Argentina

Written by:Alberto RubioMaría Florencia Labarile On June 1, 2026, Executive Order No. 407/2026 (Order) was published in Argentina’s Official Gazette, implementing regulations for various provisions of the Employment Contract Law No. 20,744 (LCT), as amended by the Labor Modernization Act No. 27,802, in addition to regulations governing collective bargaining (Law No. 14,250), trade union organizations (Law No. 23,551), temporary staffing agencies (TSA), and construction industry registration (Law No. 22,250). The Order took effect on the date of its publication. Below, we offer a summary of the Order and highlight its key provisions. LCT Section 52: Employment registration The registration obligation required by the Order is fulfilled exclusively through enrollment and termination in the Customs Collection and Control Agency’s (ARCA) systems. Such registration is sufficient for all legal purposes. The obligation to maintain employment books – whether in physical or digital form – is eliminated; no administrative authority may impose additional requirements. LCT Section 140: Pay slip The pay slip must be structured in four clearly differentiated sections that identify: 1) data of the employer and the employee; 2) employer contributions and payroll charges; 3) gross remuneration and deductions; and 4) net remuneration. The document must include a summary of total labor cost sorted into the following categories: union fees, social security, health coverage (obra social), National Institute of Social Services for Retirees and Pensioners (INSSJP), Workers’ Compensation Insurance (ART), employer chamber contributions, and other items. Each line item must specify the computation base, unit of measurement, and resulting amount. LCT Sections 103 bis and 105: Fringe benefits and in-kind compensation Employer-provided meal benefits (Section 103 bis, para. (a)) must be furnished or directly funded by the employer and may not be substituted for or commuted into cash. The monthly cap is 40 percent of the prevailing Minimum Living Wage (SMVM). For in-kind compensation (Section 105, para. (b)), the applicable maximum is set at five percent of the employee's annual gross remuneration. LCT Section 210: Illness monitoring and medical certificates Medical prescriptions indicating rest leave must be issued electronically through platforms registered with the National Register of Electronic Prescriptions (ReNaPDiS) and signed by professionals enrolled in the Register of Health Professionals (REFEPS). Paper-based certificates with handwritten signatures are permitted only where lack of digital connectivity is demonstrated. Where an irreconcilable discrepancy exists between the initial diagnosis and the employer's medical review, the parties may resort to (a) an official medical panel in jurisdictions that have established such a mechanism or (b) an opinion from institutions registered with the Federal Registry of Healthcare Facilities (Ministry of Health Resolution No. 1,070/2009) with at least five continuous years of standing. LCT Sections 240 and 241: Resignation and mutual termination Concerning resignation (Section 240), the Secretariat of Labor, Employment, and Social Security (STEySS) will issue complementary regulations to implement the procedure for formalizing resignations before the labor administrative authority, including registration and verified notice to the employer. For mutual termination (Section 241), termination agreements submitted to the administrative authority may be ratified pursuant to Section 15 of the LCT, following verification of legality, absence of consent defects, and adequate accommodation of the parties' interests. LCT Section 252: Retirement notification The National Social Security Administration (ANSES) must implement an electronic notification system to inform both employers and agents of the National Health Insurance System of the commencement and completion of retirement proceedings, enabling timely awareness of the grant of the retirement benefit and allowing each party to make the relevant decisions regarding the employment relationship and health coverage. Law No. 14,250 and Executive Order No. 199/88: Collective bargaining Concerning employer representation (new Section 2), employer associations and business chambers are entitled to participate in collective bargaining provided that they demonstrate representation of at least ten percent of workers within the relevant scope. In multi-jurisdictional agreements, up to two additional employer-side representations may be admitted. Condominium-owner associations may be represented by the grouping associations to which they belong. For obligatory clauses and the Section 9 cap (new Sections 6 and 6 bis), the concept of an obligatory clause encompasses all contributions, dues, withholdings, funds, or economic charges benefiting the signatory parties or affiliated entities, regardless of denomination. The Section 9 cap is computed globally across all charges, and the computation base is the applicable conventional basic wage for the relevant job category. Agreements currently in force that exceed the cap must be restructured; those exceeding it as of the Order's effective date will discharge the obligor up to that limit. Agreements exceeding the cap will not be ratified or registered, while contributions within the cap are mandatory only for companies affiliated with the signatory entities (pursuant to Executive Order No. 149/2025). For the purposes of Section 137 of Law No. 27,802, collective bargaining agreements whose stated term has expired (Section 4) are deemed to