Guide · 5. FX and capital controls
Export proceeds: repatriation and settlement rules for Argentine exporters
Last verified: 27 Oct 2026 · Status: Changing
Argentina still requires exporters to bring their foreign currency home and, in most cases, to sell it for pesos in the official market. The legal hook is Decree 609/2019, art. 1, as replaced by Decree 91/2019: the value of exports of goods and services "must be brought into the country in foreign currency and/or traded in the exchange market under the conditions and terms set by the BCRA". The BCRA sets those conditions in Sections 2, 7, 8, 9 and 14 of its consolidated FX rules. Breaches fall under the Criminal Exchange Law (FX rules, point 1.5), which allows fines of up to ten times the amount of the operation for a first offence and prison for repeat offenders (Criminal Exchange Law, art. 2).
The core rules in force on 22 October 2026 are:
- Goods. The exporter must bring in and settle the invoiced value under the agreed sale terms (FX rules, point 7.1.1). The deadline runs from the customs shipment date and depends on the tariff code and on whether the buyer is related. It is 30 days for grains, oilseeds and by products and most of chapter 27 (fuels), 60 days for most ores, precious metals and sales to related parties, 180 days for the general case, and 365 days for leather goods, clothing, footwear, hats, a nuclear reactor parts code and the "Exporta Simple" scheme (point 7.1.2). Independently of that outer limit, money actually collected must be settled within 20 business days of collection (point 7.1.1).
- Services. Collections for services rendered by residents to non residents must be settled within 20 business days of collection abroad or in Argentina, or of credit to an account abroad (point 2.2.1).
- Advances, prefinancing and postfinancing from abroad must be settled within 20 business days of collection or disbursement (point 7.1.3). Prefinancing by local banks must be settled on disbursement (point 7.1.4).
- Exceptions that let the exporter keep dollars. Individuals (not companies) exporting services or goods may credit the proceeds to their own foreign currency account at a local bank without selling them, provided the result is fiscally neutral (points 2.2.2.1 and 7.1.5). The former USD 36,000 annual cap for individuals was removed on 18 September 2025 (Com. A 8330) and the exception was extended to all service concepts and to goods on 9 April 2026 (Com. A 8417). Companies benefit only through narrower routes: the knowledge economy export incentive (30% of incremental exports over the same quarter of 2021, used for dollar payroll, points 2.2.2.2, 2.6 and 7.8.4), simultaneous application to an outflow that would itself have access (point 2.7), RIGI project vehicles (Section 14), inbound tourism (point 2.2.2.3) and certain financing structures (points 7.3, 7.8.5, 7.9, 7.10).
- The blend scheme is over. Blends began for all exports with DNU 549/2023 (70% MLC, 30% securities, from 23 October 2023) and DNU 597/2023 (50/50 to 10 December 2023). From 13 December 2023 Decree 28/2023 let exporters of goods and services settle 80% in the MLC and channel 20% through securities bought in foreign currency and sold for pesos (Decree 28/2023, art. 1). DNU 269/2025 repealed Decree 28/2023 from 14 April 2025 and restored the general Decree 609 regime (DNU 269/2025, arts. 1 and 2). The BCRA text no longer contains the blend; only transitional clauses for operations done while it was in force remain (points 7.3.9, 7.5.2 and 8.5.20).
- Export duties are separate. They are set by decree per tariff code under the Customs Code (arts. 724, 726, 735 and 755). Some 2025 duty cuts were conditional on fast settlement: for example, 90% of the currency within 3 business days of the sworn foreign sale declaration under the temporary 0% grain window (Decree 682/2025, art. 2), and 95% within 15 business days under Decree 38/2025 (art. 2).
Nothing on this page should be read as saying that selling export dollars through MEP or CCL is a lawful way to comply. Since the blend ended, the only admitted ways to discharge a shipment permit are those listed in points 7.2, 7.3 and 8.5 of the FX rules.
Who should read this page.
- Foreign investors with an Argentine subsidiary that exports, who need to know how much of the export revenue will be converted into pesos and when.
- Local SMEs shipping goods or invoicing services abroad for the first time.
- Freelancers and individual professionals billing foreign clients, who since 2025 and 2026 may keep their dollars.
- Software and other knowledge economy companies considering the LEC export incentive.
- Advisers (accountants, customs brokers, bank compliance teams) who need the exact BCRA point numbers.
Related pages: the general framework for access to the FX market is in Exchange controls. The legal bond swap markets (MEP and CCL), and the 90 day restrictions that link them to the official market, are in Dólar MEP and CCL. How to become an exporter, the ARCA profile and customs registration are in Importer and exporter registry. Export duty rates by product are in the customs duties page of the taxes section.
Peso amounts are converted at the dólar MEP (bolsa) selling rate of ARS 1,563.90 per US$ on 23 Oct 2026 (source: dolarapi.com, MEP quote). Conversions are indicative and move daily.
Key rules
1. Legal basis: who can impose the obligation
- Decree 609/2019, art. 1 (DNU, BO 1 September 2019, replaced by Decree 91/2019, BO 28 December 2019): the value of exports of goods and services must be brought into the country in foreign currency and/or traded in the exchange market "in the conditions and terms that the BCRA establishes". The original 2019 text limited this to 31 December 2019 (Infoleg summary of Decree 609/2019); the Decree 91/2019 replacement removed the time limit (FX rules, point 15.2, transcribing art. 1 as replaced).
- Decree 609/2019, art. 2: the BCRA sets when access to the market for buying foreign currency and transfers abroad need prior approval, using objective criteria and distinguishing individuals from legal entities.
- Decree 609/2019, art. 3: the BCRA may issue rules to prevent practices that seek to avoid the decree "through public securities or other instruments". This is the anchor for the rules that restrict exporters' use of MEP and CCL (see section 12 below).
- Decree 260/2002, arts. 1 and 2 (art. 1 as replaced by Law 27.444, art. 132, BO 18 June 2018): there is a free exchange market where authorised entities operate; FX operations are at freely agreed rates subject to BCRA rules (FX rules, point 15.1).
- BCRA Charter, art. 29(b): the BCRA issues the regulations of the exchange regime and supervises compliance (quoted in the recitals of Decree 609/2019).
- FX rules, point 1.5: breaches of the FX rules fall under the Criminal Exchange Law.
- DNU 269/2025, art. 1 (BO 14 April 2025): repeals Decree 28/2023 and states that the value of exports of services under Customs Code art. 10.2(c) and of goods in the Mercosur nomenclature, including prefinancing, postfinancing and advances, "shall be governed by the general provisions" of Decree 609/2019. Exporters keep paying export duties at the applicable rate, computed on that value (same article, second paragraph).
Contested or uncertain points. Decree 609 is a decree of necessity and urgency (DNU), and DNU 269/2025 is another. Both rest on Constitution art. 99(3) and are subject to review by the Bicameral Committee under Law 26.122 (recitals of Decree 28/2023 and DNU 269/2025). Whether Congress has expressly approved or rejected DNU 269/2025 is not shown in the sources (unconfirmed). Whether a decree can validly back criminal sanctions through the blanket clause in Criminal Exchange Law art. 1(f) ("any act or omission that breaches the rules of the exchange regime") is a long running constitutional debate in Argentine law; no source in this project resolves it, so readers should assume the sanctions apply (unconfirmed).
2. Exports of goods: the basic obligation (point 7.1.1)
For exports registered (oficializadas) with customs from 2 September 2019:
- What must come in. The foreign currency value of the export "up to the invoiced value under the agreed sale condition" must be brought in and settled within the deadline in point 7.1.2 (point 7.1.1, first paragraph). The bank computes the amount from SECOEXPO data and the commercial documents: the FOB value registered with customs plus the other items included in the price under the agreed sale terms (point 8.4.1). If the sale is CIF, freight and insurance in the price are part of the obligation.
