4)). Annual CNV fee for individuals: ARS 5,344,000 in 2026.

C. Adding a category, changing name, or leaving

• New category: email the CNV PSAV registry (RegistroPSAV@cnv.gov.ar) first, file the supporting documents on the AIF, and once the CNV confirms, report a material fact describing the change and the corporate resolution, and update form PSAV_003 (art. 42).
• Change of corporate name: file the Public Registry certificate on the AIF (art. 43).
• Voluntary cancellation: notify clients at least 30 calendar days in advance, enable withdrawal or transfer of balances, send periodic reminders, then file the request through TAD with a sworn statement that activity has ceased (art. 44(a)). The CNV also cancels on revocation (art. 44(b)) or at the UIF's request for breaches of UIF reporting, including beneficial owner identification (art. 44(c)).

D. Foreign exchange with Argentine users that decides not to register

1. Run the five tests in art. 4. If any applies, stop: you must register or exit.
2. If you exit: remove ".ar" domains, terminate local ramp agreements, stop targeted advertising, geo block onboarding, and monitor Argentine volume against the 20% test (art. 4).
3. Keep reverse solicitation clients only where the client approached you on the client's exclusive initiative and keep evidence of that (art. 4(4)).
4. Expect enforcement risk: URL blocking requests (art. 41) and sanctions under Law 27.739 art. 37 (art. 3).

Costs and timelines

Rates, thresholds and amounts

Deadlines

Timeline of norms

Worked examples

Example 1. A foreign exchange registers an Argentine subsidiary as a PSAV

Facts (hypothetical). A crypto exchange incorporated in a cooperative, FATF compliant jurisdiction has 40,000 Argentine users, a Spanish language app and a local peso on ramp partner. It meets points of contact 2, 3 and probably 5 in art. 4, so it must register. It decides to form an Argentine SA ("ArgCo"), 100% owned by the parent (registered under Law 19.550 art. 123), offering fiat to crypto, crypto to crypto, transfers and custody (Categories 1 to 4). Decision date: 2 November 2026.

Step 1: capital.

The CNV measures equity at the Com. "A" 3500 rate, not MEP. ArgCo must have the capital paid in and registered before filing (art. 10(i) to (iii)). Because ArgCo will start with zero volume but expects to exceed US$ 2.5 million within its first year, the prudent plan is to capitalise at US$ 150,000 so it does not breach art. 10 when volume crosses the threshold and avoid a material fact and a 10 day recapitalisation plan (art. 11).

Step 2: regulatory fees.

If ArgCo is registered by 31 December 2026, it pays the annual fee between the 8th and 12th business day of January 2027 (Title XVII, Chapter I, art. 3(b)). The amount payable in January 2027 will be whatever MECON fee annex is then in force; ARS 13,360,000 is the 2026 annex (unconfirmed).

Step 3: professional and set up costs (hypothetical; no official source). These are placeholders the reader must replace with quotes. They are included only to show the structure of the budget.

(unconfirmed)

Step 4: timeline (editorial estimate) (unconfirmed).

Result. About 4 to 8 months and a regulatory floor of US$ 150,000 of capital plus ARS 13,360,000 (US$ 8,542.75) a year in CNV fees, before professional and staff costs. The parent can keep running the global matching engine and cold storage if it signs an outsourcing agreement that gives the CNV and the UIF full access to information, is regulated for AML in its home jurisdiction, and ArgCo keeps full responsibility (art. 36). Client assets held by the parent must sit in a wallet used only for ArgCo's clients (art. 17).

What happens to the parent. Once ArgCo is registered, the parent itself does not need to register, provided it has no direct contractual relationship with Argentine clients and does not itself meet an art. 4 point of contact (art. 2, last paragraph). Argentine users must therefore be migrated to contracts with ArgCo.

Example 2. A resident individual sells USDT at a gain

Facts (hypothetical prices). A tax resident individual bought 100,000 USDT on a CNV registered PSAV on 15 January 2025 at ARS 1,180 per USDT and sold all of them on 23 October 2026 at ARS 1,563.90 per USDT. The PSAV charged 0.5% on each trade (hypothetical). No other crypto sales in 2026.

