Argentina remains one of the most active cryptoasset markets in Latin America: according to Chainalysis’s The 2026 Geography of Crypto Report, it was the region’s second-largest crypto economy, behind Brazil, with USD88.5 billion in activity in the 12 months ending 30 June 2026 and growth of 15.3% on the previous period^[1]. Chainalysis links Argentina’s growth to the role of cryptoassets as an alternative to traditional financial services and as a means of accessing scarce foreign currency^[2].

The market relies heavily on US dollar stablecoins (mainly USDT and USDC). These are used as a store of value, for peer-to-peer and cross-border payments, for receiving income from abroad and, increasingly, for interest-bearing ‘earn’ products offered by local platforms. Chainalysis reports that, by June 2026, stablecoins accounted for 32.1% of cross-border crypto value and 22.1% of domestic peer-to-peer activity across Latin America, and that the number of Argentine wallets holding at least USD10,000 in stablecoins had risen by 82% since July 2024^[3].

On the supply side, the market is organised around virtual asset service providers (proveedores de servicios de activos virtuales or PSAVs) registered with the National Securities Commission (Comisión Nacional de Valores or CNV) under Law No 27739^[4] and CNV General Resolutions No 994/2024 and No 1058/2025 (see questions 2 and 5)^[5].

According to the Argentine Fintech Chamber (Cámara Argentina Fintech or CAF), 135 of the 939 fintech companies operating in Argentina are active in the crypto and blockchain vertical^[6]. In the CAF’s 2025 industry survey, 51% of participating companies identified tokenisation, and 46% blockchain, as strategic areas for their business^[7].

As of October 2026, financial entities and payment service providers offering payment accounts (PSPCPs) still cannot offer crypto services under Communications A 7506 and A 7759 of the Central Bank of the Argentine Republic (Banco Central de la República Argentina or BCRA) (see question 9)^[8].

Distributed ledger technology (DLT) is mostly being adopted in the following sectors:

(i) Capital markets: this is where adoption is currently most dynamic. Under the CNV’s tokenisation regime, securities may be digitally represented and traded through registered PSAVs. The regime was introduced in 2025 for financial trust securities and closed-end fund units and extended the same year to shares, negotiable obligations and Argentine depositary certificates (Certificados de Depósito Argentinos or CEDEARs), and to certain automatic public-offering regimes. General Resolution No 1150/2026 consolidated the list of tokenisable securities, added exchange-traded fund (ETF) units and exchange-traded product certificates, and extended the regulatory sandbox until 31 December 2027 (see question 8)^[9]. In August 2025, the CNV authorised the first public offering of tokenised financial trust participation certificates, under Landtoken’s programme^[10].

(ii) Agribusiness: the grain sector has been an early adopter, with private initiatives tokenising grain held in storage (Agrotoken is the best-known example^[11]). On the regulatory side, Decree No 640/2024 modernised the regime for certificates of deposit and warrants under Law No 9643 (the instruments issued by licensed warehouses over stored goods, which can be transferred or pledged)^[12]. It now allows them to be issued and traded electronically, including through DLTs^[13].

(iii) Public sector: Argentine Federal Blockchain (Blockchain Federal Argentina or BFA), a multi-stakeholder, non-profit permissioned network promoted by NIC Argentina and other public and private members, provides free timestamping. The Official Gazette timestamps its daily editions on BFA so that anyone can verify that published texts have not been altered^[14]. BFA is also used by, among others, the National Agri-Food Health and Quality Service (Servicio Nacional de Sanidad y Calidad Agroalimentaria or SENASA), the National Insurance Superintendency (Superintendencia de Seguros de la Nación or SSN), the Argentine Coast Guard (Prefectura Naval Argentina), the national education authority (for diplomas), the National Communications Agency (Ente Nacional de Comunicaciones or ENACOM) for open data, and the public procurement platforms ‘compr.ar’ and ‘contrat.ar’^[15]. At sub-national level, the Government of the City of Buenos Aires has integrated the QuarkID self-sovereign identity protocol, anchored on ZKsync Era, into its ‘miBA’ platform. From 1 October 2024, all active users of ‘miBA’ (more than 3.6 million) received a decentralised digital identity (DID) giving access to more than 60 digital documents and certificates^[16].