- The 20 business day rule. Regardless of the maximum deadline, collections must be brought in and settled within 20 business days of the collection date, but only within the maximum term that applies to the operation (point 7.1.1, second paragraph). In practice: if the buyer pays early, the clock starts on payment; if the buyer pays late, the outer deadline still governs.
- Insurance claims that cover the value of exported goods are caught by the same obligation (point 7.1.1, third paragraph).
- One tracking bank per shipment. The exporter selects an entity (bank or exchange house) to track each shipment permit in SECOEXPO. The obligation is discharged when that entity certifies it (point 7.1.1, fourth paragraph; Section 8). The nomination is first made when the export declaration is registered with ARCA; if omitted, the exporter agrees it with the chosen entity, which reports it to the BCRA (point 8.2). The exporter may change the entity at will before the settlement deadline expires (point 8.2.1).
- Individuals. Goods exported by individuals may be exempt from settlement (point 7.1.5; see section 8 below).
- RIGI. A RIGI project vehicle (VPU) that declared it would use the FX benefits of Law 27.742 art. 198 follows points 14.1.1 and 14.1.2 instead (point 7.1.1, last paragraph).
- Older shipments. Exports registered before 2 September 2019 and unpaid at that date must be settled within 20 business days of collection (point 7.1.6).
- Exceptions to tracking do not cancel the obligation. Some customs operations (samples, diplomatic franchise, temporary exports, transhipment and others listed in point 8.5.17) are excluded from SECOEXPO tracking, but if the exporter receives payment for them, the payment must still be brought in and settled (point 8.1, second paragraph).
3. Deadlines by product (point 7.1.2)
Deadlines count in calendar days from the customs cumplido de embarque (point 7.1.2). See the table in the Tables section for the full list. Key mechanics:
- Mixed shipments. If a shipment permit contains different products, the deadline is the one for the product with the largest share of total FOB value (point 8.4.2, second paragraph).
- Weekends and holidays. The due date is the cumplido date plus the term; if that day is not a business day, it moves to the next business day (point 8.4.2, third paragraph).
- Changes in deadlines. A longer term applies both to new shipments and to earlier shipments whose deadline has not yet expired. A shorter term applies only to exports registered after the change (point 8.4.2, last paragraph).
- Related parties. For related party exports not in the 30 or 60 day lists, the term is 60 days (point 7.1.2.3). If the foreign buyer is a company controlled by the Argentine exporter, the tracking bank may extend the term to the term that would apply to an unrelated buyer, when the exporter's total exports in the previous calendar year did not exceed USD 200,000,000 (exports registered from 1 January 2026) or USD 50,000,000 (exports registered before 1 January 2026). Above that size, a 120 day term is available only for listed beef, pork, poultry, a food preparation code in packs up to 1 kg and wine codes (point 7.1.2.3, items i and ii; Com. A 8417, point 3).
- Revisable prices and mineral concentrates. The term counts from the cumplido on the provisional permit, and the amount is computed on the FOB of the final permit (point 7.8.2).
4. What counts as compliance: admitted imputations (points 7.2, 7.3, 7.4 and 8.5)
The tracking bank records amounts imputed to each permit (point 8.4.3). Admitted imputations include:
- Settlement in the MLC of collections after the cumplido (point 7.2.1).
- The exporter's own funds brought from its accounts abroad to settle an export still unpaid (point 7.2.2).
- Payment processors that settle in the MLC and credit pesos to the exporter's local account (points 7.2.3 and 8.5.16).
- Local currency system (SML) collections credited in pesos (point 7.2.4). For exports to Paraguay or Uruguay invoiced in the destination currency, the equivalent in that currency counts.
- Individuals' and other exempt collections credited in foreign currency under points 7.1.5, 2.6 and 2.7 (points 7.2.5 and 7.2.6).
- Application of currency to repay advances, prefinancing, postfinancing and other admitted financing, with a certificate from the bank that tracks the financing (point 7.3; Section 9).
- Other imputations listed in point 8.5, including: items included in customs FOB but not in the agreed sale terms (8.5.1); foreign bank charges debited in the collection (8.5.2); goods given free of charge, with an external auditor certificate above USD 25,000 (8.5.3); goods rejected and reimported (8.5.6); shortfalls and defects (8.5.8); discounts and service charges payable abroad shown in the documents (8.5.11); contractual late delivery penalties between unrelated parties (8.5.13); foreign withholding taxes retained by the buyer's country (8.5.14).
When the bank accepts an imputation other than a direct settlement, it must report it to the BCRA within 5 business days (point 8.4.3, last paragraph). When imputations reach the full amount, the bank issues the certificate of compliance (cumplido). That certificate is needed for FX purposes and also "gives rise to the release of payments by ARCA" under customs and tax rules (point 8.4.4) (unconfirmed).
5. Extensions (point 7.5)
The tracking bank may extend the deadline only in these cases:
| Ground | Extension allowed | Point |
|---|---|---|
| The destination country imposes a minimum import financing term longer than the Argentine deadline | To the destination country term | 7.5.1 |
| The unpaid amount was fully prefinanced (or covered by postfinancing settled before the deadline) and the exporter gave the buyer credit terms | To the maturity of the exporter's credit to the buyer, or of the longest discounted receivable | 7.5.2 |
| Proceeds held in accounts pledged under an admitted financing | To the 5th business day after the date the contract requires the funds to stay deposited, up to 125% of debt service for the current month and the next 6 months | 7.5.3 |
| Exports to a controlled foreign subsidiary (size threshold) or wrongly declared as related party | To the term in 7.1.2.3 or the unrelated party term | 7.5.4 |
| Revisable prices or mineral concentrates where the final price cannot be set for reasons beyond the exporter's control | Up to 120 calendar days from the cumplido of the provisional permit, if at least 85% has been imputed and the exporter files a sworn statement | 7.5.5 |
| Collections held pending application under the Decree 234/2021 investment regime | To the estimated application date | 7.5.6 |
| Knowledge economy exporter using the special account mechanism | While the funds remain in the special account | 7.5.7 |
The bank must report extensions to the BCRA (point 8.4.8).
6. When the buyer does not pay (point 7.6)
A permit can be recorded as "Incumplido en gestión de cobro" (unpaid despite collection efforts) when non payment is due to the buyer and the exporter proves one of the listed situations, with a sworn statement signed by the legal representative or an empowered attorney (point 7.6):
- Exchange controls in the buyer's country after shipment, proven with a consular legalised copy of the rule; or delays in prior approvals for import payments there (point 7.6.1).
- Insolvency of the buyer after shipment, proven with the publications and the creditor's filing, legalised or apostilled (point 7.6.2).
- Debt collection lawsuit filed against the buyer, with a certified copy of the complaint (point 7.6.3).
- Without a lawsuit: export credit insurance paid and subrogated (7.6.3.1); a foreign public sector buyer (7.6.3.2); claims through a credit insurer or a recovery agency where the total owed by that non resident does not exceed USD 200,000 (7.6.3.3); or documented claims without court action where unpaid permits registered in the calendar year do not exceed USD 100,000 (7.6.3.4). For 7.6.3.2 and 7.6.3.4, above USD 25,000 the bank must also obtain an external auditor's report on the receivable, its accounting, provisions or write offs and the collection actions (point 7.6, final paragraph).
This status is not available for related party sales, except where the cause is exchange controls in the buyer's country (point 7.6, third paragraph). If the buyer later pays, the exporter or the credit insurer must bring in the currency within 20 business days of the funds being made available (point 7.6, fourth paragraph).
7. Exports of services (point 2.2)
- Obligation. Collections for services rendered by residents to non residents must be brought in and settled in the MLC within 20 business days from collection abroad or in Argentina, or from credit to accounts abroad (point 2.2.1). There is no SECOEXPO style tracking of each invoice for services in the text; the obligation attaches to each collection.
- Bank charges. For funds received abroad, the usual charges debited by foreign banks for the transfer count as settled (point 2.2.1, last paragraph).
- SML. Collections through the local currency system count as settled for the pesos credited (point 2.2.3).