Step 1: peso amounts.

Step 2: the three possible readings. The law does not settle source for an asset whose issuer is abroad, nor how to strip "exchange differences" from a dollar stablecoin. The three readings below are all defensible on the text; none is confirmed by a source in the file (unconfirmed).

Reading A: Argentine source, peso gain fully taxable (ITL art. 98(b), deduction under art. 100).

Reading B: Argentine source, exchange differences excluded (ITL art. 98, rule (i)). USDT is treated as a dollar denominated asset. The gain is measured in USDT: proceeds 99,500 USDT net of fees, cost 100,500 USDT including the fee. Result: a loss of about 1,000 USDT, so no tax. Any loss is specific and can only offset future art. 98 gains of the same source (ITL art. 25) (unconfirmed).

Reading C: foreign source (issuer domiciled abroad, ITL art. 7), 15% in the general return (ITL art. 94, third paragraph), no art. 100 deduction.

(unconfirmed)

Step 3: what to do. The spread between zero and ARS 5.55 million on a position worth about US$ 100,000 shows why advisers keep records in both pesos and USDT, document the PSAV used, and take a written position on source and exchange differences. Under the simplified income tax return regime (see Fiscal innocence regime) the filing mechanics differ; this example assumes the ordinary regime.

Step 4: reporting footprint. The PSAV will show this individual in its UIF monthly report (operations of 6 SMVM or more; ARS 156 million is about 66.6 times the October 2026 threshold of ARS 2,347,200) (UIF Res. 49/2024 art. 39(a)) and in its ARCA RG 4614 report for October 2026 if the platform is within that regime, because monthly flows exceed ARS 50,000,000 (RG 4614 art. 3) (unconfirmed).

Step 5: personal assets. If the individual still held the USDT at 31 December 2026, the holding would enter the personal assets tax base at a value and location that the sources do not fix for crypto (unconfirmed). On its own, ARS 156 million is below the 2025 non taxable minimum of ARS 384,728,044.57 (the 2026 figure is not in the sources) (unconfirmed).

Example 3. Does a small P2P trader need to register?

Facts. An individual buys and sells USDT for other people through social media, as a business, for a monthly total of ARS 60,000,000 in November 2026. Assume a UVA value of ARS 1,800 at 30 November 2026 (hypothetical) (unconfirmed).

• Threshold: UVA 35,000 × ARS 1,800 = ARS 63,000,000 (US$ 40,283.91).
• Activity: ARS 60,000,000, below the threshold.
• Result: the individual is not required and, on the RG 1172/2026 wording, not able to register for November (art. 1). If December activity is ARS 70,000,000 at a similar UVA, the threshold is exceeded and the individual must register before carrying out that activity, which in practice means registering before the business grows past the threshold. Trading for own account would not count at all (art. 2(i)).
• UIF: an unregistered individual is not within UIF Res. 49/2024, which applies to CNV registered PSAVs (art. 2(v)), but Law 25.246 art. 20(13) names "virtual asset service providers" without a threshold (unconfirmed).

