Fintech 2026

ARGENTINA Law and Practice Contributed by: Santiago J. Mora, Nicolas Garfunkel, Milagros Caneda and May Steward, GPG Advisory Partners

cryptocurrency purchase, sale and custody services, which could be announced during the first months of 2026. This measure would benefit not only banks but also PSAVs and other fintechs that develop ser - vices for businesses, as they could become traditional banks’ crypto partners. Regarding the lending vertical, this segment shows a relative lag due, among other factors, to the macroeco - nomic context inherited from previous years; however, it has shown a significant recovery in recent months, and further improvements are expected as the mac - roeconomic environment continues to stabilise and improve. The main challenge lies in deepening credit penetration. Participants in this segment consider that such progress can be achieved through, among other things, increased data availability – an aspect expect - ed to be driven by the new Open Finance measures (see 1.1 Evolution of the Fintech Market ) – and fully digital, end-to-end processes, which enable more efficient collection mechanisms and lower operating costs, as well as through enhanced financial educa - tion. In addition, there have been important new projects and start-ups in the regtech sector and in the provi - sion of IT services to financial institutions and fintech companies, as well as in the use of blockchain tech - nology. 2.2 Regulatory Regime There is no centralised regulatory framework govern - ing the entire fintech ecosystem in Argentina. Instead, there are separate regulations scattered throughout the legal system, with some issues receiving more detailed regulation than others. The following para - graphs review the key regulations that apply to the main fintech verticals. Payments Verticals Before 2020, e-money systems were not expressly covered by any specific regulation within the Argen - tine domestic legal framework; therefore, they were governed by pre-existing general rules, such as (among others): • the Civil and Commercial Code (CCC); • the Consumer Protection Law No 24,240 (CPL);

• certain aspects of the Credit Cards Law No 25,065 (CCL); • the Anti Money Laundering Law No 25,246 (AMLL) for certain business models; • the Personal Data Protection Law No 25,326 (PDPL); and • the Digital Signature Law No 25,506 (DSL). Many of these regulations continue to apply today, notwithstanding the specific regulations enacted in recent years. In 2020, the BCRA issued a series of communications aimed at regulating these businesses, which have been named PSPCPs, and implemented Transfers 3.0 ( Transferencias 3.0 ), an interoperability scheme between bank accounts and payment accounts that enables QR-code interoperability, and immediate set - tlement. Throughout the following years, the BCRA issued further regulation for payment service providers ( proveedores de servicios de pago or PSPs), incorpo - rating new roles (among others, initiation, acquiring, aggregation or sub-acquiring, and non-bank agen - cies that collect payment of taxes and/or services), and enacting rules that align the operation of pay - ment accounts issued by PSPCPs with that of bank accounts, as well as progressively establishing more stringent cybersecurity and digital fraud prevention requirements for all participants in the system. Lending Businesses Online lending businesses are mainly regulated by the CCC, as regular lending operations, in addition to the CPL, AMLL, PDPL and DSL. Also, in 2020 the BCRA amended the rules regarding “non-financial credit providers” ( proveedores no finan - cieros de crédito or PNFCs), making them mandatory for companies that, based on their last financial state - ments, granted credit in excess of ARS10 million and are not financial institutions. In addition, in 2021 the BCRA regulated crowdlend - ing businesses, which have been named “providers of credit services between individuals through platforms”

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