Argentina: Fintech Regulatory Developments 2025

The regulatory framework for Fintech in Argentina is undergoing rapid transformation, driven by the growing relevance of virtual asset service providers (VASPs), open finance initiatives, and tokenization. This article offers an overview of the current legal landscape, exploring how recent regulations and supervisory measures are shaping innovation, compliance, and market development in the local ecosystem.

1. VASPs.

Over the past decade, Argentina has emerged as one of the most dynamic crypto markets in Latin America. The country’s chronic inflation, currency restrictions, and growing technological literacy have driven citizens and firms toward digital assets as a store of value and alternative investment. This surge in adoption has created an urgent need for legal certainty and institutional oversight. The Argentine government, through the Comisión Nacional de Valores (CNV), is progressively developing a regulatory framework to integrate VASPs into the financial system.

Following the enactment of Law No. 27,739 in 2024, which introduced the definition of VASPs into national law, and CNV Resolution No. 994/2024, which created the VASP Registry in 2025, the CNV Resolution No. 1058 (the “VASP Resolution”) established a comprehensive regulatory structure governing VASP activities. Together, these instruments aim to align Argentina’s crypto regulation with international standards set by the Financial Action Task Force (FATF) and signal a clear policy intention to combine financial innovation with consumer protection and systemic stability.

Under Law No. 27,739, Section 4 bis, virtual assets are defined as “digital representations of value that may be traded and/or transferred digitally and used for payment or investment purposes”, and VASPs are defined as any natural or legal person that, as a business, performs one or more of five key activities related to virtual assets: (i) exchange between virtual assets and fiat currency; (ii) exchange between one or more types of virtual assets; (iii) transfer of virtual assets; (iv) custody or administration of virtual assets or instruments allowing control over them; and (v) participation or provision of financial services related to the offer or sale of virtual assets.

The VASP Resolution in Argentina requires all entities performing these activities –whether incorporated in Argentina or abroad with significant operations in Argentina– to register with the CNV prior to commencing business. This definitional framework harmonizes Argentina’s domestic legislation with FATF’s Recommendation 15, emphasizing the supervision of intermediaries who could facilitate money laundering or terrorist financing.

The VASP Resolution pursues multiple interrelated policy goals. First, it seeks to protect users and investors by ensuring that PSAVs meet prudential, transparency, and governance standards similar to those of traditional financial intermediaries. Second, it promotes market solvency and stability by imposing sound organizational and risk management requirements, thereby mitigating systemic vulnerabilities.

A central purpose is also to strengthen Argentina’s compliance with AML/CFT standards. The regulation incorporates FATF principles to prevent the misuse of digital assets for illicit finance, mandating comprehensive due diligence, record-keeping, and reporting mechanisms. Lastly, the CNV emphasizes cybersecurity and operational resilience, recognizing the high digital exposure of the sector.

Moving forward to an analysis of the key provisions of the VASP Resolution, the primary obligation for VASPs is to register with the CNV before conducting activities in Argentina. Foreign VASPs must either incorporate a local subsidiary or establish a permanent branch under Article 118. Registration is processed electronically through the Trámites a Distancia (TAD) platform, reflecting the government’s digital modernization initiative.

VASP entities must operate as either a Sociedad Anónima (S.A.) or Sociedad de Responsabilidad Limitada (S.R.L.), ensuring minimum governance standards as defined in the General Corporate Law. They must submit extensive documentation, including ownership structure, management composition, financial statements, and technical compliance reports to the CNV. The CNV may require periodic updates and impose sanctions for inaccurate or delayed information.

The VASP Resolution introduces detailed cybersecurity obligations, requiring VASPs to adopt policies guaranteeing confidentiality, integrity, and availability of information. They must establish secure backup systems, perform annual IT audits, and submit reports to the CNV describing security incidents and mitigation measures.

Each VASP must appoint a Compliance Officer responsible for ensuring adherence to applicable regulation, AML/CFT laws, and cybersecurity policies. VASP entities are required to maintain internal audit functions and board-approved procedures for data protection, operational continuity, and conflict management.

The CNV retains authority to inspect VASPs, require information, and impose administrative sanctions. It may suspend or revoke registration in cases of non-compliance. This supervisory framework extends the CNV’s traditional capital markets mandate into the virtual assets sector, only with regard to the provider of assets and not the assets themselves.

The VASP Resolution interacts closely with other regulatory instruments. Particularly, it complements Argentina’s Financial Information Unit (UIF) Resolution No. 49/2024, which describes anti-money laundering (AML) and counter-terrorist financing (CTF) duties for VASPs.