- Debt service. Service export proceeds may be applied to foreign financial debt, bonds with market access and repatriation of direct investment if point 7.9 conditions are met (point 2.2.4), and accumulated in guarantee accounts up to the amounts the loan contracts require (point 2.2.5).
- Customs side. Services rendered in Argentina and used abroad are "goods" for customs purposes (Customs Code art. 10.2(c), referred to in Decree 28/2023 art. 1 and DNU 269/2025 art. 1). Whether a customs registration or export duty applies to a given service is outside the BCRA rules; see the knowledge economy page for the 0% export duty for LEC beneficiaries (Decree 1034/2020, art. 3, as summarised in that page) (unconfirmed).
- Thresholds. For companies there is no threshold: the 20 business day obligation applies from the first dollar. For individuals, the only threshold was the USD 36,000 calendar year cap on the exception (former point 2.2.2.1(iii), in force in the February and August 2025 consolidated texts, Com. A 8191 and A 8307). Com. A 8330, point 1, removed it from 18 September 2025.
8. Exceptions that allow the exporter to keep dollars
(a) Individuals exporting services (point 2.2.2.1). No settlement is required if the collection arrives within the normal terms and (i) the funds are credited to a foreign currency account in the client's own name at a local bank, and (ii) the mechanism is fiscally neutral. The bank records two FX tickets with no peso movement: a purchase under the relevant services concept and a sale under concept "A22. Acreditación de cobros de exportaciones de bienes y servicios". Banks may not charge commissions, though they may pass on documented foreign bank charges at cost (point 2.2.2.1, last paragraph; point 2.8; Com. A 8330, point 2). History: until 18 September 2025 the exception was capped at USD 36,000 a year and limited to listed service codes (S01, S07, S12 to S19, S21 to S24, S27, S28), with sworn statements on the cap and the 90 day securities restrictions (Com. A 8191 text, point 2.2.2.1). Com. A 8226 (from 14 April 2025) dropped the 90 day securities sworn statements for this exception (point 4). Com. A 8330 removed the cap; Com. A 8417, point 2 (9 April 2026), extended it to all service concepts.
(b) Individuals exporting goods (point 7.1.5). Since Com. A 8417, point 1 (9 April 2026), individuals may also keep goods export proceeds in their own local foreign currency account on the same terms, if the funds come in within the deadlines. The exception does not cover exports made by individuals on behalf of companies or other entities (point 7.1.5(i)). The same applies to advances and prefinancing received by individuals (points 7.1.3 and 7.1.4).
(c) Knowledge economy companies (points 2.2.2.2, 2.6 and 7.8.4; Decree 679/2022, Chapter II). Companies registered in the LEC beneficiaries register may keep in dollars up to 30% of the foreign currency from incremental net exports, checked quarterly against the same quarter of 2021, to pay registered employees working on promoted activities (Decree 679/2022, art. 8). The BCRA conditions are:
- The collection must come in within the normal deadline (point 2.6.1.1).
- For services, it must fall under listed concept codes (S01, S07, S12 to S19, S21 to S24, S27, S28) and the client must sign a sworn statement that the unsettled amounts relate to knowledge economy activities (point 2.2.2.2(i)).
- The client must hold a "Certification of increase in knowledge economy exports (Decree 679/22)" for the amount, issued by a single nominated local bank for each quarter after registration. Total certificates for the quarter cannot exceed 30% of the increase in goods and services export collections settled in the MLC in that quarter against the same quarter of 2021; the bank checks the figure in BCRA data (point 2.6.2.1).
- The client's sworn statement must confirm: the increase relates to knowledge economy activities; the funds will be used for dollar payroll of registered staff on promoted activities under Decree 679/2022 and Ministry of Economy Res. 234/2022; no outstanding export settlement breaches; and compliance with the 90 day securities restrictions of points 3.16.3.1 and 3.16.3.2, measured from the day of the request (point 2.6.2.2).
- The funds must sit in a "Cuenta especial para el régimen de fomento de la economía del conocimiento. Decreto 679/22" in the client's name until paid out as salaries (point 2.2.2.2(iii)).
- The amounts cannot benefit from any other differential FX treatment (points 2.6.1 and 2.6.2.3).
- Breach of the commitment forfeits the benefit and obliges the company to settle an equivalent amount in the MLC, plus possible LEC sanctions (Decree 679/2022, art. 11).
(d) Simultaneous application (point 2.7). Any resident may skip settlement of proceeds under points 2.1 to 2.5 (goods, services, non produced assets and debt) if, within the settlement term: the funds stayed in the client's local foreign currency account (or came into a local bank's correspondent account in the client's name); they are applied at the same time to an outflow for which the rules allow access to the MLC against pesos, within that concept's limits; the mechanism is fiscally neutral; and the client signs a sworn statement that the amount counts toward the relevant limits (points 2.7.1 to 2.7.4). Typical use: an exporter pays an import invoice or a loan instalment that it could have paid by buying dollars in the MLC, without the round trip through pesos.
(e) Inbound tourism (point 2.2.2.3). Card, wallet and similar payments by non residents for spending in Argentina, tourism services and passenger transport to Argentina are exempt from settlement.
(f) RIGI project vehicles (Section 14). For a VPU that opted for the FX benefits of Law 27.742 art. 198, goods export proceeds are freed from the settlement obligation in a rising percentage measured from the start up date reported by the authority: for long term strategic export projects 0% in year 1, 20% after 1 year, 40% after 2 years and 100% after 3 years; for other projects 0% within 2 years, 20% after 2 years, 40% after 3 years and 100% after 4 years (points 14.1.1 and 14.1.2). Service collections are fully exempt for services rendered from start up (point 14.1.3). Advances and financing follow the percentage of the export financed (point 14.1.4).
(g) Investment for exports regime (Decree 234/2021, point 7.10). For projects under that regime, up to 20% of a permit's currency may be applied abroad to import debts, foreign financial debt, dividends or repatriation, capped in each calendar year at 25% of the gross investment brought in for the project (points 7.10.1 and 7.10.2).
(h) CNV promissory notes (point 7.3.5; Com. A 8441, 21 May 2026). Funds raised by issuing foreign currency promissory notes under CNV RG 1003/2024 may be applied against export permits if the exporter settled all the funds within 72 business hours, and later export collections credited to the exporter's local dollar account and used within 72 business hours to pay the notes are exempt from settlement.
9. Advances, prefinancing and postfinancing
- Settlement. Advances, prefinancing and postfinancing from abroad: within 20 business days of collection or disbursement abroad (point 7.1.3). Prefinancing, postfinancing and import financing granted by local banks: settled at disbursement (point 7.1.4).
- Definitions. An advance is a payment by the foreign buyer settled before the cumplido (point 7.3.1). Prefinancing is financing by a local bank or a non resident other than the buyer to fund inputs, production and export, settled before the cumplido (point 7.3.2). Postfinancing is financing against receivables for goods already delivered (point 7.3.3).
- Tracking. Each such settlement gets an APX number and enters the "Tracking of advances and other export financing" (point 7.3; Section 9). To impute a repayment against a permit, the exporter needs a certificate of application from the bank tracking the financing (point 7.3, second paragraph).
- Repayment must come from exports. Advances and export financing must be repaid with export proceeds unless the client proves it cannot, for reasons beyond its control, such as cancellation or non payment by the buyer. Otherwise access to the MLC to repay is governed by the rules for financial loans (point 7.7). Prepaying a local bank's export financing needs BCRA prior approval unless the client has export settlements at least equal to the amount prepaid (point 7.7, third paragraph).
- New financing to repay old. New advances or pre or postfinancing may be applied to repay earlier prefinancing (point 7.8.3).
- Long term prefinancing with external funding settled from 1 August 2025, with an average life of at least 3 years and 1 year of grace (or 2 years and 18 months of grace), allows the exporter to accumulate export proceeds in guarantee accounts up to 125% of the debt service for the current month and the next 6 months (point 7.8.5).