(iv) Corporate and registry uses: BFA has been used to timestamp the hashes of entries recorded in the digital corporate books of simplified joint-stock companies (sociedades por acciones simplificadas or SAS)^[17].

^[1] Chainalysis, ‘Latin America: Brazil Leads World in Adoption as Region’s Crypto Economy Grows’ (23 September 2026), chapter of The 2026 Geography of Crypto Report, https://www.chainalysis.com/blog/latin-america-crypto-adoption-2026/.

^[2] Ibid.

^[3] Ibid.

^[4] Law No 27739 (Official Gazette, 15 March 2024).

^[5] CNV General Resolution No 994/2024 (22 March 2024; Official Gazette, 25 March 2024), https://www.boletinoficial.gob.ar/detalleAviso/primera/305110/20240325; CNV General Resolution No 1058/2025 (12 March 2025; Official Gazette, 14 March 2025), https://www.boletinoficial.gob.ar/detalleAviso/primera/322539/20250314.

^[6] Cámara Argentina Fintech, ‘Industria Fintech Argentina 2025’, https://camarafintech.org/mapa-fintech-2025/. Including companies that provide services to the sector, the ecosystem comprises 1,027 companies.

^[7] Ibid.

^[8] BCRA Communication A 7506 (5 May 2022), https://www.bcra.gob.ar/Pdfs/comytexord/A7506.pdf; BCRA Communication A 7759 (4 May 2023), https://www.bcra.gob.ar/Pdfs/comytexord/A7759.pdf.

^[9] CNV General Resolution No 1150/2026, https://www.argentina.gob.ar/normativa/nacional/norma-426586/texto; CNV, ‘Ampliación del régimen de Tokenización’, https://www.argentina.gob.ar/noticias/ampliacion-del-regimen-de-tokenizacion-valores-negociables-con-oferta-publica-automatica-y.

^[10] LexLatin, ‘CNV de Argentina autoriza emisión de certificados de participación tokenizados’ (23 September 2025), https://lexlatin.com/noticias/cnv-argentina-autoriza-emision-certificados-participacion-tokenizados.

^[11] Agrotoken, https://landing.agrotoken.oaro.net/.

^[12] Decree No 640/2024 (July 2024), amending the regulations of Law No 9643, https://www.argentina.gob.ar/normativa/nacional/decreto-640-2024-401750/texto.

^[13] Ibid.

^[14] Blockchain Federal Argentina, ‘Sello de Tiempo 2.0’, https://bfa.ar/sello2.

^[15] Blockchain Federal Argentina, ‘Aplicaciones’, https://bfa.ar/bfa/aplicaciones.

^[16] Government of the City of Buenos Aires, ‘miBA con tecnología QuarkID’ (22 October 2024), http://buenosaires.gob.ar/innovacionytransformaciondigital/miba-con-tecnologia-quarkid-la-ciudad-de-buenos-aires-incorporo.

^[17] Blockchain Federal Argentina, ‘Caso de Uso Libros Digitales SAS’, https://www.argentina.gob.ar/sites/default/files/bfa_-_libros_digitales.pdf.

Currently, there is no comprehensive, technology-specific regulation of blockchain in Argentina. It is generally understood that the existing rules on digital documents and electronic and digital signatures —set out in the Digital Signature Law No 25506 (DSL) and in the Civil and Commercial Code (CCC)— are sufficient to enable its use (although, in practice, this should be reviewed on a case-by-case basis), while in certain cases there may be a pre-existing regulation that stipulates some requirement or process that is incompatible with this technology.