2. Open Finance.

Building upon the developments in the Fintech sector, Open Finance represents the latest evolution in the global trend toward financial data democratization. Building upon the foundations of Open Banking, which focuses primarily on enabling secure data sharing between banks and authorized third-party providers, Open Finance extends these principles to the entire financial ecosystem, and paves the way toward Open Data, a model in which individuals may grant access not only to financial information but also to data from other domains, including telecommunications and utilities, fostering a fully integrated digital economy.

Argentina’s pathway toward Open Finance has been gradual but consistent. Early regulatory steps came from the Central Bank (BCRA), which in 2021 and 2022 began promoting interoperability among payment service providers through initiatives such as transfer payments and the unification of QR systems. These measures introduced the principles of openness and data exchange within the payments ecosystem, which constituted an embryonic form of Open Banking. The recognition of Payment Service Providers Offering Payment Accounts (PSPCP) enabled non-bank entities to integrate into the financial system, catalyzing fintech competition. Parallel innovations such as DEBIN (Immediate Debit), CVU (Unique Virtual Account Number), and electronic checks (eCheq) have transformed transactional efficiency and user experience in the last years.

This evolution unfolded under Argentina’s broader digital finance framework, anchored in Law 25.326 on the Protection of Personal Data (2000). The law guarantees that personal and financial information can only be processed or transferred with the explicit consent of its owner, a principle that anticipates the user-centric approach of Open Finance in Argentina. Combined with the BCRA’s cybersecurity standards (including Communication “A” 8280), this legal foundation ensures that data sharing in financial services must respect privacy, integrity, and confidentiality. Together, these initiatives created the groundwork for the comprehensive Open Finance regulation formalized in 2025.

The Executive Power’s Decree No. 353/2025 (the “Open Finance Decree”), enacted on May 23, 2025, marked a decisive institutional milestone by creating Argentina’s Open Finance System. This decree authorizes individuals and legal entities, through explicit consent, to share financial data with institutions registered and supervised by the BCRA. This system aims to expand access to credit, enhance competition, and promote financial inclusion by allowing users (not institutions) to decide when and how to share their information. The Open Finance Decree appoints the BCRA as the enforcement authority, responsible for setting interoperability standards, technical protocols, and security parameters. It may also coordinate with other agencies to ensure effective implementation.

These provisions reflect the government’s broader policy objectives of administrative simplification, deregulation, and economic reactivation. By aiming to reduce friction and bureaucracy, the Open Finance Decree seeks to integrate the financial and fiscal spheres into a cohesive digital infrastructure. In essence, the Open Finance Decree positions Open Finance not only as a technological innovation but as an instrument for macroeconomic modernization.

A central tenet of the Open Finance Decree is the reaffirmation of data ownership. Users are recognized as the legitimate owners of their financial information, while financial institutions act merely as custodians. Data sharing can only occur through informed and revocable consent, in alignment with Argentina’s data protection regime. This framework requires clear mechanisms for consent management, defining what data may be shared, for what purpose, and for how long. The Open Finance Decree also underscores institutional accountability: entities receiving data are responsible for its proper use, storage, and security.

Cybersecurity and operational resilience are critical concerns. The BCRA’s existing regulatory instruments, particularly Communication “A” 8280, already demand adherence to ISO 27001 standards, incident response procedures, and third-party risk management. However, Open Finance introduces new vulnerabilities through expanded data flows and multiple interfaces. Effective governance will therefore require real-time supervision, harmonized API standards, and cross-institutional coordination to prevent breaches and fraud.

The implementation of the Open Finance Decree is expected to yield several benefits. First, it would advance financial inclusion by allowing individuals without traditional banking histories (particularly small and medium-sized enterprises) to build alternative credit profiles based on transaction and payment data. Second, it would stimulate innovation in savings, investment, and insurance products through personalized data analytics. Third, it would enhance consumer autonomy, enabling users to manage and monetize their own financial information. It also anticipated to improve competition by lowering entry barriers for fintechs and reducing information monopolies held by incumbent banks. Nevertheless, as data sharing expands, the goal should be a balanced model that ensures both innovation and protection of users’ personal information.

3. Tokenization.

Finally, in June 2025, the CNV introduced a pioneering framework for the tokenization of financial instruments through Resolution 1069 (the “First Stage Resolution”), followed by its expansions under Resolution 1081 (the “Second Stage Resolution”) and Resolution 1087 (the “Third Stage Resolution”). Together, these measures represent a decisive step in aligning Argentina’s capital market regulation with global financial innovation trends. Under Argentine law, tokenization refers to the digital representation of negotiable securities through distributed ledger technology (DLT) or equivalent systems, enabling the recording, transfer, and custody of assets in a decentralized manner. Rather than creating new classes of digital assets, tokenization under this regime provides an additional, technologically enhanced form of representing existing securities with public offering authorization.