have lapsed. Those lacking an express expiration date will be treated as expiring on December 31, 2026. STEySS is required to initiate the renegotiation convocation procedure within 30 days of the Order's effective date. Law No. 23,551 and Executive Order No. 467/88: Trade union organizations The Order mandates that the size of governing bodies must bear reasonable proportion to the number of dues-paying members. In addition to the membership register, an association may demonstrate dues-paying membership through union fee invoices, pay slips showing union dues withheld, or employer-issued certifications. The Competent Authority will cross-check the membership list against Integrated Argentinian Pension System (SIPA) records; material discrepancies will preclude satisfaction of the legal requirement. To replace an existing registered union, the Order requires the petitioning association to exceed the incumbent's dues-paying membership by at least five percent. The administrative authority must issue a decision within 45 days. Union time-off credits must be exercised upon 48-hour advance notice in a manner compatible with the establishment's operational continuity and without affecting critical sectors; credits may not be accumulated or transferred. In addition, the protection afforded under Section 50 of the Trade Union Act is enforceable against the employer only from the moment the association formally notifies the candidacy; protection ceases upon failure to officially list the candidate or if the candidate receives fewer than five percent of valid votes cast. An employer may seek judicial suspension of the protected employee's work activity where a potential hazard exists to persons, assets, or the effective operation of the business. Loss of coverage under the union's registration does not affect the personal protection afforded under Section 48, third paragraph of the Trade Union Act. Annex II: Temporary staffing agencies The Order revokes Executive Order No. 1,694/06 and enacts a new regulatory framework setting regulations for TSAs. A TSA is a legal entity whose exclusive purpose is to supply personnel to client companies for any economic activity. Under the Order, employment agreements with non-continuous workers must expressly identify the staffing modality. Workers deployed to client companies are engaged under a permanent non-continuous contract; those performing services at the TSA's own premises are engaged under a permanent continuous contract. Gap periods between assignments may not exceed 45 consecutive calendar days (extendable to 60 by agreement) or 90 alternating days per anniversary year. An employee is not required to accept a posting located more than 30 km away from their place of residence (or 50 km away by agreement at commencement of the relationship). Minimum remuneration must be no less than the applicable statutory and/or collectively agreed minimums, nor less than the compensation paid to permanent employees of the client company in the same job category and seniority. The Order authorizes the use of a TSA in the event of an absence of permanent staff, a statutory or collectively agreed leave or suspensions, an increase in extraordinary activity (including technology adoptions), urgent accident-prevention or repair work, and, generally, extraordinary or transient needs outside the company's ordinary course of business. In addition, the Order limits the ratio of temporary to permanent staff. Registration for authorization to use a TSA can be made electronically and at no cost with STEySS. If there are no objections, authorization becomes effective after 15 business days. Successful registration guarantees 1) a principal guarantee of 14,000 UVA units, applicable to all TSAs; and 2) a scaled supplemental guarantee of 100 UVA units per each additional worker between 31 and 100 employees, and 75 UVA units per worker when there are more than 100 employees. The Order designates the following permitted instruments: UVA-indexed cash deposit, government securities, real property security interest, bank guarantee, or surety bond. Annual adjustments are made based on UVA value and a sworn statement of headcount. Law No. 22,250: Construction industry registration Enrollment, termination, and modification of employment data for construction-industry workers must be filed with ARCA pursuant to the procedures and technological means it establishes. The Order establishes ARCA’s record as the authoritative record of registration, thereby excluding the Institute of Statistics and Registry of the Construction Industry’s (IERIC) registration competence. ARCA has 120 days to adapt its systems and implement the information exchange with the IERIC; the IERIC will act as a transitional relay channel until full implementation. Other amendments and repeals Concerning digital-platform workers (Section 3), the Secretariat of Transport of the Ministry of Economy is designated as the Competent Authority for the Mobility and Delivery Services Regime (Title XII, Law No. 27,802), while STEySS retains jurisdiction over collective bargaining agreements in the sector. Family allowances for agricultural workers covered by Sections 16 and 17 of the Agricultural Labor Act No. 26,727 are unified with the general framework under Section 1(a) of Law No. 24,714. The following are repealed: Sections 9 and 12 of Executive Order No. 199/88; Sections 6, 7, 8, and 11 of Executive Order No. 301/13 (Regulation of Law No. 26,727); and Executive Order No. 1,694/06 (TSA regulations). For more information, please contact the authors.   Leer este artículo en español.