- Financial debt. Proceeds of goods and services exports may be applied to foreign financial debt and bonds that meet point 7.9 conditions, for example debt settled from 19 April 2024 with an average life of at least 3 years and no principal in the first year (point 7.9.1.5), or settled from 8 August 2025 with an average life of at least 2 years and no principal in the first 18 months (point 7.9.1.4). The nominated bank must send a certificate to the BCRA within 90 calendar days of the first inflow (point 7.9.4).
10. How banks handle the money (points 2.8, 5.3 and 1.8)
- Banks must let clients credit inflows from abroad to their foreign currency accounts, crediting the same amount if the currency matches, unless the inflow is subject to settlement and its deadline has already expired (point 2.8).
- Each FX operation needs an FX ticket (boleto) (points 1.4 and 5.3). For a goods settlement the bank needs a sworn statement on the type of imputation and the shipment permits; if one settlement covers several permits, each permit and amount must be recorded (point 7.2, last paragraphs).
- Requests for BCRA prior approval must be filed by an authorised entity on the client's behalf, addressed to the BCRA's Exchange department, with the bank's own analysis (point 1.8).
- Exporters must also file the BCRA survey of external assets and liabilities for the operations it covers, even if no funds go through the MLC (point 1.9). Thresholds and deadlines changed from 1Q 2026 data (see the foreign debt registration page) (unconfirmed).
11. What happens if the deadline passes (points 8.4.5 and 8.4.6)
If the deadline passes without full imputation, the tracking bank must report the permit to the BCRA as "incumplido" (non compliant) within 10 business days of the deadline (point 8.4.5). If the exporter later completes the obligation, the bank issues the cumplido and closes the report within 5 business days (point 8.4.6). A late settlement does not erase the breach; it is the factual basis for any proceedings under the Criminal Exchange Law (see section 13). Whether and how often the BCRA opens proceedings for late but completed settlements is not shown in the sources (unconfirmed).
12. Interaction with MEP, CCL and later access to the MLC
- No partial "blend" any more. Since 14 April 2025 there is no legal route to discharge part of an export through securities sales (DNU 269/2025, art. 1). The transitional clauses only cover operations done while Decrees 492/23, 549/23, 597/23 and 28/23 were in force (points 7.3.9, 7.5.2 and 8.5.20).
- The 90 day cross restriction. A company or other non individual that wants to buy currency in the MLC (for imports, debt, dividends) must declare that in the previous 90 days it has not sold securities for foreign currency in Argentina, swapped securities for foreign assets, transferred securities abroad and similar, and commit not to do so for 90 days after (points 3.16.3.1 and 3.16.3.2). An exporter that uses MEP or CCL therefore blocks its own access to the MLC. Details are in Dólar MEP and CCL.
- Using MEP with pesos after settling. After settlement the exporter holds pesos. What it does with them, including buying dollars through MEP, is governed by the general rules for securities trades and by point 3.16.3, not by the export rules. This page does not address it further.
13. Penalties: the Criminal Exchange Law (Law 19.359, t.o. 1995)
- Offences (art. 1): FX trades without an authorised entity (a); operating in FX without authorisation (b); false declarations in FX operations (c); failing to correct declarations when the real operation differs (d); FX operations not made for the amount, currency, rate, terms and other conditions required by the rules (e); and any act or omission that breaches the exchange regime (f). Late settlement of export proceeds falls naturally under (e) and (f); a false sworn statement to a bank under (c).
- Penalties (art. 2): a fine of up to 10 times the amount of the operation for a first offence (a); for a first repeat offence, prison from 1 to 4 years or a fine of 3 to 10 times (b); for a second repeat offence, prison from 1 to 8 years plus the maximum fine (c). If the first fine did not exceed 3 times, the prison term for a first repeat offence is 1 month to 4 years (d). In all cases, suspension up to 10 years or cancellation of FX authorisations and disqualification up to 10 years from acting as importer or exporter (e).
- Companies and managers (art. 2(f)): if directors, legal representatives, attorneys, managers, statutory auditors or supervisory board members act with the company's means and in its name or benefit, the company is also fined, and the fine is jointly enforceable against the company and the individuals who took part.
- Voluntary correction (art. 2(g)): a false declaration corrected spontaneously within 15 days is fined at one quarter of the normal fine and does not count for repeat offences.
- Several offences (art. 3): fines add up, but the total cannot exceed 10 times the largest operation.
- Procedure (arts. 5 to 9 and 16): the BCRA investigates and runs a summary proceeding that cannot exceed 360 business days from opening; the file then goes to the federal criminal economic court, which decides. Records must be kept for 10 years; the BCRA may limit inspections to operations within the previous 6 years (art. 5).
- Estimates (arts. 10 to 13): if records are missing, the BCRA may estimate the currency not settled, and may presume a link between exporter and foreign buyer when the declared price differs from the wholesale price at destination (art. 13(a)).
- Precautionary measures (art. 17): the BCRA may refuse FX authorisations, stop the processing of the exporter's shipping permits, suspend registrations, request a ban on leaving the country for persons under investigation (with fines of up to 3 times for each breach of the ban) and ask courts for asset freezes.
- Repeat offences count if the new offence is within 5 years of the previous final sentence (art. 18). The action prescribes in 6 years, interrupted by investigation steps known to the person and by new offences (art. 19).
14. Export duties: how they link to settlement
- Separate tax. Export duties tax exports for consumption (Customs Code art. 724). The rate is the one in force when the export declaration is registered (art. 726). Ad valorem duties are on the FOB value for sea and air shipments (art. 735). The Executive sets, removes or changes rates by decree (art. 755).
- Blend period. Under Decree 28/2023, art. 2, exporters paid the duty at the rate for their product "considering the exceptional value" of the 80/20 blend. DNU 269/2025, art. 1, second paragraph, keeps the duty payable at the applicable rate on the value under the restored regime.
- Duty cuts conditioned on settlement. Several 2025 decrees tied lower export duty rates to fast settlement:
- Decree 38/2025 (BO 27 January 2025), art. 2: reduced rates until 30 June 2025 for listed grains, available to exporters under Law 21.453 that settled at least 95% of the currency within 15 business days of the sworn foreign sale declaration (DJVE); otherwise the previous rate applied. Decree 439/2025 extended the reduced rates for some listed goods to 31 March 2026 (Infoleg note on Decree 38/2025, art. 2) (unconfirmed).
- Decree 682/2025 (BO 22 September 2025), arts. 1, 2 and 4: 0% duty on listed grains and by products until 31 October 2025 or until DJVE registrations reached USD 7,000,000,000, whichever came first, provided exporters settled at least 90% of the currency within 3 business days of the DJVE. Breach meant paying the full duty, plus sanctions, and losing the benefit until paid.
- Decree 685/2025 (BO 23 September 2025), arts. 1 and 2: 0% until 31 October 2025 for other listed goods, with 90% settled within 3 business days of the shipment permit. Whether the USD 7,000 million cap was reached and on what date is not in the sources (unconfirmed).
- Current rates by product are in the customs duties page of the taxes section (Decrees 526/2025, 877/2025, 423/2026 for grains; 305/2025, 563/2025, 811/2025, 566/2026 for 0% lists).
Step by step
A. Goods
- Classify the product. Find the NCM code. It sets the export duty (Customs Code art. 755 decrees) and the settlement term (FX rules, point 7.1.2). Check whether the buyer is related; the related party flag on the export declaration matters (points 7.1.2.3 and 7.5.4.2).
- Agree terms with the buyer that fit the deadline. A 180 day deadline cannot accommodate 240 day credit terms unless one of the extensions in point 7.5 applies (for example full prefinancing under point 7.5.2).
- Nominate the SECOEXPO bank when registering the export declaration with ARCA through the customs broker (point 8.2). Any authorised bank or exchange house that has not opted out of foreign trade must accept (point 8.2).
