ARGENTINA Law and Practice Contributed by: Santiago J. Mora, Nicolas Garfunkel, Milagros Caneda and May Steward, GPG Advisory Partners
This segment entered into a new implementation phase with the enactment of the National Securities Exchange Commission ( Comisión Nacional de Valores or CNV) Resolutions No 994 and 1058. This regulation builds upon Law No 27,739, which incorporated the definition of “virtual assets” ( activos virtuales or AVs) and “virtual asset service providers” ( proveedores de servicios de activos virtuales or PSAVs) into the legal framework, and designated the CNV as the competent authority for their registration, supervision, regulation and sanctioning. In this context, Resolution No 994 and, in particular, Resolution No 1058 established the initial regulatory principles applicable to PSAVs (focusing on information security and prudential standards, among others), and formalised the PSAV registry within the CNV, making prior registration a mandatory requirement for entities providing virtual asset services in or directed to Argentina. This regu - latory framework has been regarded by the industry as pragmatic, flexible and gradual. As of early Janu - ary 2026, 94 legal entities and two individuals were registered. In addition, in recent months, the CNV issued Reso - lutions No 1069, 1081 and 1087, which authorised the tokenisation of certain securities. This regime includes debt securities or participation certificates in financial trusts with public offering, whose underly - ing assets are mainly composed of real-world assets (RWAs), units of closed-end investment funds with public offering backed by RWAs, shares (including dual-listed shares), negotiable obligations, and Argen - tine Depositary Receipt (CEDEARS). The regime was implemented within a regulatory sandbox for a one- year period, with the possibility of subsequent review and adjustments. The trading of these tokenised securities is carried out by PSAVs duly registered with the CNV. Finally, there also has been progress in the area of open finance. In May 2025, Decree No 353/2025 was enacted, creating the Open Finance System ( Sistema de Finanzas Abiertas ), which allows individuals and legal entities to share information with financial insti - tutions registered with the BCRA, subject to express consent, with the aim of fostering credit development, competition and financial inclusion. The BCRA was designated as the authority in charge of implement -
ing and overseeing the system. In this regard, specific regulations to be issued by the BCRA are expected during the first months of 2026. Looking ahead, the fintech sector is expected to con - tinue growing and developing in the next 12 months, with an increase in the number of companies, trans - actions, customers and businesses. This is mainly because of the recent change of administration in the federal government, which leans towards promoting citizens’ liberties and freedom of choice in the market, and also because of the good projections in terms of macroeconomic regularisation. At the same time, the regulatory framework is expected to continue evolving and adapting, particularly as the current authorities have actively encouraged public-private dialogue to support these developments. 2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models In Argentina, the payments, crypto and lending verti - cals are the predominant business models. In the payments sector, competition between financial applications intensified and took on different forms. In the retail segment, differentiation focused on the incorporation of new products, promotions and dis - counts, while other platforms geared their strategy towards the institutional segment, offering solutions for companies that include international transfers. It should also be noted that the consolidation of user experience was a driver of growth in this vertical, along with trust, security and cybersecurity, which today serve as strategic differentiators to sustain the sector’s development, enhanced by the growing use of artificial intelligence (AI) for real-time fraud detec - tion, the automation of operational processes, and the reduction of friction in digital transactions. In the crypto vertical, most crypto-asset exchanges operating in Argentina allow their users to acquire various types of cryptocurrencies (including stable - coins), and provide access to decentralised finance (DeFi) products. Moreover, the BCRA is working on and advancing a plan that would allow banks to offer
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