A significant portion of the relevant legislation stems from laws enacted by the National Congress: the DSL, the CCC, the warrants regime under Law No 9643, and Law No 27739. The latter amended the Anti-Money Laundering Law No 25246 (AMLL), and incorporated into the legal framework the definitions of virtual assets (VAs) —a digital representation of value that can be traded and/or transferred digitally and used for payments or investments. In no case shall legal tender in national territory or currencies issued by other countries or jurisdictions (fiat currency) be understood as a virtual asset— and of PSAVs — any natural or legal person that, as a business, carries out one or more of the following activities or operations for or on behalf of another natural or legal person: i. Exchange between virtual assets and legal tender (fiat currencies); ii. Exchange between one or more forms of virtual assets; iii. Transfer of virtual assets; iv. Custody and/or administration of virtual assets or instruments that enable control over them; and v. Participation in, and provision of, financial services related to an issuer’s offer and/or sale of a virtual asset. Law No 27739 also designated the CNV as the enforcement authority, granting it powers of oversight, regulation, inspection, supervision and sanction over PSAVs.

Much of the framework that applies derives mainly from the regulations issued thereunder by the competent agencies, in particular, by the CNV. As previously mentioned, through Decree No 640/2024, the Argentine government approved assets’ tokenisation by updating the warrant regime governed by Law No 9643. This update allows for the electronic registration and blockchain-based trading of warrants, authorises the use of electronic signatures to validate warrant transactions on the blockchain, and eliminates the requirement for depositors and warrant issuers to be officially registered.

In addition, the CNV issued General Resolutions No 1069/2025, 1081/2025, 1087/2025 and 1150/2026, which authorised the tokenisation of certain securities —including debt securities and participation certificates in financial trusts with public offering whose underlying 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, CEDEARs, exchange-traded fund (ETF) units and exchange-traded product certificates. The regime was implemented within a regulatory sandbox in force until 31 December 2027. Trading of these tokenised securities is carried out by PSAVs duly registered with the CNV.

Beyond these cases, the regulatory treatment of VAs will depend on their nature; the activities of PSAVs, in particular, are regulated in detail by CNV General Resolutions No 994/2024 and No 1058/2025, which make prior registration in the PSAV registry kept by the CNV a mandatory requirement for providing VA services in or directed to Argentina. By way of exception, individuals acting as PSAVs are relieved of the duty to register where their operations do not exceed 35,000 UVA^[1] per month. This threshold exemption does not extend to legal entities^[2].

As noted in question 1, financial entities and PSPCPs are currently prohibited from carrying out or facilitating their clients’ operations with VAs. However, the BCRA has indicated that it has on its agenda the lifting of the prohibition, a measure that would integrate blockchain technology into the traditional financial system^[3].

The consolidation of the CNV’s tokenisation scheme —currently transitional— into a permanent regime can also be anticipated. However, the enactment of a comprehensive cryptoasset law is not foreseen in the short term.

^[1] The unit of purchasing value (unidad de valor adquisitivo or UVA) is an inflation-indexed unit of account published daily by the BCRA. At the time of writing, one UVA was equivalent to ARS2,146.90, so the threshold amounted to approximately ARS75 million (around USD49,000 at the BCRA reference exchange rate).

^[2] CNV General Resolution No 1058/2025, Article 1.

^[3] F Meaños, ‘El fin del cepo abre la puerta para que el BCRA habilite a bancos y billeteras a vender criptomonedas’ [The end of exchange controls opens the door for the BCRA to allow banks and digital wallets to sell crypto assets], Infobae (20 April 2025), https://www.infobae.com/economia/2025/04/20/el-fin-del-cepo-abre-la-puerta-para-que-el-bcra-habilite-a-bancos-y-billeteras-a-vender-criptomonedas/; MJ Lanzi, ‘El Banco Central analiza permitir que los bancos operen con criptoactivos’ [The Central Bank considers allowing banks to operate with crypto assets], La Nación (5 December 2025), https://www.lanacion.com.ar/economia/IA/una-nueva-ola-de-adopcion-masiva-el-banco-central-trabaja-en-una-medida-para-permitir-que-los-bancos-nid05122025/.