- If you receive an advance or prefinancing, settle it within 20 business days (point 7.1.3), ask the bank for an APX number and keep it for Section 9 tracking (point 7.3).
- Ship. Customs grants the cumplido de embarque; the clock starts (point 7.1.2).
- Send commercial documents to the tracking bank: invoice, contract or purchase order, documents showing the sale condition. Without them the bank cannot certify compliance (point 8.4.1).
- Collect and settle. When the buyer pays, sell the currency in the MLC within 20 business days and in any case by the deadline (point 7.1.1). Sign the sworn statement identifying the permits (point 7.2). If a different bank handles the settlement, ask it for a settlement certificate for the tracking bank (point 8.4.3.1).
- Claim other imputations: foreign bank charges, withholding taxes abroad, discounts, rejected goods (point 8.5), with documents.
- Ask for an extension before the deadline if a ground in point 7.5 applies.
- Obtain the cumplido certificate (point 8.4.4) and keep it; ARCA uses it.
- If the buyer does not pay, gather the evidence for point 7.6 and file it with the tracking bank, with an auditor's report where required.
- Report to the BCRA survey of external assets and liabilities if within its scope (point 1.9).
Who files: the exporter (and its broker for customs). Online or paper: the customs side is electronic through ARCA systems (unconfirmed); the bank side is handled through each bank's channels; the BCRA side is between banks and the BCRA. Official fees: none found in the sources; banks charge FX spreads and fees (unconfirmed).
B. Services
- Invoice the foreign client (unconfirmed).
- Collect into a local bank account or an account abroad.
- Decide which route applies: company with no exception (settle within 20 business days, point 2.2.1); individual (credit to own local dollar account, point 2.2.2.1); LEC beneficiary (certificate and special account, points 2.2.2.2 and 2.6); simultaneous application (point 2.7).
- Instruct the bank on the services concept code and sign the sworn statements required for the route.
- Keep evidence of the service, the invoice and the collection date for at least 10 years (Criminal Exchange Law, art. 5).
Costs and timelines
Table 1. Settlement deadlines for goods (FX rules, point 7.1.2, at 14 September 2026)
| Goods (NCM) | Buyer | Deadline from customs cumplido | Point |
|---|---|---|---|
| 1001.19.00, 1001.99.00 (wheat), 1003.90.10, 1003.90.80 (barley), 1005.90.10 (maize except popcorn), 1007.90.00 (sorghum), 1201.90.00 (soybeans), 1208.10.00, 1507.10.00, 1507.90.19, 1517.90.90 (with soy), 2304.00.10, 2304.00.90 (soy meal), chapter 27 except 2710.19.31, 2710.19.32, 2710.19.99 and 2716.00.00 | Any | 30 calendar days | 7.1.2.1 |
| Chapter 26 (ores) except 2601.11.00, 2603.00.90, 2607.00.00, 2608.00.10, 2613.90.90, 2616.10.00, 2616.90.00, 2621.10.00; chapter 71 (precious metals and stones) except 7106.91.00, 7108.12.10, 7112.99.00 | Any | 60 calendar days | 7.1.2.2 |
| All other goods | Related party | 60 calendar days (extendable for controlled subsidiaries, see below) | 7.1.2.3 |
| Chapters 42 (leather goods), 61 and 62 (clothing), 64 (footwear), 65 (headgear), 8401.40.00 (nuclear reactor parts) | Unrelated | 365 calendar days | 7.1.2.4 |
| All other goods | Unrelated | 180 calendar days | 7.1.2.5 |
| Any goods under "Exporta Simple" | Any | 365 calendar days | 7.1.2.6 |
| Any collection actually received | Any | 20 business days from collection, within the above maximum | 7.1.1 |
| Exports registered before 2 Sep 2019 | Any | 20 business days from collection | 7.1.6 |
Product descriptions in brackets are the editor's shorthand; the legal text lists only codes (unconfirmed).
Table 2. Other deadlines
| Item | Deadline | Source |
|---|---|---|
| Services export collections | 20 business days from collection or credit abroad | Point 2.2.1 |
| Advances, pre and postfinancing from abroad | 20 business days from collection or disbursement | Point 7.1.3 |
| Prefinancing and other financing from local banks | At disbursement | Point 7.1.4 |
| Sale of non produced non financial assets to non residents | 20 business days | Point 2.3 |
| Payment by a defaulting buyer after "incumplido en gestión de cobro" | 20 business days from availability | Point 7.6 |
| CNV promissory note proceeds (for application) | Settle within 72 business hours | Point 7.3.5.1 |
| Bank report of non compliant permit | 10 business days after deadline | Point 8.4.5 |
| Bank closes non compliance report after cumplido | 5 business days | Point 8.4.6 |
| Bank reports imputations other than settlement | 5 business days | Point 8.4.3 |
| Bank certificate to BCRA for point 7.9 debt | 90 calendar days after first inflow | Point 7.9.4 |
| Grain exporters under Decree 682/2025 (0% duty window) | 90% within 3 business days of DJVE | Decree 682/2025, art. 2 |
| Grain exporters under Decree 38/2025 (reduced rates) | 95% within 15 business days of DJVE | Decree 38/2025, art. 2 |
Table 3. Thresholds and percentages
| Threshold | Amount | Point or article |
|---|---|---|
| Former annual cap on individuals' services exception | USD 36,000 (removed 18 Sep 2025) | Former 2.2.2.1(iii); Com. A 8330, pt 1 |
| Exporter size for extending related party term (controlled buyer), exports from 1 Jan 2026 | USD 200,000,000 previous calendar year | 7.1.2.3(i)(a); Com. A 8417, pt 3 |
| Same, exports before 1 Jan 2026 | USD 50,000,000 | 7.1.2.3(i)(b) |
| Unpaid via insurer or recovery agency, no lawsuit | USD 200,000 per non resident | 7.6.3.3 |
| Unpaid via documented claims, no lawsuit | USD 100,000 per calendar year | 7.6.3.4 |
| External auditor report required (7.6.3.2, 7.6.3.4, 8.5.3) | Above USD 25,000 | 7.6; 8.5.3.4 |
| Revisable prices extension: minimum imputed | 85% of provisional FOB | 7.5.5.1 |
| Guarantee accumulation cap | 125% of debt service, current month + 6 months | 7.5.3; 7.8.5.1 |
| Knowledge economy retention | 30% of increase vs same quarter of 2021 | 2.6.2.1; Decree 679/2022, art. 8 |
| Decree 234/2021 application | 20% of permit; 25% of gross investment per year | 7.10.2 |
| RIGI goods exemption, strategic projects | 0%, 20%, 40%, 100% after 0, 1, 2, 3 years | 14.1.1 |
| RIGI goods exemption, other projects | 0%, 20%, 40%, 100% after 0, 2, 3, 4 years | 14.1.2 |
| Ship's stores collected locally | USD 2,000,000 per month per local agent | 8.5.18.4 |
| Blend (repealed) | 80% MLC, 20% securities | Decree 28/2023, art. 1 |
| Decree 443/2023 shipments | Up to 25% imputable if rest settled by 30 Sep 2023 | 8.5.19 |
Table 4. Penalties under the Criminal Exchange Law (t.o. 1995)
| Situation | Penalty | Article |
|---|---|---|
| First offence | Fine up to 10 times the operation | 2(a) |
| First repeat offence | Prison 1 to 4 years, or fine 3 to 10 times | 2(b) |
| First repeat offence where first fine was 3 times or less | Prison 1 month to 4 years | 2(d) |
| Second repeat offence | Prison 1 to 8 years and maximum fine | 2(c) |
| Accessory | Disqualification up to 10 years as importer or exporter; suspension or cancellation of FX licences | 2(e) |
| Company liability | Company fined; fine joint with individuals involved | 2(f) |
| Spontaneous correction of false declaration within 15 days | One quarter of the fine; no repeat offence effect | 2(g) |