Written by:Marcelo EtchebarneMartín MittelmanJoaquín Eppens EchagüeAugusto Nicolás MancinelliRichard Chesley The Milei Administration recently submitted to Congress a bill titled Ley de Régimen de Incentivo para Grandes Inversiones en Nuevas Industrias (Súper RIGI), which aims to promote investments exceeding USD1 billion. The Súper RIGI expands on existing, similar legislation (RIGI), increasing investment size from USD200 million to USD1 billion, and granting tax, labor, foreign exchange (FX), and other benefits to both foreign and domestic investors. This alert provides a snapshot of the original RIGI pipeline – approved projects, projects pending approval, and major investments announced but not yet formally filed – and a summary of key terms from the Súper RIGI. Original RIGI: Pipeline status as of May 2026 The original RIGI (Law No. 27,742; regulated August 2024) offers a minimum USD200 million-investment threshold across strategic sectors with a 30-year tax, customs, and FX stability. The adhesion window was extended by Decree 105/2026 to July 8, 2027. As of May 2026, 16 projects have been approved (approximately USD30 billion) and 22 projects are pending approval (approximately USD68 billion), for a total formal pipeline of approximately USD95 billion. Net FX inflows through March 2026 totaled USD762 million – a fraction of committed amounts, reflecting the long construction timelines. Minister Luis Caputo's oft-cited figure of USD140 billion includes the formal pipeline plus major projects announced but not yet filed, principally YPF's LNG project with ENI and XRG and Chevron's Vaca Muerta expansion. Approved projects: Sixteen projects totaling USD30 billion YPF Luz – El Quemado Solar Park (USD211 million; Mendoza). Photovoltaic park with 305 MW installed capacity.   Vaca Muerta Oleoducto Sur (VMOS) (USD2.4–2.9 billion; Neuquén, Río Negro). Oil pipeline consortium: YPF, PAE, Vista, Pampa, Pluspetrol, Chevron, Shell. Capacity of up to 700,000 barrels per day.   Southern Energy – GNL Pampa del Castillo (USD6.8–15.1 billion over 20 years, Río Negro). Floating LNG-export facility; PAE, Golar LNG, YPF, Pampa Energía, and Harbour Energy. First export is expected by 2027.   Salar de Rincón (USD2.7–2.74 billion; Salta). Río Tinto lithium project, estimated to produce 60,000 metric tons per year of battery-grade lithium.   Sidersa – Steel Plant (USD286 million; San Nicolás, Buenos Aires). Estimated to produce 360,000 metric tons per year of green long steel products.   Parque Eólico Olavarría (USD276 million; Buenos Aires). PCR/ArcelorMittal Acindar.   Hombre Muerto Oeste (HMW) (USD292 million; Catamarca). Galán Lithium.   Los Azules (USD2.3 billion; San Juan). McEwen Copper; large-scale copper mining.   Agua Rica (MARA) (USD3.8–6.7 billion; Catamarca). Glencore; copper and gold mining.   Carbonatos Profundos (DCP) (USD519 million; San Juan). MASA-SD; gold and silver mining.   Terminal Multipropósito Timbúes (USD277 million; Santa Fe). Port infrastructure expansion.   PSJ Cobre Mendocino (USD891 million; Mendoza). First copper export from Mendoza province.   Veladero Expansion (USD380 million; San Juan). Barrick/Shandong Gold.   Diablillos (USD760 million; Salta). AbraSilver; gold and silver.   Cauchari-Olaroz Expansion (USD1.2 billion; Jujuy). Lithium Americas/JEMSE. Projects pending approval: Twenty-two projects totaling USD68 billion The following projects have been formally filed and are currently under evaluation by the enforcement authority. Where investment figures have been publicly disclosed, they are included. Mining Proyecto Vicuña (USD9.7 billion; San Juan). BHP/Lundin; integrates the Josemaría and Filo del Sol copper deposits. 25-year mine lifespan.   El Pachón (USD11.6 billion; San Juan). Glencore; copper. Projected to create 12,000 jobs.   Plata Grande/Bajo del Choique–La Invernada (USD12.2 billion; Neuquén). Pluspetrol; oil production of up to 100,000 barrels per day plateau.   Pozuelos Pastos Grandes (USD4.2 billion; Salta). Lithea; lithium.   Sal de Oro II (USD845 million; Salta/Catamarca). Posco Argentina; lithium carbonate, hydroxide, and phosphate plant. Projected to create 2,335 jobs.   Sal de Vida (USD1.3 billion; Catamarca). Río Tinto (second project); lithium. Expected to create 1,404 jobs.   Cauchari-Olaroz Expansion II (USD1.2 billion; Jujuy). Minera Exar.   Litio Ángeles Argentina (USD726 million; Salta). Potasio y Litio de Argentina S.A.   Salterra Lithium (USD710 million; Catamarca). LIEX S.A.   Jama Solaroz (USD1.1 billion; Jujuy). CNGR Advanced Material; lithium.   San Jorge (USD630 billion; Mendoza). Minera San Jorge; copper.   