Practical traps

1. "Registered" is not a light touch any more. Many foreign groups registered under RG 994/2024 in 2024 with a simple form. Those that did not migrate to RG 1058/2025 standards by 1 September 2025 (foreign companies) were to be cancelled (Title XVIII, Ch. XIV, art. 1(c), RG 1058/2025). Check the current register before relying on a partner's status (unconfirmed).
2. SAS is not allowed. A PSAV company must be an SA or SRL; SAS registrants had to convert (RG 1058/2025 transitional art. 1(b)).
3. Generic corporate purpose fails. RG 1172/2026 rejects purposes that only implicitly cover PSAV activity (art. 7(b)(3)).
4. Unregistered irrevocable contributions do not count. Capitalise and register them before filing (art. 10(iii)).
5. Halved capital is not a safe harbour. The 50% reduction depends on trailing volume; crossing US$ 2.5 million makes the full PNM due (art. 10) and a shortfall is a material fact (art. 11).
6. The parent cannot keep the client contracts. The art. 2 carve out for the foreign parent requires no direct contractual relationship with Argentine clients.
7. Reverse solicitation must be genuine. It must be the client's "exclusive initiative" (art. 4(4)); marketing to Argentines elsewhere defeats it, and any other point of contact independently triggers registration.
8. Decentralised in name only. If someone has control or sufficient influence over a protocol and provides PSAV services, the carve out does not apply (art. 2(iii)).
9. Proof of reserves is public. It must be published, and the annual systems audit must cover it (arts. 16 and 21).
10. Client crypto on the balance sheet. Booking client assets as your own assets or counting them as equity breaches art. 17.
11. Nil returns are still returns. The monthly CNV report is due even with no activity (Annex I, section I); the UIF reports run on their own calendar.
12. Two compliance officers, two regulators. The CNV regulatory compliance officer (art. 22) and the UIF compliance officer (UIF Res. 49/2024 art. 11) have different duties and reports; one person may hold both only if the rules allow (unconfirmed).
13. STR clock. The 24 hour clock runs from the conclusion of the analysis, but never later than 90 days from the operation for laundering cases; for terrorist financing it runs from the operation (UIF Res. 49/2024 art. 36).
14. Advertising crossover. Influencers and promoters of a PSAV may not promote capital markets products, and vice versa (art. 33).
15. Banks still cannot trade crypto for clients. Partnerships where a bank app "facilitates" crypto buying run into Com. "A" 7506 (unconfirmed).
16. Bank tax exemption needs registration. Without RG 3900 registration of the exclusive accounts, the Decree 475/2026 exemption does not apply.
17. Tax source and FX differences. See Example 2: document your filing position.
18. Law 27.739 timing. The CNV and UIF rules took effect on 25 and 26 March 2024, while Law 27.739 entered into force 30 days after 15 March 2024 (art. 40). For acts in that window the legal basis was debatable; it matters only for historical enforcement (unconfirmed).

Recent changes

• 15 October 2026, CNV RG 1172/2026. Rewrote Chapter III: decentralised protocol carve out now depends on absence of control or sufficient influence; self custody carve out defined; individuals must prove the UVA 35,000 threshold with an accountant's certificate; foreign subsidiary and branch requirements, PNM quality rules (fully paid, registered capital; contributions capitalised within 6 months) and express corporate purpose codified from interpretive criteria 95 to 97 (now repealed); smart contracts in the annual audit; new procedures for category changes (art. 42), name changes (art. 43) and cancellation with 30 day client notice (art. 44); expanded material facts list (art. 40(d)); monthly report Annex I applicable from 1 November 2026; new defined terms ARS, BTC, USD, USDC, USDT (RG 1172/2026 art. 1).
• 29 June 2026, ARCA RG 5866/2026. Monthly electronic invoice option for PSAVs from 1 July 2026.
• 18 June 2026, Decree 475/2026. Bank tax exemption for PSAV exclusive accounts.
• 11 June 2026, CNV RG 1150/2026. Amendments to the tokenisation regime (unconfirmed).
• 14 May 2026, CNV RG 1139/2026. CNV AML information regime applies to PSAVs from 1 July 2026; payment methods rules and fitness rules extended to PSAVs.
• 20 February 2026, CNV RG 1108/2026. Crypto transfers from PSAV accounts accepted as a funding route for simplified regime clients.
• 26 February and 6 March 2026, CNV RG 1112/2026 and RG 1118/2026. TAD procedures and delegation; Title XIV renamed after removal of the innovation hub chapter.
• 7 and 9 January 2026, MECON Res. 1/2026 and CNV RG 1103/2026. New annual fees and payment window.
• 24 December 2025, ARCA RG 5804/2025. RG 4614 reporting rewritten; new fields apply from returns due May 2026.
• 2025, CNV RG 1058/2025, RG 1069/2025, RG 1081/2025, RG 1086/2025. Full regime, transitional deadlines (individuals 1 July 2025, local companies 1 August 2025, foreign companies 1 September 2025; all other requirements 31 December 2025), tokenisation sandbox, and first fee payment window 3 to 7 November 2025.