Based on what has been set out throughout this questionnaire, progress in blockchain regulation has continued at a steady pace and the outlook appears favourable.

At the governmental and legislative level, this is reflected in the measures already described: Law No 27739, which incorporated VAs and PSAVs and designated the CNV as the competent authority, and Decree No 640/2024 on the electronic and tokenised warrant regime. Moreover, on 29 May 2026, a bill to replace the General Companies Law No 19550 (GCL), introducing decentralised autonomous organisations (DAOs) as a new entity type (see question 13), was sent to Congress, and is currently under discussion. Additionally, in July 2026, the Ministry of Deregulation and State Transformation published a draft deregulation bill —which has not yet been submitted to Congress— that would allow, among other things, mutual funds to invest in cryptoassets, recognise the legal validity of smart contracts, and enable the blockchain-based issuance, custody and trading of securities.

The CNV has arguably been the most active regulator. As previously mentioned, it established the PSAV framework and introduced the tokenisation regime through a regulatory sandbox, with the aim of fostering the development of blockchain-related projects —a framework that the industry has regarded as pragmatic, flexible and gradual. The Financial Information Unit (Unidad de Información Financiera or UIF), for its part, has regulated the anti-money laundering, counter-terrorist financing and counter-proliferation financing (AML/CFT/CPF) obligations of PSAVs under a risk-based approach aligned with Financial Action Task Force (FATF) standards (as set out in question 6).

By contrast, the BCRA appears to be taking a more cautious stance, while still maintaining the prohibition that prevents financial entities and PSPCPs from offering services related to cryptoassets, despite having indicated that repealing this ban is on its agenda.

As of October 2026, the BCRA has not publicly announced, piloted or put out for consultation any retail or wholesale CBDC, and its regulatory publications contain no CBDC-related rules.

In Argentina, there is no regime that treats cryptoassets as a single category; its legal treatment depends on its nature, function and characteristics.

On the one hand, when a cryptoasset qualifies as a security, it falls within the Capital Markets Law No 26831 (CML) and the CNV’s jurisdiction, and its public offering requires the corresponding authorisation (see question 10). Separately, securities may be tokenised —that is, digitally represented and traded on-chain through registered PSAVs— under the CNV’s securities-representation regime (see question 8).

On the other hand, when the cryptoasset does not qualify as a security, services related to it fall within the scope of the CNV’s PSAVs regime. As previously stated, PSAVs require prior registration with the CNV, and those registered are subject to prudential and conduct requirements under CNV General Resolution No 1058/2025. These include a minimum net worth of up to USD150,000; segregation of client assets, which may not be used for the PSAV’s own account; a code of conduct and procedural manuals; and the submission of audit, regulatory-compliance and internal-control reports, among other obligations. PSAVs may only list assets for which white paper-type information on the issuer and the project is available, with the corresponding risk warnings.

As indicated above, in the banking sphere, financial entities and PSPCPs remain barred from offering cryptoasset services.

When it comes to DeFi, the only express reference is found in CNV General Resolution No 1058/2025, which excludes from the PSAV definition (i) decentralised protocols that provide virtual asset services where there is no identifiable service provider, and (ii) persons that act exclusively as providers of self-custody wallets.

However, this is not a general exemption for every project that describes itself as DeFi. The PSAV definition is activity-based. Where an identifiable person or entity carries out an in-scope activity (for example, by operating a front end, holding custody or administering keys, intermediating, or providing services to issuers), its status as a PSAV must be reassessed. This is consistent with the FATF’s 2021 guidance, under which creators, owners, operators or other persons that maintain control or sufficient influence over a nominally decentralised arrangement may qualify as PSAVs^[1]. Purely non-custodial software, by contrast, would fall outside the perimeter.