Arenas de Cercanías (USD233 million; Río Negro). Minera del Mojotoro/Minera Orosmayo. Projected to create 2,050 jobs. Hydrocarbons and energy YPF LLL Oil – Vaca Muerta (USD25 billion; Neuquén). Filed May 15, 2026 and announced simultaneously by YPF CEO Horacio Marín. The project includes 1,152 wells; 240,000 barrels per day plateau by 2032; USD6 billion per year in exports; USD100 billion in exports over the project’s lifespan. The largest RIGI filing to date.   Proyecto RDA (USD4.5 billion; Neuquén). Pampa Energía; oil and gas development.   PAE – GNL Dedicated Pipeline (USD1.3 billion; Río Negro/Neuquén). Pan American Energy; dedicated gas export pipeline.   Los Toldos (USD6.3 billion; Neuquén). Tecpetrol; upstream oil and gas development.   Duplicar Norte + MEGA Expansion (jointly, USD740 million). Oldelval/MEGA; midstream.   Gasoducto Perito Moreno Expansion (USD550 million). Transportadora de Gas del Sur. Infrastructure and industry Pampa Fértil (USD2.4 billion; Bahía Blanca). Pampa Energía; largest fertilizer plant in Latin America. Gas industrialization project highlighted by Minister Caputo.   Parque Eólico La Rinconada (USD219 million; Buenos Aires). Tenaris; wind energy to supply the SIDERCA steel plant. Projected to create 809 jobs.   NCA Railway Expansion (USD200 million; multiple provinces). Nueva Central Argentino; freight rail infrastructure. This list reflects projects publicly identified as pending as of mid-May 2026. Several additional projects may be in the pipeline but have not been individually named in official or press sources. The USD68 billion aggregate figure is according to official Ministry of Economy data. Announced but not formally filed Argentina GNL (YPF / ENI / XRG) (approximately USD20 billion). YPF has stated it plans to file a RIGI application for the Argentina GNL project in partnership with Italian ENI and Abu Dhabi's XRG (formerly ADNOC) in the coming weeks. The project involves USD20 billion in infrastructure investment and USD10 billion in upstream well development, estimated to create up to 50,000 jobs at peak.   Chevron – Vaca Muerta Expansion (over USD10 billion; Neuquén). Announced at the Milken Conference meeting with President Javier Milei and Minister Caputo (May 7, 2026). Formal RIGI filing is expected imminently. These two projects account for the bulk of the difference between the formal USD95-billion pipeline and Minister Caputo's projection of USD140 billion in total committed RIGI investment. The Súper RIGI: Key Terms The Súper RIGI is a separate, complementary regime – not a replacement for the original RIGI – designed exclusively for projects in industries that do not currently exist in Argentina or exist only at a pilot or experimental scale. The bill (Mensaje No. 181/2026, signed by President Milei, Minister Caputo, and Chief of Staff Manuel Adorni) was sent to Congress on May 23, 2026. Eligible activities Projects must involve new industrial, technological, or strategic digital/technological infrastructure activities that are not currently developed or produced in Argentina. Target sectors include artificial intelligence, semiconductors, copper refining, lithium batteries, electric vehicles, data centers, solar and wind manufacturing, uranium processing, fertilizers, and advanced biotechnology. Expansions or modernizations of existing facilities are expressly excluded from the scope of the Súper RIGI. Eligible vehicles Projects must be structured through a Single Project Vehicle (VPU) with exclusive object and ring-fenced assets. Permitted structures include local stock corporations and limited liability companies (S.A.; S.A.U.; and S.R.L.), foreign branches registered locally under Art. 118 of the General Companies Law, joint ventures (UTEs), and other partnership agreements. Minimum investment and commitment schedule The minimum investment is USD1 billion minimum per project (compared to USD200 million under the original RIGI). At least 20 percent of the minimum must be invested within the first two years from the adhesion date (compared to 40 percent under the original RIGI). The application window is five years from regulation, extendable once by one year. Income tax VPUs pay a flat rate income tax of 15% (compared to 25% under the original RIGI and the 35-percent standard rate). Accelerated depreciation is available and includes movable assets in a minimum of two annual installments and infrastructure at 60 percent in the commissioning year, plus 40 percent over two subsequent years. Net operating losses may be carried forward indefinitely and