Pending changes

• Travel rule modality. UIF Res. 49/2024 art. 37 leaves the exchange and validation method to the UIF (unconfirmed).
• Tokenisation sandbox after 21 August 2026. Extension, permanent regime or closure (unconfirmed).
• BCRA stance on banks and crypto. Com. "A" 7506 is still the reference; any opening would need a new BCRA communication (unconfirmed).
• Tax guidance. No regulation or ARCA guidance in the sources on crypto source rules, exchange differences, swaps, staking or airdrops, or personal assets valuation (unconfirmed).
• ARCA rules for PSAV custodians. CNV RG 1010/2024 (Title XIV Section IV art. 13) refers PSAV custodians to AFIP rules issued for the amnesty; whether a permanent ARCA information regime specific to PSAV custody exists is not in the sources (unconfirmed).
• Interpretive criteria on "clear targeting". None in the sources (unconfirmed).
• 2027 CNV fees. A new MECON annex would set the January 2027 payment (unconfirmed).

FAQ

1. Is a CNV PSAV registration a licence? Legally it is still called a registration (inscripción), but since RG 1058/2025 it comes with capital, governance, custody, conduct and reporting requirements, CNV supervision under Law 26.831 art. 19 (Law 27.739 art. 37), sanctions under Law 26.831 (art. 41) and revocation (art. 44(b)). The 2024 legend saying it was "not a licence" was removed. Treat it as a licence in practice.

2. Can a foreign exchange serve Argentines from abroad without registering? Only if none of the five points of contact in art. 4 applies: no ".ar" domain, no local ramps, no targeting, no targeted advertising, and Argentine volume of 20% or less, with Argentine clients coming on their own exclusive initiative. If any one applies, it must register through an Argentine company or a registered branch or representation (arts. 1 and 4).

3. Can the foreign parent register directly? No. Since RG 1058/2025 a foreign company registers only through an art. 123 Argentine company or an art. 118 branch or representation (art. 1). Foreign entities registered under RG 994/2024 had to convert by 1 September 2025 or be cancelled.

4. How much capital does a crypto exchange need? US$ 150,000 of net equity for Categories 1, 2 or 4, or US$ 75,000 while trailing 12 month volume is under US$ 2.5 million (art. 10). Capital must be fully paid and registered.

5. Can a PSAV keep client crypto with its parent or a third party custodian? Yes, through an outsourcing agreement, but the PSAV remains fully responsible, the custodian must be AML regulated in a cooperative jurisdiction if it performs PSAV activities abroad, and client assets must sit in a wallet used exclusively for the PSAV's clients (arts. 17 and 36).

6. Do I need to register to accept bitcoin in my shop? No. Receiving or delivering crypto as payment for your own goods or services is outside the PSAV definition (art. 2(ii)). You still have tax obligations on the sale and on any later disposal of the crypto.

7. Do I need to register to trade my own crypto? No. Trading for your own account is excluded whatever the amount (art. 2(i)).

8. I run a P2P desk as an individual. When must I register? When your activity for others, as a business, exceeds UVA 35,000 in a calendar month (art. 1). You can register only for Categories 1 and 2, need an accountant's certificate of the volume, and must meet the PNM (arts. 7(a) and 10).

9. Can my Argentine bank sell me crypto? Not under BCRA Com. "A" 7506, which bars banks from offering or facilitating operations with digital assets not authorised by a national regulator or the BCRA. Wallets that offer payment accounts are under the same bar (BCRA PSP rules point 4.6).

10. What tax do I pay on crypto gains? 15% for individuals, either as Argentine source schedular tax (ITL art. 98(b)) or as foreign source gain in the general return (ITL art. 94). The source rule and the treatment of exchange differences are uncertain (Example 2). Companies include gains in business income.

11. What does the PSAV report about me? To the UIF: operations of 6 SMVM or more and your client data including PEP status, monthly (UIF Res. 49/2024 art. 39). To ARCA: monthly flows and balances if you reach the RG 4614 thresholds (ARS 50,000,000 for individuals). To the CNV: only aggregated data (art. 40(b)).