Transfers to and from unhosted wallets are not prohibited. Instead, they are handled through the risk-based approach: PSAVs are expected to collect originator and beneficiary information from their own customers, assess wallet ownership and exposure (typically with blockchain analytics), and apply enhanced measures to transfers involving mixers, privacy-enhancing tools or high-risk counterparties.

^[1] FATF, Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers (October 2021), https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-rba-virtual-assets-2021.html.

For AML purposes, the key point is that PSAVs are reporting entities before the UIF (article 20(13) AMLL).

Question 2 describes the general framework for PSAVs, including the changes that Law No 27739 made to the AMLL, and the CNV’s registration and supervisory powers over PSAVs.

UIF Resolution No 49/2024 is the specific AML/CFT/CPF rulebook for PSAVs^[1]. Under it, PSAVs registered with the CNV must also register with the UIF as reporting entities^[2] and implement a risk-based prevention system^[3] covering: board-approved policies and procedures^[4]; a compliance officer^[5]; a documented, annual self-assessment of AML/CFT/CPF risks^[6]; customer and beneficial owner due diligence^[7]; ongoing transaction monitoring and analysis^[8]; independent external review^[9], staff training^[10] and record-keeping^[11]; suspicious transaction reports^[12]; and periodic systematic reports to the UIF^[13].

Beyond these general obligations, the resolution contains specific provisions on blockchain-based operations, peer-to-peer (P2P) transactions and self-custody wallets. It also incorporates the travel rule of the FATF^[14]. For operations abroad, PSAVs must apply the stricter of the Argentine or foreign rules, to the extent permitted by the laws and regulations of the foreign jurisdiction^[15].

Non-compliance with the PSAV regime exposes providers to the sanctions set out in Chapter I of Title IV of the CML (article 132), namely warnings, fines, disqualification, suspension and prohibition, and the CNV may revoke the PSAV’s registration in the exercise of its supervisory and sanctioning powers.

DeFi calls for a separate analysis. Neither the AMLL nor UIF Resolution No 49/2024 regulates DeFi protocols as such (see question 5).

^[1] UIF Resolution No 49/2024 (Official Gazette, 25 March 2024), https://www.boletinoficial.gob.ar/detalleAviso/primera/305109/20240325; UIF, ‘Resoluciones aplicables a cada Sujeto Obligado’, https://www.argentina.gob.ar/uif/normativa-uif/resoluciones-aplicables-cada-sujeto-obligado.

^[2] Ibid, Articles 2(v) and 42; UIF Resolution No 50/2011.

^[3] Ibid, Article 3.

^[4] Ibid, Article 10(d)–(e).

^[5] Ibid, Articles 8(r), 11 and 12.

^[6] Ibid, Article 5(c)–(d).

^[7] Ibid, Articles 8(d)–(e) and 21–30.

^[8] Ibid, Articles 8(k)–(l), 33 and 34.

^[9] Ibid, Article 19(a).

^[10] Ibid, Article 18.

^[11] Ibid, Article 17.

^[12] Ibid, Articles 8(m) and 36.

^[13] Ibid, Article 39.

^[14] Ibid, Article 37.

^[15] Ibid, Article 15.

Cryptoassets in Argentina are taxed under the general rules of each tax, according to the category into which they fall.

(i) Income Tax. Law No 27430 included ‘digital currencies’ among the objects of the tax (article 2(4)). What is taxed is the gain on their disposal —sale, exchange, or use as a means of payment—, together with periodic returns (such as staking or lending) and mining rewards.

For individuals and undivided estates, that gain is taxed under the schedular regime within income tax at a rate of 15% (the 5% rate reaches only gains in domestic currency without an adjustment clause); it allows a special deduction, the acquisition cost, and related expenses. Foreign-source gains are also taxed at 15%. For individuals, mere differences in market price are not taxed.