transferred to third parties after 5 years. All tax losses and adjustments are indexed to CPI. Debit and credit tax 100% of bank debit and credit tax is creditable against a VPU’s income tax. Dividend withholding tax The dividend withholding tax is 7% during the first four years from adhesion; 3.5% from year four onwards (compared to year seven under the original RIGI). Social security New employment relationships from the adhesion date are subject to a flat employer contribution rate of 10% (vs. 20.4%–26.4% standard). This benefit is not available under the original RIGI. Value-added tax Value-added tax on computable asset purchases is offset through Tax Credit Certificates (Certificados de Crédito Fiscal), freely transferable if the Customs Collection and Control Agency (ARCA) fails to process refunds within 3 months. Customs duties There is full exemption from import duties; statistics tax; and all national, provincial, and municipal levies on plan-of-investment assets (including components physically integrated into fixed assets). In addition, there is full exemption from export duties on project products. A VPU may import and export freely without quotas, prior authorizations, or price measures. FX: Export proceeds 20% of foreign currency generated by VPU’s exports freely available from year 1; 40% from year 2; 100% from year 3 (vs. 100% from year 4 under the original RIGI). Capital contributions, external financings, and service payments are exempt from settlement requirements from the beginning. Legal stability Thirty years from the adhesion date in tax, customs, social security, and FX matters. Taxes in force at adhesion are frozen; future increases do not apply. Future decreases in the general regime apply. The burden of proving that a new measure does not increase the investor's tax burden falls on ARCA, not the investor. Guarantees The national government guarantees full availability of project outputs without mandatory domestic commercialization (under other local regimes guaranteeing supply to domestic market was mandatory; for example, gas exports), protection against confiscation or expropriation, uninterrupted project operation (absent prior judicial order with due process), and unrestricted access to justice. Provincial adherence National incentives only apply to projects in provinces (and municipalities) that expressly adhere. Adhering jurisdictions must 1) cap gross turnover tax (ingresos brutos) at 0.50%  (the single most distortive local tax is up to 5% of gross sales, not including income and applicable at each stage of the local supply chain), 2) exempt all VPU transactions from stamp tax (sellos), 3) waive all royalties and administrative canons, and 4) waive the pay-to-play requirement for VPU legal challenges. Once a province adheres, subsequent withdrawal does not affect previously approved VPUs. Arbitration Similar to the original RIGI, disputes are subject to a 60-day amicable negotiation period, after which the VPU may elect the Permanent Court of Arbitration, the International Chamber of Commerce (no abbreviated procedure), or International Centre for Settlement of Investment Disputes/Additional Facility arbitration. The seat must be outside Argentina in a country that is party to the New York Convention. Proceedings require three-member tribunals, none of which can be nationals of Argentina or of a VPU-controlling shareholder. No exhaustion of administrative remedies is required and there are no limitation periods on arbitral claims. Project rights are treated as protected investments under applicable bilateral investment treaties. Mutual exclusion with the original RIGI A VPU may not adhere to the Súper RIGI if it, or a controlled-group entity, has already filed under the original RIGI with a substantially overlapping project. Overlap is defined as sharing 50%  or more of capital expenditure, principal physical assets, or projected production capacity, or having the same value chain or final product. Importantly, the bill provides that corporate reorganizations, spin-offs, transfers, or other restructurings cannot be used to circumvent this exclusion; the enforcement authority may look through any such transaction and apply the overlap test to the economic reality of the project. OECD Pillar Two Art. 45 contains a self-limiting clause by which income tax incentives will not apply to the extent that their use would result in a transfer of Argentine fiscal revenues to foreign governments through any global minimum tax mechanism, including GloBE Income Inclusion Rules, Undertaxed Profits Rule, or analogues implementing Organisation for Economic Co-operation and Development (OECD)/G-20 Pillar Two. In practice, this means investors whose parent entities are subject to Pillar Two top-up taxes in their home jurisdiction will not receive the full economic benefit of the 15-percent rate – the Argentine incentive will simply be clawed back abroad. Each investor will need to model the net after-Pillar Two benefit of the Súper RIGI based on its specific global tax profile.   