12. Can I still regularise undeclared crypto under the 2024 amnesty? No. The last stage closed on 7 May 2025, with returns due 6 June 2025 (Law 27.743 art. 23, as extended).

13. How much is the CNV annual fee? For 2026: ARS 13,360,000 for legal persons and ARS 5,344,000 for individuals (MECON Res. 1/2026), payable in the 8th to 12th business days of January after year end for PSAVs registered at 31 December (Title XVII art. 3(b)).

14. Can a PSAV list any token? Only tokens with a white paper or equivalent information published in Spanish or English; tokens launched less than 90 days ago only in a separate warned section; and never tokens that are securities without CNV authorisation (art. 38).

Primary sources

• Law 27.739 (BO 15 Mar 2024), arts. 4, 37 to 40
• Law 25.246, updated text, arts. 4 bis, 20, 24, 24 bis
• Law 26.831, updated text, arts. 2, 19, 132, 133
• CNV RG 994/2024 (BO 25 Mar 2024)
• CNV RG 996/2024 (BO 5 Apr 2024)
• CNV RG 1010/2024 (BO 19 Jul 2024)
• CNV RG 1026/2024 (BO 21 Oct 2024)
• CNV RG 1040/2024 (BO 31 Dec 2024)
• CNV RG 1048/2025 (BO 9 Jan 2025)
• CNV RG 1058/2025 (BO 14 Mar 2025)
• CNV RG 1060/2025 (BO 11 Apr 2025)
• CNV RG 1069/2025 (BO 13 Jun 2025)
• CNV RG 1081/2025 (BO 21 Aug 2025)
• CNV RG 1086/2025 (BO 24 Sep 2025)
• CNV RG 1087/2025 (BO 23 Oct 2025)
• CNV RG 1103/2026 (BO 9 Jan 2026)
• CNV RG 1108/2026 (BO 20 Feb 2026)
• CNV RG 1112/2026 (BO 26 Feb 2026)
• CNV RG 1118/2026 (BO 6 Mar 2026)
• CNV RG 1139/2026 (BO 14 May 2026)
• CNV RG 1150/2026 (BO 11 Jun 2026)
• CNV RG 1172/2026 (BO 15 Oct 2026)
• Infoleg search, norms citing "proveedores de servicios de activos virtuales"
• MECON Res. 1418/2024 (BO 24 Dec 2024), Annex II fee table
• MECON Res. 1/2026 (BO 7 Jan 2026), Annexes I and II
• UIF Res. 49/2024 (BO 25 Mar 2024)
• CNEPYSMVM Res. 4/2026 (minimum wage)
• BCRA Com. "A" 7506 (5 May 2022)
• BCRA, Proveedores de servicios de pago, ordered text at 2 Oct 2026, point 4.6
• BCRA Com. "A" 8481, Exterior y Cambios ordered text at 14 Sep 2026, points 3.16.2.1, 3.16.3, 4.1.4.5
• Income Tax Law, text ordered by Decree 824/2019, arts. 2, 3, 7, 56, 67, 94, 98, 100, 101, 132, 155
• ARCA, art. 30 deductions, annual period 2026
• Law 27.743 (BO 8 Jul 2024), arts. 23, 24, 27, 28
• Decree 608/2024 (BO 12 Jul 2024), arts. 12, 13
• AFIP RG 5528/2024
• AFIP RG 5536/2024
• ARCA, Bienes personales, alícuotas
• Decree 475/2026 (BO 18 Jun 2026)
• ARCA RG 5607/2024 (BO 29 Nov 2024)
• ARCA RG 5699/2025 (BO 23 May 2025)
• ARCA RG 5804/2025 (BO 24 Dec 2025), amending RG 4614
• ARCA RG 5866/2026 (BO 29 Jun 2026)

Related pages

• Is crypto legal in Argentina, and how is it taxed?
• Banking and payments in Argentina: accounts, transfers, cards and cross border flows
• Raising capital in Argentina: CNV public offerings, ONs and the SME regime
• Can a foreigner open a bank account in Argentina?
• Can a foreigner invest in the Argentine stock market?
• Live rates: BADLAR, TAMAR, time deposits