For legal entities there is no schedular regime: the gain forms part of the general tax base and is taxed at the progressive corporate rate, which may range from 25% to 35% depending on the amount of the fiscal year’s profits. The source of the income —Argentine or foreign— is not specifically resolved for cryptoassets, since the law looks to the domicile of the issuer, a criterion that is difficult to apply to assets without an identifiable issuer.

In the case of legal entities, the valuation difference on holdings is subject to the tax.

(ii) Personal Assets Tax. Law No 23966 does not mention cryptoassets. Nevertheless, the Revenue and Customs Control Agency (Agencia de Recaudación y Control Aduanero or ARCA) considers them to be covered, relying on the Opinion No 2/2022 of the Directorate of Tax Legal Advisory and Social Security Resources: as assets located in the country (article 19, subsection j), valued as of December 31 at their acquisition cost plus accrued interest, adjustments, and exchange differences (article 22, subsection h).

(iii) Value Added Tax (VAT). The sale or exchange of cryptoassets falls outside the scope of the tax, as they do not qualify as movable property within its object. Intermediation and related services (exchange or platform fees) are taxed at the general rate of 21%.

(iv) Tax on Credits and Debits. This tax (Law No 25413) falls on movements in bank accounts, not on the transfer of cryptoassets. However, for the bank accounts of PSAVs registered with the CNV that are used exclusively for the specific purpose of carrying out their activity, the tax could be exempt to the extent that the tax authority authorises it at the provider’s request.

(v) Reporting regimens: General Resolution No 4614/2019 requires exchanges and digital platforms to report their clients’ accounts and cryptoasset flows.

(vi) Turnover Tax (Gross Income Tax). As a provincial tax, it does not have uniform treatment; several jurisdictions —among them the City of Buenos Aires— tax the habitual purchase and sale of cryptoassets or related services, so the position must be assessed province by province.

As with anti-money laundering, DeFi calls for a separate analysis: there are no specific tax rules for decentralised finance, so the general rules apply according to the nature and substance of each operation. The main uncertainty is the legal characterisation of the arrangement —and hence the category and source of the income— where there is no identifiable provider (see question 5).

Tokenisation in Argentina is governed mainly by the CNV’s regime for the digital representation of securities, which is open to retail investors. This regime is set out in Title XXII (‘Tokenización’) of the CNV Rules and was built in stages:

1. General Resolution No 1069/2025^[1] allowed the tokenisation of debt securities and participation certificates of financial trusts, and of closed-end fund units, backed by RWAs.
2. General Resolution No 1081/2025^[2] extended it to shares (including dual-listed shares), negotiable obligations and Argentine depositary certificates (Certificados de Depósito Argentinos or CEDEARs).
3. General Resolution No 1087/2025^[3] admitted tokenisation under certain automatic public-offering regimes.
4. General Resolution No 1150/2026^[4] consolidated the list of tokenisable securities and added ETF units of open-ended funds and exchange-traded product certificates. It also allowed the tokenisation of shares, negotiable obligations, financial trust securities and closed-end fund units issued under any automatic authorisation regime, except those applicable to open-ended funds. Securities that qualify as social, green and sustainable securities or as sustainability-linked securities remain excluded^[5].

The model is deliberately hybrid rather than purely on-chain. It works as follows^[6]:

(i) Custody of the traditional securities. The securities must exist in their traditional form and be deposited with a central securities depositary. They are held in the name of one or more registered holders acting on behalf of investors. The registered holder may be a PSAV, a collective investment product management agent, a fund custodian or a comprehensive settlement and clearing agent^[7].

(ii) Generation of the tokens. A specialised DLT entity, which need not itself be a PSAV, generates the digital representation. It must use a standard that ensures security, immutability, verifiability, fungibility, integrity, transferability and traceability^[8].