III. Key issues to monitor "New activity" definition. New activity will be determined by additional regulations and requires a sworn declaration, in addition to an independent technical report. How the enforcement authority treats sectors where some domestic capacity already exists – such as partial battery assembly or small-scale copper processing – is to be determined. Investors in those sectors are encouraged to monitor for future updates.   Provincial adherence. Unlike mining and hydrocarbon projects (where geology determines location), AI, data center, semiconductor, and advanced manufacturing projects are flexible in terms of their location. Competition among provinces to attract Súper RIGI projects by offering adherence and complementary local incentives will play a role that is not present under the implementation of the original RIGI.   Mutual exclusion overlap analysis. Companies with existing RIGI filings or controlled-group projects in related sectors must complete the 50% overlap test before filing under the Súper RIGI. As noted above, the test is designed to survive restructurings, therefore, investors should analyze the economic substance of their projects rather than relying on legal form.   OECD Pillar Two impact. As explained above, the 15% rate benefit may be partially or fully offset by Pillar Two top-up taxes for investors whose parent entities are in GloBE-implementing jurisdictions. This requires case-by-case modeling before adhesion.   Investment realization gap. Commitment figures significantly exceed actual disbursements. Net FX inflows through March 2026 were USD762 million against a total committed pipeline of around USD30 billion. The gap reflects long construction timelines, for example, the GNL Pampa del Castillo project's first export is not expected until 2027, and LLL Oil's production plateau is targeted for 2032.   Congressional approval. The bill requires passage through both chambers. Final terms – including the minimum investment threshold, eligible sectors, and provincial adherence conditions – may be modified during legislative debate. The government lacks a majority but has demonstrated the ability to build sufficient coalitions on an ad hoc basis with the Ley de Bases in 2024, the Labor Reform Act and the 2026 Budget, and by significantly increasing its congressional representation. Following the October 2025 midterms – in which La Libertad Avanza (Liberty Advances, or LLA) obtained over 40% of the national vote – LLA now holds approximately 88–92 seats in the Chamber of Deputies, the largest single bloc in the lower chamber, with the Propuesta Republicana (Republican Proposal, or PRO) contributing an additional 14. To pass legislation, 129 votes are required for a quorum majority; to sustain a presidential veto, 86 are required – a threshold LLA now clears on its own for the first time. In the Senate, Peronism has fallen to just 25 senators following a series of defections in early 2026, its smallest caucus since the return of democracy in 1983. LLA itself holds 20 Senate seats, up from seven before the midterm elections. The majority threshold in the Senate is 37 votes, which the government cannot reach on its own, making the provincial governors the decisive players; these include the Unión Cívica Radical (9 senators), PRO (6 senators), and Provincias Unidas (3 senators) blocs – most aligned with non-Peronist provincial administrations – which voted with the current administration on recent laws. Given that the Súper RIGI's provincial adherence mechanism directly channels large-scale investment projects to the governors who sign on, the political incentives for a negotiated approval are substantial. For more information on conducting business in Argentina, including the RIGI framework or the Súper RIGI bill, please contact Marcelo Etchebarne, Argentina's Managing Partner; Martin Mittleman, Deputy Managing Partner and leader of the Corporate practice; Joaquin Eppens Echagüe, Deputy Managing Partner and leader of the M&A practice; Augusto Mancinelli, leader of the Tax practice; or Richard Chesley, Co-Global Managing Partner.  

