Fintech 2026

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

Public Offerings of Securities, Securities Markets and Exchanges The CML regulates public offerings of securities, securities markets and exchanges, and intermediar - ies operating in such markets; it also covers the public offering of term contracts, futures and options, their markets, clearing houses and intermediaries. Insurtech Insurtech activities fall under the general rules of Insurance Law No 17,418 (IL). 2.3 Compensation Models Compensation models vary from business to business and vertical to vertical. Businesses related to the payments vertical are usu - ally compensated through transactional commissions that are ultimately borne by the affiliated businesses. PSAVs frequently charge a fee for their services or include their earnings in the prices of the cryptocur - rencies that can be purchased or sold on their plat - forms. Businesses related to lending verticals are compen - sated through the interest rate charged to the bor - rower. It is important to mention that case law exists that limits the interest applicable to loans when such interest is deemed excessive. In regtech undertakings and the provision of IT, as well as blockchain and services to financial institutions and fintech companies, the compensation model is freely agreed between the parties (ranging from fixed amounts to variables per transaction). 2.4 Variations Between the Regulation of Fintech and Legacy Players While legacy players’ activity tends to be highly regu - lated and centralised mostly by the BCRA and the CNV, the regulation applicable to the fintech industry is more flexible and, as mentioned in 2.2 Regulatory Regime , there is no centralised regulatory framework governing the entire fintech ecosystem. Nevertheless, the BCRA and the CNV do issue specific regulations on most of the verticals.

( proveedores de servicios de créditos entre particu- lares a través de plataformas or PSCPPs). Equity crowdfunding is regulated by Entrepreneurial Capital Support Law No 27,349 (ECSL) and CNV Res - olution No 942/2022. PSAVs At an initial stage, PSAV businesses were regulated by the pre-existing general rules of the CCC, the CPL, the PDPL and the DSL, among others. In 2024, the regulation status of these businesses underwent a series of changes, among other things through the enactment of Law No 27,739 that modi - fied the AMLL, defined the concepts of AV and PSAV, designated the PSAVs as obligated entities before the Financial Intelligence Unit ( Unidad de Información Financiera or UIF), and created a PSAV Registry under the CNV. In this context, the CNV and UIF issued Res - olutions No 994/24 and 49/24, respectively, to regu - late the provisions of Law No 27,739. Subsequently, in 2025, the CNV issued Resolution No 1058/25, which went a step further, establishing the core principles and initial parameters applicable to the provision of PSAV services, including general rules of conduct and the definition of specific conditions under which PSAVs must carry out their activities, following a principles-based and risk-oriented approach. However, the CNV’s regulatory authority does not extend to the regulation of virtual assets themselves, except where such assets fall within the definition of negotiable securities, pursuant to the CNV’s origi - nal jurisdiction under Capital Market Law No 26,831 (CML). In this regard, in 2025 the CNV enabled the tokenisation of certain securities authorised for public offering through CNV Resolutions No 1069, 1081 and 1087 (see 1.1 Evolution of the Fintech Market ). Regtech Businesses Regtech businesses, the provision of computer ser - vices and innovations in the use of blockchain tech - nology are regulated by the CCC, the DSL and Intel - lectual Property Law No 11,723 (IPL).

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