The CNV’s motivation for these measures lies in the modernization of the domestic capital market, the promotion of financial inclusion, and the desire to strengthen Argentina’s position as a regional hub for digital finance. By incorporating DLT-based mechanisms within a legally secure and supervised environment, Argentina seeks to merge innovation with investor protection, offering a pragmatic model for the gradual integration of blockchain technology into traditional securities law.

This approach is supported by Argentina’s broader legal framework. The Capital Markets Law No. 26.831, appoints the CNV as the authority for regulating and supervising securities, ensuring that their issuance, registration, and trading comply with investor protection standards. The Productive Financing Law No. 27.440 promotes technological modernization within financial markets, while the Law No. 27.739 grants the CNV supervisory authority over VASPs. Together, these statutes empower the CNV to regulate DLT-based activities as extensions of the capital market, rather than as parallel ecosystems.

The First Stage Resolution establishes the first stage of Argentina’s tokenization framework, focusing on the additional digital representation of certain publicly offered securities. Its scope is deliberately narrow, covering debt securities, participation certificates from financial trusts, and units of closed-end investment funds whose underlying assets consist primarily of “real-world assets” (that is, tangible goods such as real estate, infrastructure, or other physical properties). This regulation explicitly excludes sustainability-linked bonds and securities issued under automatic offering regimes.

The CNV emphasizes four guiding principles for tokenization: security, traceability, immutability, and functional equivalence. These ensure that the digital representation of securities is technologically reliable while remaining legally indistinguishable from its traditional form. The use of DLT must guarantee that each transaction is auditable, tamper-proof, and transparent to relevant market participants.

Issuers seeking to tokenize their securities must obtain prior CNV authorization, disclosing the terms of the digital representation in their issuance documentation and on the Financial Information Highway (AIF). Tokenized instruments may coexist with their non-tokenized equivalents, allowing investors to request conversion between forms. The CNV adopts a neutral technological standpoint, meaning no specific blockchain or platform is mandated; instead, the focus is on compliance with functional and security benchmarks.

The First Stage Resolution introduces a “sandbox” regulatory environment, permitting experimentation with tokenization projects under CNV oversight. This model would allow the CNV to observe technological developments and market responses before expanding the framework’s reach. The regulation thus positions Argentina’s capital markets to evolve incrementally while aiming at minimizing systemic risks.

In August, the Second Stage Resolution was adopted, marking the second phase of Argentina’s tokenization program, expanding the types of eligible assets and formalizing the institutional roles of market participants. This new resolution extends tokenization to equity securities, such as shares, corporate bonds, and CEDEARs, as well as certain fund participation units.

A central innovation of this resolution is the incorporation of VASPs as authorized depositaries and custodians for digitally represented securities, under certain requirements, such as that VASPs implement custody mechanisms equivalent in safety to those used in conventional systems, protecting unplaced or blocked securities from unauthorized access.

Investor protection is reinforced through requirements for transparency, consultation mechanisms, and secure communication channels between VASPs and investors. The regulation stipulates that investors must be able to exercise rights, such as voting or redemption, through the digital platform in a manner that guarantees traceability and verifiability. At the same time, tokenized securities remain reversible: investors may at any point request the substitution of digital tokens for traditional instruments, preserving market flexibility.

However, this resolution maintains certain limitations. It excludes foreign sovereign debt from tokenization (except those issued by Mercosur countries and Chile) and continues to restrict sustainability-linked or green bonds.

In October, the Third Stage Resolution was issued, streamlining prior regulations and supporting financial innovation. It authorizes tokenizations under medium-impact automatic offering regimes or for frequent issuers of financial trusts, covering shares, corporate bonds, debt securities, and closed-end fund shares backed mainly by real-world assets. It requires prior CNV approval for digital representation when no prospectus is approved. Crucially, it removes the obligation to list securities issuances on traditional markets when fully digital, addressing concerns that listing requirements hinder tokenization and reinforcing CNV’s goal of modernizing Argentina’s capital markets through regulatory simplification and technological adaptation.

The Argentine tokenization framework inaugurated by the analyzed resolutions marks a significant advance in Latin America’s approach to digital finance. It establishes tokenization as a regulated extension of the existing securities system. In regional terms, Argentina’s initiative positions it alongside Brazil and Uruguay as a leader in DLT-based financial regulation. The framework promises to enhance financial inclusion by lowering issuance and custody costs, broadening access to investment opportunities, and facilitating secondary market liquidity. It also signals Argentina’s intent to attract fintech investment and become a hub for digital asset experimentation under regulatory supervision.