Following the enactment of Law N°27,739 on March 15, 2024, which designated the CNV as the regulatory authority for the crypto industry, the CNV issued General Resolution No. 994, which introduced a mandatory registry for Virtual Assets Service Providers (“VASPs”). On October 15, 2024, the CNV issued General Resolution No. 1025/2024, which proposed a comprehensive regulatory framework applicable to VASPs and opened a consultation process, which ended with the issuance of General Resolution No. 1058/2025 on March 12, 2025- The following is an overview of the key elements of the regulation: The VASPs Registry General Resolution No. 1058/2025 outlined the requirements and conditions for registration and the necessary documentation that both individuals and entities needed to submit to be included in the VASPs Registry. The regulation aimed to ensure proper oversight of VASPs and enhance regulatory compliance in line with anti-money laundering efforts. (a) Scope of the VASPs Registry The CNV's resolution established specific conditions for mandatory registration. Individuals and entities residing or established in Argentina who are directly engaged in VASP Services, are required to register in the VASPs Registry before conducting such activities. For foreign individuals and entities, the requirement to register applies if they perform VASP Services that are connected with Argentina. Registration is mandated if operations involve: (i) the use of a ".ar" domain, (ii) commercial agreements or subsidiaries receiving funds from Argentine residents for operations (ramp services), (iii) clear business focus or advertising directed at Argentine residents, not including cases where the client initiates contact with the legal entity established outside the Republic of Argentina (reverse solicitation), or (iv) a business volume in Argentina exceeding 20% of their total business volume (in which case only the total business volume related to the activities requiring registration in the VASPs Registry will be considered). Exemptions from registration are granted to VASPs if the total value of their activities or operations do not exceed the equivalent of 35,000 UVA per month (approx. US$44,275). In that regard, unregistered individuals and entities were prohibited from conducting VASP Services within Argentina. Foreign VASPs not registered in the VASPs Registry may participate as sponsors in international events held in Argentina, provided they meet certain conditions. (b) Disclosure requirements Registered entities are obligated to display a clear notice on their website, social media, and promotional materials indicating their registration status. This notice clarifies that registration was for oversight purposes only and does not imply licensing or supervision by the CNV over the VASP’s activities. Furthermore, registration in the VASPs Registry does not equate to a license to operate virtual asset activities, which will be subject to further regulation, as mentioned in section B. below. (c) Public offering of virtual assets The resolution clarifies that the CNV has the authority to exclusively regulate the activity of PSAVs, without extending such authority to the regulation of virtual assets, except when they fall under the definition of securities as established in Article 2 of Law No. 26,831. In that regard, PSAVs are prohibited from making any offering or intermediation that constitutes a public offering of virtual assets that qualify as securities, unless they have been granted public offering authorization by the CNV. However, the resolution lacks mechanisms to determine when a specified virtual asset is considered a security. (d) Effectiveness VASPs registered in the VASP Registry as of the effective date of General Resolution No. 1058/2025 (i.e., May 26, 2025), must comply with the following requirements: • VASPs must update and complete all documentation requested for the VASPs Registry, before July 1, 2025 (in the case of individuals), or before August 1, 2025 (in the case of entities). • VASPs organized as S.A.S. (simplified share companies), must convert to S.A. or S.R.L. types. • Foreign VASPs must prove their registration as a branch in Argentina (Article 118 of Law No. 19.550) before September 1, 2025. In cases where foreign VASPs decide to establish a company in the country (remaining as a foreign