(iii) Trading venues. Subscription, placement, trading and custody take place on the platforms of no more than five PSAVs designated in the issue documents. These PSAVs must be registered in all PSAV categories and keep their records synchronised in real time^[9].

(iv) Transfer restrictions. Tokens may not be transferred outside the participating PSAVs or to decentralised protocols, and smart contracts must block non-permitted transfers^[10].

The digital representation does not create a new security: it is an additional form of representing an existing one, with the same validity and functionality as the traditional form^[11].

Because the securities remain registered in the name of the registered holder, investors do not hold them directly: they exercise their rights through the PSAV, and the registered holder votes on the basis of their instructions^[12]. Investors may nonetheless obtain a holding certificate from the PSAV at any time, which has the effects of a book-entry security^[13], or request that the token be replaced by the traditional form. In that case, the PSAV blocks or burns the token^[14]. PSAVs may not dispose of or use tokenised securities for their own account^[15].

The regime includes several safeguards for retail investors: the issue documents must contain a specific chapter on the digital representation, including its technical features and risk warnings; PSAVs are liable for their placement, custody and digital-environment functions and must provide complaint mechanisms; and their advertising must use plain language that avoids technical jargon, so that investors understand the associated risks^[16].

As previously mentioned, the regime operates in a sandbox until 31 December 2027. After that date, the CNV will decide whether to extend, modify, expand, reduce or terminate it^[17].

Tokenising real estate outside the securities route faces structural hurdles under the CCC. Ownership of real property is transferred only through a public deed, followed by delivery of possession and registration with the relevant real estate registry for the transfer to be enforceable against third parties^[18]. A token is neither a public deed nor a registry entry, so transferring it does not transfer ownership of the property: at most, it gives the holder personal rights against the issuer or the vehicle that holds the property, not rights in rem over the property. Market practice therefore uses financial trusts, closed-end funds or corporate vehicles whose securities or units are tokenised.

On the wholesale side, there are currently no BCRA tokenisation initiatives, as financial entities remain barred from offering cryptoasset services (see questions 2 and 5).

^[1] CNV General Resolution No 1069/2025, published in the Official Gazette on 13 June 2025, incorporating Title XXII into the CNV Rules, https://www.argentina.gob.ar/normativa/nacional/resoluci%C3%B3n-1069-2025-414017/texto.

^[2] CNV General Resolution No 1081/2025, dated 20 August 2025 and published in the Official Gazette on 21 August 2025, replacing Chapter I of Title XXII of the CNV Rules, https://www.argentina.gob.ar/normativa/nacional/resoluci%C3%B3n-1081-2025-416670/texto.

^[3] CNV General Resolution No 1087/2025, published in the Official Gazette on 23 October 2025, https://www.boletinoficial.gob.ar/detalleAviso/primera/333326/20251023.

^[4] CNV General Resolution No 1150/2026, dated 10 June 2026 and published in the Official Gazette on 11 June 2026, amending Title XXII of the CNV Rules, https://www.argentina.gob.ar/normativa/nacional/norma-426586/texto.

^[5] CNV General Resolution No 1150/2026, Article 2 (replacing Articles 1 and 2, Section I, Chapter I, Title XXII, CNV Rules), https://www.argentina.gob.ar/normativa/nacional/norma-426586/texto.

^[6] Ibid, Articles 3 and 5 (replacing Articles 5 and 14, Title XXII).

^[7] CNV Rules, Title XXII, Chapter I, Article 5(a)–(c) (as replaced by General Resolution No 1150/2026, Article 3).

^[8] Ibid, Articles 5(d), 10(a) and 14, second paragraph (as replaced by General Resolution No 1150/2026, Articles 3, 4 and 5).

^[9] Ibid, Articles 5(e) and 14, first paragraph.

^[10] Ibid, Article 5(f).

^[11] Ibid, Articles 7 and 8.

^[12] Ibid, Article 15.

^[13] Ibid, Articles 18 and 28.

