On March 12, 2025, the CNV issued General Resolution No. 1058/2025, introducing adjustments to the VASP registry and establishing a comprehensive regulatory framework for these providers.
he key aspects of the regulation are presented below:
(a) VASP Registration
Individuals and legal entities residing or established in Argentina that provide VASP Services must register in the VASP Registry before starting their activities. For foreign individuals and legal entities, the registration requirement applies if they have a connection point with Argentina, according to the parameters set forth in the regulation. VASPs whose operations do not exceed 35,000 UVA per month (approximately USD 44,275) are exempted. Unregistered foreign VASPs may participate as sponsors in international events held in Argentina, provided they meet certain conditions.
(b) Local Establishment and Minimum Net Worth
VASP activities must be conducted through a corporation (S.A.), a limited liability company (S.R.L.), or a branch, in accordance with Article 118 of Law No. 19,550. VASPs must demonstrate a minimum net worth (“MNW”) by submitting their latest annual financial statements. If these statements are more than eight months old, an additional certification from an Independent Public Accountant confirming compliance with the MNW requirement must be provided. The required MNW for each category is as follows:
- Categories 1° (exchange between virtual assets and FIAT), 2° (exchange between one or more forms of virtual assets), and 4° (custody and/or administration of virtual assets or instruments enabling control over them): USD 150,000.
- Category 3° (transfer of virtual assets): USD 75,000.
- Category 5° (participation and provision of financial services related to the offering and/or sale of a virtual asset by an issuer): USD 35,000.
If the VASP has transacted less than USD 2,500,000 over the past 12 months for Categories 1°, 2°, and 3°, or maintained a volume below this threshold for Category 4°, the MNW requirement will be reduced by 50%.
(c) Reporting Obligations
VASPs must keep updated records of wallet addresses used for the custody of clients’ virtual assets. Within 15 calendar days after the end of each month, VASPs must submit information regarding the number of clients and transaction volumes. This information must be filed within 10 calendar days following the end of each month, starting in October 2025. Annually, VASPs must submit: (i) The annual system audit report, within 70 calendar days after the end of the fiscal year. (ii) A report from the Compliance and Internal Control Officer within the same timeframe. (iii) In the case of companies, audited Annual Financial Statements, within five days after filing with the Public Registry or within five days after the filing deadline, whichever comes first.
(d) Organizational Structure
VASPs must appoint a Compliance Officer, who must be a member of the board of directors, and a Public Relations Officer, responsible for handling customer inquiries, concerns, or complaints and reporting them to the board. VASPs must meet specific requirements regarding IT systems, cybersecurity, and asset custody. Only virtual assets launched within the last 90 days may be offered on their platforms or mobile applications, provided that a clear warning is included regarding their high volatility and risk of total loss. The IT systems used by VASPs for their activities must undergo an annual system audit. VASPs must provide the CNV with procedure manuals, a code of conduct, information security policies, and complaint management procedures. A VASP may enter into agreements with third parties, whether domestic entities authorized by the relevant regulatory authority or foreign entities, to integrate operations or delegate functions related to its activities.
(e) Effective Date
VASPs registered in the VASP Registry as of the effective date of General Resolution No. 1058/2025 (May 20, 2025) must comply with the following requirements:
- VASPs must update and complete all required documentation for the VASP Registry before July 1, 2025 (for individuals) or August 1, 2025 (for entities).
- VASPs established as S.A.S. must convert to an S.A. or S.R.L.
- Foreign VASPs must register as a branch in Argentina (Article 118 of Law No. 19,550) before September 1, 2025. If a foreign VASP decides to establish a company in the country while maintaining foreign shareholders, the new company must apply for registration in the VASP Registry before September 1, 2025.
All provisions of General Resolution No. 1058/2025, except those specifically mentioned above, will apply to registered VASPs as of December 31, 2025.
Access the complete text of the Resolution here.
This publication was prepared on the basis of information dated 02/13/2025 and does not constitute a legal opinion on specific issues. If necessary, expert legal advice should be sought.
For more information, please contact:
Sebastián Luegmayer – LuegmayerS@eof.com.ar