shareholder), the newly formed company must apply for registration in the VASP Registry before September 1, 2025. • All provisions established in the General Resolution 1058/2025, except for those specified in the preceding paragraphs, will be applicable to registered VASPs, starting on December 31, 2025. O’Farrell has a dedicated team of Virtual Assets laws and regulations lawyers, whose deal experience, business acumen, and regulatory insight can help guide clients through a wide range of sophisticated transactions and regulatory requirements. ayeeof.com.ar For more information contact: Sebastian Luegmayer Partner [email protected] Nicolas Fernández Madero Senior Counsel [email protected]  

Bruchou & Funes de Rioja y Clifford Chance LLP actuaron como asesores legales de Vista Energy Argentina S.A.U, subsidiaria de Vista Energy, S.A.B. de C.V. (“Vista Energy”), en la adquisición del 100% del capital social y los derechos de voto de Petronas E&P Argentina S.A. a Petronas Carigali Canada B.V. y Petronas Carigali International E&P B.V. (“Petronas”). Esta transacción representa un paso estratégico para Vista Energy en su crecimiento en Vaca Muerta, una de las formaciones de hidrocarburos no convencionales más prometedoras del mundo. A través de esta adquisición, Vista Energy consolida una participación del 50% en la concesión de hidrocarburos no convencional La Amarga Chica (operada por YPF S.A.), el segundo bloque de mayor producción en la ventana de crudo negro de Vaca Muerta, y asegura una capacidad significativa de evacuación de crudo en proyectos clave de infraestructura, principalmente destinados a exportación. La transacción involucró una estructura compleja ya que incluyó, entre otras, una combinación de diferentes formas y métodos de pago —incluyendo pagos al cierre, pagos diferidos y la emisión de ADSs— y la necesidad de acquisition financing a través de una línea de crédito de mediano plazo. La operación también requirió una sofisticada estrategia legal multijurisdiccional y una estrecha coordinación con equipos legales de México, Nueva York y el Reino Unido, abordando cuestiones regulatorias, societarias, de financiamiento e impositivas en todas estas jurisdicciones. El equipo de Bruchou & Funes de Rioja, liderado por el socio Nicolás Dulce y la senior associate Agustina Rocca, asesoró a Vista Energy en todos los aspectos de esta operación emblemática, con el apoyo de los asociados María Bourdieu, Josefina De La Torre, Santiago Cleti y Sofía Guevara Lynch. El equipo también incluyó al socio José Bazán y al senior associate Ramón Poliche (financiamiento de adquisiciones – Banking y Mercado de Capitales), la socia Florencia Angélico y el asociado Ezequiel Castello (Gobierno Corporativo), y el socio Pablo Muir (Impuestos). El equipo de Clifford Chance LLP (Londres) fue liderado por el socio Steven Fox y los asociados Olivia Higgs y Tom Masters; y su equipo de Nueva York fue liderado por los socios David Brinton y Carla Ruggero, reafirmando la experiencia de ambos estudios en transacciones complejas, de alto perfil y con alcance internacional en la industria del petróleo y gas. Adicionalmente, Vista Energy fue asesorada por Creel, García-Cuéllar, Aiza y Enríquez (México), liderado por el socio Carlos Zamarrón, el counsel Crisanto Sánchez Carrillo y los asociados Alejandro González Cruz y Juan Carlos Hernández Peláez; y por Cleary Gottlieb Steen & Hamilton LLP (Nueva York), liderado por el socio Manuel Silva junto con los asociados Rodrigo López Lapeña y Lara Gomez Tomei. El equipo legal interno de Vista fue liderado por Pablo De Michelis y Nicolás Marino, del equipo de Desarrollo de Negocios, y Rosario Maffrand, abogada in-house. Mayer Brown LLP asesoró a Petronas con un equipo liderado por el socio Pablo Ferrante junto con el socio Bob Palmer y las senior associates Federica Castro y Lucía Londoño. Petronas también fue asesorada localmente por Marval O’Farrell & Mairal, con un equipo integrado por los socios Francisco Macías, María Laura Bolatti Cristofaro, Soledad Riera, Bárbara Ramperti, Francisco Abeal, Luciana Virgile y los asociados María Virginia Canzonieri, Gabriel Fortuna, María Victoria Gonzalez y Gabriela Vidart Egaña. Con esta adquisición, Vista Energy se convierte en el mayor productor independiente de petróleo en Argentina, con una inversión acumulada de más de USD 6.000 millones desde 2018.