| Several offences | Sum of fines, capped at 10 times the largest operation | 3 |
| Breach of a ban on leaving the country | Fine up to 3 times the operations investigated | 17(b) |
| Prescription | 6 years | 19 |
| Repeat offence window | 5 years | 18 |
Table 5. Timeline of norms
| Norm | Date | Effect |
|---|---|---|
| Law 19.359 | BO 10 Dec 1971 | Criminal Exchange Regime |
| Decree 480/1995 | BO 25 Sep 1995 | Consolidated text 1995 of Law 19.359 |
| Law 27.444, art. 132 | BO 18 Jun 2018 | Replaces Decree 260/2002 art. 1 (free exchange market) |
| DNU 609/2019 | BO 1 Sep 2019 | Restores export settlement obligation |
| BCRA rules effective | 2 Sep 2019 | SECOEXPO tracking for exports registered from this date (points 7.1.1, 8.1) |
| Decree 91/2019 | BO 28 Dec 2019 | Replaces Decree 609 art. 1, removes 31 Dec 2019 limit |
| Decree 234/2021 | 2021 | Investment for exports regime (point 7.10) |
| Decree 576/2022 and follow up decrees (787/2022, 194/2023, 378/2023, 443/2023, 492/2023) | Decrees dated 4 Sep 2022 to 30 Sep 2023 (DNU 269/2025 recitals) | "Programa de Incremento Exportador": special export exchange treatments for listed products (unconfirmed) |
| DNU 549/2023 | BO 23 Oct 2023 | Blend for all goods and services: 70% MLC, 30% securities, until 17 Nov 2023 (art. 1) |
| DNU 597/2023 | BO 21 Nov 2023 | Extends Decree 549 to 10 Dec 2023 with 50% MLC, 50% securities (arts. 1 and 2) |
| DNU 679/2022 | BO 11 Oct 2022 | Knowledge economy export FX incentive (Chapter II) |
| DNU 28/2023 | BO 13 Dec 2023 | Blend: 80% MLC, 20% securities, for goods and services, no end date (art. 1) |
| Decree 38/2025 | BO 27 Jan 2025 | Duty cuts, 95% settlement in 15 business days condition |
| Com. A 8191 | 10 Feb 2025 | Consolidated text with blend and USD 36,000 cap |
| DNU 269/2025 | BO 14 Apr 2025 | Repeals Decree 28/2023; end of blend |
| Com. A 8226 | 11 Apr 2025, effective 14 Apr 2025 | Broad FX easing; drops 90 day statements for individuals |
| Com. A 8307 | 25 Aug 2025 | Consolidated text without blend |
| Com. A 8330 | 18 Sep 2025 | Removes USD 36,000 cap; no commissions on individuals' inflows; chapter 27 deadline wording |
| Decree 682/2025 | BO 22 Sep 2025 | 0% grain duty window with 90% settlement in 3 business days |
| Decree 685/2025 | BO 23 Sep 2025 | 0% for other listed goods with 90% in 3 business days |
| Com. A 8417 | 9 Apr 2026 | Individuals' goods exception; all service concepts; USD 200 million threshold; 365 days for chapters 42, 61, 62, 64, 65 |
| Com. A 8441 | 21 May 2026 | CNV promissory notes as admitted application |
| Com. A 8481 | 14 Sep 2026 | Consolidated text used for this page |
BO dates for BCRA communications are not listed; the dates shown are the dates of issue on each communication.
Worked examples
Example 1: a USD 500,000 goods export
All facts are hypothetical. The official rate of ARS 1,530.00 is an assumption (unconfirmed); the MEP rate of ARS 1,563.90 is from some secondary summaries (unconfirmed). Business day counts below skip only weekends; Argentine national and bank holidays push the dates later (unconfirmed).
Facts. An Argentine SA manufactures machinery parts (an NCM code in chapter 84, not in any special list) and sells them to an unrelated distributor in Germany for USD 500,000 FOB, shipped by sea. Terms: 30% advance (USD 150,000) paid on 15 October 2026; 70% balance (USD 350,000) payable 90 days after shipment. The SA nominates its main bank for SECOEXPO when the export declaration is registered.
Step 1. Which deadline? Chapter 84, unrelated buyer: general case, 180 calendar days (point 7.1.2.5).
Step 2. The advance. Received 15 October 2026 (Thursday). It must be settled within 20 business days (point 7.1.3): counting weekends only, by 12 November 2026 (unconfirmed). The bank assigns an APX number (point 7.3). Pesos received: USD 150,000 × 1,530.00 = ARS 229,500,000.00 (USD 146,748.51 at MEP).
Step 3. Shipment. Customs grants the cumplido on 2 November 2026 (Monday). 2 November 2026 + 180 days = 1 May 2027, a Saturday, so the deadline moves to the next business day, Monday 3 May 2027 (point 8.4.2).
Step 4. Applying the advance. The bank tracking the advance issues a certificate of application, and the tracking bank imputes USD 150,000 to the permit (points 7.3 and 8.4.3.2). Outstanding: USD 350,000.
Step 5. The balance. The buyer pays on 15 January 2027 (Friday). The SA must settle within 20 business days of collection (point 7.1.1): counting weekends only, by 12 February 2027, well before 3 May 2027 (unconfirmed). The German bank deducts USD 150 in charges [hypothetical], so USD 349,850 arrives. The USD 150 counts as imputed because it is a foreign bank charge in the collection (point 8.5.2). Pesos received: USD 349,850 × 1,530.00 = ARS 535,270,500.00 (USD 342,266.45 at MEP).
Step 6. Cumplido. Imputations: 150,000 + 349,850 + 150 = USD 500,000. The bank issues the cumplido certificate (point 8.4.4).
Step 7. Official rate versus MEP. What the SA receives in pesos, before bank fees, compared with the peso value of the same dollars at the MEP rate:
| Item | USD | ARS at official ARS 1,530.00 | ARS at MEP ARS 1,563.90 | Difference ARS | Difference in USD at MEP |
|---|---|---|---|---|---|
| Advance | 150,000.00 | 229,500,000.00 | 234,585,000.00 | 5,085,000.00 | 3,251.49 |
| Balance (gross) | 350,000.00 | 535,500,000.00 | 547,365,000.00 | 11,865,000.00 | 7,586.80 |
| Total | 500,000.00 | 765,000,000.00 | 781,950,000.00 | 16,950,000.00 | 10,838.29 |
With these assumed rates the official market pays about 2.2% less than MEP (1,563.90 ÷ 1,530.00 − 1 = 2.22%). The real gap on the settlement date must be measured that day (unconfirmed). The gap is the economic incentive that the settlement rule removes; it is not a legal option.
Step 8. Historical comparison: the blend. (For reference, the October and November 2023 versions used 70/30 and 50/50 splits: DNU 549/2023, art. 1; DNU 597/2023, art. 2.) Had the same export been shipped between 13 December 2023 and 13 April 2025, Decree 28/2023 would have let the SA settle 80% (USD 400,000) in the MLC and channel 20% (USD 100,000) through securities sold for pesos. Using today's assumed rates purely as an illustration: 400,000 × 1,530.00 = ARS 612,000,000.00, plus 100,000 × 1,563.90 = ARS 156,390,000.00, total ARS 768,390,000.00, about ARS 3,390,000 more than full settlement. The real gain at the time depended on the gap then, which was far larger (DNU 269/2025 recitals mention a gap above 170% in December 2023).
Step 9. What if the SA kept the balance abroad? If by 3 May 2027 USD 350,000 is still not imputed, the bank must report the permit as non compliant by about 17 May 2027 (10 business days, point 8.4.5) (unconfirmed). The exposure for a first offence is a fine of up to 10 times the operation (Criminal Exchange Law, art. 2(a)): up to USD 3,500,000, that is ARS 5,355,000,000.00 at the assumed official rate or ARS 5,473,650,000.00 at MEP, plus possible disqualification as an exporter for up to 10 years (art. 2(e)), and joint liability of the directors involved (art. 2(f)). The BCRA could also stop processing the company's shipping permits as a precautionary measure (art. 17(a)(3)). How the fine is converted to pesos is not settled in the sources: art. 4 refers to the Banco Nación selling rate on the day of the offence, but in the context of updates only to 31 March 1991 (unconfirmed).
Step 10. Export duty. Many industrial NCM codes are at 0% after the 2025 and 2026 decrees (see the customs duties page). If the code carried an illustrative 5% duty, the duty would be 5% × USD 500,000 FOB = USD 25,000, ARS 38,250,000.00 at the assumed official rate (ARS 39,097,500.00 at MEP), assessed at the rate in force when the declaration is registered (Customs Code arts. 726 and 735).
Cost to do it. BCRA fees: none found. Bank costs: FX spread and fees on ARS 764.8 million of settlements (unconfirmed). Customs broker and documentation (unconfirmed). Time: up to 180 days of exposure per shipment, plus a few days of bank processing for the cumplido. Capital: none required by the FX rules.
Example 2: a software services exporter billing USD 20,000 a month
Hypothetical facts. Same rate assumptions and caveats as Example 1.
Facts. Monthly invoices of USD 20,000 to a US client for software development, paid by transfer around the 5th of each month. Annual billing: USD 240,000. Three alternative structures are compared.
Structure A: an SAS with no special regime. Each collection must be settled within 20 business days (point 2.2.1). A payment received on Thursday 5 November 2026 must be settled by 3 December 2026 (weekends only) (unconfirmed).
| Period | USD | ARS at official ARS 1,530.00 | ARS at MEP ARS 1,563.90 | Difference ARS | Difference in USD at MEP |
|---|---|---|---|---|---|
| One month | 20,000.00 | 30,600,000.00 | 31,278,000.00 | 678,000.00 | 433.53 |
| One year | 240,000.00 | 367,200,000.00 | 375,336,000.00 | 8,136,000.00 | 5,202.38 |
Variant with simultaneous application. The SAS pays a foreign cloud provider USD 2,000 a month, a service import for which it could buy dollars in the MLC under the services payment rules (unconfirmed). Under point 2.7 it can leave USD 2,000 of each collection in its local dollar account and apply it at the same time to that payment, with a sworn statement, settling only USD 18,000. It saves the round trip spread on USD 2,000 a month but must meet all of points 2.7.1 to 2.7.4 and the 90 day statements that point 3.16.3 requires for the outflow.
Structure B: the same developer working as an individual. Since Com. A 8330 (18 September 2025) there is no cap, and since Com. A 8417 (9 April 2026) all service concepts qualify. If the USD 20,000 is credited within the normal terms to the developer's own foreign currency account at a local bank, nothing has to be sold (point 2.2.2.1). The bank books two FX tickets with no pesos, may not charge a commission and may pass on only documented foreign bank charges at cost (points 2.2.2.1 and 2.8). The developer keeps USD 240,000 a year in dollars. The exception requires the result to be fiscally neutral: income tax, social security and the simplified regime (monotributo) still apply in full, measured in pesos (unconfirmed). If the developer sets up a company later, Structure A applies.
Structure C: an SAS registered as an LEC beneficiary. Assume collections settled in the MLC were USD 30,000 in the first quarter of 2021 and USD 60,000 in the first quarter of 2027. The increase is USD 30,000; 30% is USD 9,000 (point 2.6.2.1; Decree 679/2022, art. 8). The nominated bank issues a certificate for up to USD 9,000 for that quarter after checking BCRA data. The SAS keeps USD 9,000 in the special Decree 679/22 account and uses it to pay dollar salaries to registered staff on promoted activities; it settles the other USD 51,000.
| Item | USD | ARS at official ARS 1,530.00 | ARS at MEP ARS 1,563.90 |
|---|---|---|---|
| Settled | 51,000.00 | 78,030,000.00 | 79,758,900.00 |
| Kept in special account for payroll | 9,000.00 | not converted | 14,075,100.00 equivalent |
| Quarter total | 60,000.00 | 93,834,000.00 equivalent |
Note the circularity: the base is collections settled through the MLC in the 2021 quarter and the current quarter (point 2.6.2.1). A company that did not export in 2021 has a zero base and can use 30% of its full current settled collections; one that exported more in 2021 than now gets nothing (unconfirmed).
Cost to do it. Structure A: no BCRA fee; bank spread on ARS 367.2 million a year (unconfirmed). Structure B: no commission allowed (point 2.8); foreign charges at cost. Structure C: LEC registration costs and obligations (see the knowledge economy page), one nominated bank, quarterly certificates, a special account, sworn statements and the 90 day securities restrictions. Time: registration takes months (unconfirmed).
Example 3: a buyer default
Hypothetical. An exporter shipped USD 80,000 of wine to an unrelated importer that stopped paying. No lawsuit was filed, but the exporter sent registered letters and emails. Its total unpaid permits registered in the calendar year are USD 80,000, below the USD 100,000 limit of point 7.6.3.4. Because the amount exceeds USD 25,000, the bank also needs an external auditor's report on the receivable, its provision and the collection steps (point 7.6). With that, the bank reports the permit as non compliant (point 8.4.5) and also sends the "incumplido en gestión de cobro" certification (point 8.4.7). If the importer pays USD 80,000 later, the exporter has 20 business days to bring it in (point 7.6). At the assumed official rate that is ARS 122,400,000.00 (USD 78,265.87 at MEP). Whether the special status protects the exporter fully from Criminal Exchange Law proceedings is not stated in the text (unconfirmed).
Practical traps
- The 20 business day rule bites early payers. A 180 day deadline does not let you park early collections abroad for 180 days. Settlement is due 20 business days after collection (point 7.1.1).
- CIF and CFR sales. The obligation covers the invoiced value under the agreed sale condition, not only FOB (points 7.1.1 and 8.4.1). Freight and insurance collected from the buyer must be settled too, unless you claim an admitted imputation.
- Mixed shipments. One permit, one deadline: the product with most FOB value decides (point 8.4.2). Splitting shipments by product can avoid putting a 180 day product on a 30 day clock.
- Related party flag errors. A wrong related party declaration cuts the term from 180 to 60 days; the bank can extend if it confirms the error (point 7.5.4.2), but customs data must be corrected with ARCA (point 8.3).
- Changing the tracking bank too late. You can only change it before the deadline expires (point 8.2.1).
- Advances repaid without exports. If the export fails, repayment of an advance is treated as a financial loan repayment (point 7.7), with its own conditions.
- Individuals' exception is personal. It does not cover exports by an individual on behalf of a company (point 7.1.5(i)), and the account must be in the individual's own name at a local bank (point 2.2.2.1(i)). Receiving into a foreign account or a third party's account does not qualify.
- Fiscal neutrality. Keeping dollars under points 2.2.2.1, 7.1.5 and 2.7 must not change the tax result. Invoices and income must be declared as if settled.
- MEP and CCL trades block official access. A company that sells securities for dollars or moves securities abroad cannot buy in the MLC for 90 days and must sign forward looking promises (point 3.16.3).
- False sworn statements. Every exception rests on a sworn statement. A false one is an offence under Criminal Exchange Law art. 1(c), with a quarter fine only if corrected within 15 days (art. 2(g)).
- Directors are exposed personally. Fines are joint with the directors and managers who took part (art. 2(f)), and the BCRA may ask for a travel ban (art. 17(b)).
- Payment processors. Collections through processors count only if the processor settles in the MLC and credits pesos to the exporter's local account, with a settlement certificate (points 7.2.3 and 8.5.16).
- LEC benefit and the 2021 base. The 30% is of the increase over 2021, not of total exports (point 2.6.2.1). Growth in 2021 lowers the benefit.
- Duty cuts with settlement strings. Missing a 3 day or 15 day settlement condition under a duty decree means paying the full duty and losing the benefit (Decree 682/2025, art. 4; Decree 38/2025, art. 2).
- Records. Keep FX records for 10 years (Criminal Exchange Law, art. 5); the action prescribes in 6 years (art. 19).
Recent changes
- 23 October to 10 December 2023. DNU 549/2023 (70/30, to 17 November 2023) and DNU 597/2023 (50/50, to 10 December 2023) apply a securities blend to all goods and services exports.
- 13 December 2023. DNU 28/2023 reintroduces the blend at 80/20 for goods and services exports, with no end date (art. 1).
- 27 January 2025. Decree 38/2025 cuts duties, conditioning reduced grain rates on settling 95% within 15 business days of DJVE (art. 2).
- 10 February 2025. Com. A 8191 consolidated text still shows the blend and the USD 36,000 individuals' cap with listed service codes.
- 14 April 2025. DNU 269/2025 repeals the blend (BO 14 April 2025). Com. A 8226 (effective 14 April 2025) eases FX access and drops the 90 day statements from the individuals' services exception (point 4).
- 25 August 2025. Com. A 8307 consolidated text without the blend.
- 18 September 2025. Com. A 8330 removes the USD 36,000 cap, bans commissions on individuals' inflows and rewords the 30 day fuels list.
- 22 and 23 September 2025. Decrees 682/2025 and 685/2025: temporary 0% duties with 90% settlement within 3 business days.
- 9 April 2026. Com. A 8417: individuals' goods exception; all service concepts for individuals; USD 200 million threshold for controlled subsidiaries; 365 days for chapters 42, 61, 62, 64, 65 and 8401.40.00.
- 21 May 2026. Com. A 8441: CNV promissory notes as admitted application and settlement exception.
- 14 September 2026. Com. A 8481 consolidated text, which moved the deadlines into point 7.1.2.
Pending changes
- No announced end of the settlement obligation. Decree 609/2019 art. 1 remains transcribed in point 15.2 of the 14 September 2026 text. No source shows a decision to abolish it (unconfirmed).
- Communications after A 8497. A 8498 onward were not available on 26 October 2026 (probe note). Check for new CAMEX circulars before relying on this page (unconfirmed).
- Congressional review of DNU 269/2025 and other DNUs (unconfirmed).
- Constitutional challenge to criminal sanctions based on BCRA regulations (Law 19.359 art. 1(f)) (unconfirmed).
- Holiday counting. The FX rules use "días hábiles" without defining them in the parts reviewed (unconfirmed).
- Rates. The official rate for 23 October 2026 (unconfirmed).
- ARCA links. Which ARCA payments depend on the BCRA cumplido (point 8.4.4) (unconfirmed).
- Earlier special programmes. Percentages and scope of Decrees 576/2022 to 492/2023 were not reviewed (unconfirmed). Decrees 549/2023 and 597/2023 were checked (70/30 and 50/50).
FAQ
1. Do I still have to convert my export dollars into pesos? Yes, for companies, unless an exception applies. Goods: within the product term and 20 business days of collection (points 7.1.1 and 7.1.2). Services: within 20 business days (point 2.2.1). Individuals may keep them in their own local dollar account (points 2.2.2.1 and 7.1.5).
2. Is the "dólar blend" still available? No. DNU 269/2025 repealed Decree 28/2023 from 14 April 2025 (arts. 1 and 2). Only operations done while it was in force use the transitional rules (points 7.3.9, 7.5.2, 8.5.20).
3. Is there a minimum amount below which a company need not settle service exports? No threshold appears in point 2.2.1. The only threshold was the USD 36,000 cap on the individuals' exception, removed by Com. A 8330.
4. Can a freelancer keep all their dollars? Yes, if credited within the terms to their own foreign currency account at a local bank and the result is fiscally neutral (point 2.2.2.1). No cap since 18 September 2025; all service concepts since 9 April 2026.
5. Can I keep the dollars in an account abroad? Not as a way to comply. The exceptions require a local account in your name (points 2.2.2.1, 7.1.5, 2.7.2). Funds collected abroad must come in and, for companies, be settled within the terms.
6. What is the deadline for soybean exports? 30 calendar days from the cumplido for 1201.90.00 and the listed soy products (point 7.1.2.1), and 20 business days from collection if earlier.
7. Can I pay my foreign suppliers with export dollars instead of selling them? Yes, under point 2.7, if the payment itself would have access to the MLC, it is done simultaneously within the settlement term, the funds stayed in a local dollar account, and you sign the sworn statement.
8. What if my buyer never pays? Ask the tracking bank to record "incumplido en gestión de cobro" with the evidence in point 7.6 (lawsuit, insolvency, exchange controls, insurance, or documented claims within the USD 100,000 or USD 200,000 limits), plus an auditor's report above USD 25,000. Not available for related parties except for exchange controls abroad.
9. What are the penalties? Up to 10 times the amount for a first offence; prison of 1 to 4 years or 3 to 10 times for a first repeat offence; 1 to 8 years for a second; disqualification as exporter up to 10 years; joint liability of directors (Criminal Exchange Law, arts. 2 and 3).
10. Do export duties depend on settlement? Generally no; they are due at the rate in force when the export declaration is registered (Customs Code art. 726). But some reduced rates were conditional on fast settlement (Decrees 38/2025, 682/2025 and 685/2025).
11. Does a RIGI project have to settle its exports? Partly, in decreasing percentages: a strategic export project keeps 20% after 1 year, 40% after 2 and 100% after 3 years from start up (point 14.1.1); services from start up are fully exempt (point 14.1.3).
12. Can I change the bank that tracks my shipment? Yes, at will, before the settlement deadline expires (point 8.2.1).
13. Do foreign bank charges count against my obligation? Yes. For goods, charges debited by foreign banks in the collection are an admitted imputation (point 8.5.2). For services, usual foreign bank charges count as settled (point 2.2.1).
Published 27 Oct 2026 from our research draft. Points marked (unconfirmed) have not yet been checked line by line against the official text; rely on the primary sources linked below before acting, and expect this page to change as we verify it.
Primary sources
- BCRA, consolidated text "Exterior y Cambios" updated to 14 September 2026 (Com. A 8481), points 1.1 to 1.9, 2.1 to 2.8, 3.16.3, 7.1 to 7.10, 8.1 to 8.6, 9.1, 14.1, 15.1, 15.2
- BCRA Com. A 8191 (10 February 2025), consolidated text with blend and former point 2.2.2.1
- BCRA Com. A 8226 (11 April 2025)
- BCRA Com. A 8307 (25 August 2025)
- BCRA Com. A 8330 (18 September 2025)
- BCRA Com. A 8417 (9 April 2026)
- BCRA Com. A 8441 (21 May 2026)
- BCRA probe of A 8482 to A 8510, 26 October 2026
- DNU 609/2019, updated text
- DNU 28/2023, text and record
- DNU 269/2025, text and record
- Law 19.359, Criminal Exchange Regime, t.o. 1995 by Decree 480/1995 (arts. 1 to 5, 8, 10 to 13, 17 to 19
- DNU 679/2022, Chapter II, arts. 8 to 11
- Customs Code, Law 22.415, arts. 724, 726, 735, 755
- Decree 38/2025, art. 2
- Decree 682/2025, arts. 1 to 4
- Decree 685/2025, arts. 1 and 2
- DNU 549/2023 (BO 23 October 2023), art. 1, and DNU 597/2023 (BO 21 November 2023), arts. 1 and 2 (; Infoleg records reached from the Decree 28/2023 links list)
- Infoleg search for Decree 28
Related pages
- Do I have to convert service export dollars into pesos?
- FX and capital controls: current rules
- Exchange controls: access to the official FX market, dividends and capital repatriation
- BOPREAL: the BCRA bonds for importers and dividend arrears
- Paying dividends and profits abroad: FX access, taxes and timing
- Foreign debt registration and access to the FX market for loans
- Argentina's exchange rate regimes from Convertibility to 2026
- Paying for imports and foreign services under Argentina's FX rules
- Live dólar hoy: MEP, CCL, blue and the brecha