^[14] Ibid, Articles 16 and 17.

^[15] Ibid, Article 31.

^[16] Ibid, Articles 12(c), 23 and 33.

^[17] Ibid, Article 38 (as replaced by General Resolution No 1150/2026, Article 9).

^[18] Civil and Commercial Code, Articles 1017, 1892 and 1893.

There is no general prohibition in Argentina on the use or trading of cryptoassets. Both individuals and legal entities may acquire, hold and trade them, and the provision of services in relation to them is lawful, subject to prior registration as a PSAV with the CNV (see questions 2 and 5)

The only restriction in force, as mentioned, falls on financial entities and PSPCPs, which may not carry out or facilitate cryptoasset operations for their clients (see questions 2 and 5).

Crypto-asset trading is, indeed, common and widespread. As described in question 1, Argentina is one of the most active cryptoasset markets in Latin America, with a particularly intensive use of US dollar stablecoins.

There is no ICO-specific statute and no authorisation specifically called an ‘ICO licence’. Therefore, their regulatory treatment depends on the legal characteristics of the token, the terms and channels of the offer, and the role of the issuer and any intermediaries.

In December 2017 the CNV issued a public warning on ICOs. It described them as highly speculative, high-risk products suitable only for expert investors prepared to lose their entire investment. It listed their risks: lack of specific regulation, volatility and illiquidity, potential fraud, inadequate information, early-stage projects, technological failures and the cross-border nature of the activity^[1]. Crucially, the CNV warned that, depending on how an ICO is structured, the tokens offered could be securities whose public offering in Argentina requires prior CNV authorisation^[2].

^[1] CNV, ‘Oferta Inicial de Monedas Virtuales o Tokens’ (4 December 2017), https://www.iosco.org/library/ico-statements/Argentina%20-%20CNV%20-%20Oferta%20Inicial%20de%20Monedas%20Virtuales%20o%20Tokens.pdf; CNV, ‘Alerta al público inversor sobre ofertas iniciales de monedas virtuales o tokens’, https://www.cnv.gov.ar/SitioWeb/Prensa/Post/1204/1204-alerta-al-publico-inversor-sobre-ofertas-iniciales-de-monedas-virtuales-o-tokens.

^[2] Ibid.

There is currently no specific legislation in Argentina governing the transfer of title to cryptoassets or the granting of security over them.

These matters are therefore governed by the general rules of the CCC, and the legal characterisation of the cryptoasset in question must also be taken into account. In this context, a degree of uncertainty cannot be ruled out, particularly with respect to the granting of security over cryptoassets, given the novelty of the matter and the lack of judicial precedent.

Smart contracts are not recognised as a separate contractual category in Argentina, but they can implement legally binding arrangements where the requirements of general contract law are satisfied.

There is no statutory definition of smart contracts. The prevailing view among Argentine legal scholars is that a smart contract is not a new contract type. It is either: a technological means of executing, in whole or in part, obligations arising from a contract formed under the general rules of the CCC; or where the code itself embodies the parties’ consent, a contract concluded by electronic means^[1].

Either way, expressing or performing an obligation through code is valid, unless the substantive law requires a specific formality that is incompatible with the blockchain, which must be assessed on a case-by-case basis.

Smart contracts already play a role in regulated activity. Under the CNV tokenisation regime, digital representations of securities must be generated through smart contracts or networks that prevent transfers that are not permitted, such as transfers outside the authorised PSAVs or to decentralised protocols (see question 8).

As regards enforceability, given the novelty of the matter, the absence of specific regulation and the lack of judicial precedent, disputes may arise in certain cases from the use of pseudonymous counterparties, such as questions of capacity, authority and identity. Disputes may also arise in relation to consent to terms that exist only in code, given how difficult it can be in certain cases for the parties to inform themselves properly and the fact that protocols operate on non-negotiable terms, which has a greater impact where one of the parties is a consumer. Likewise, coding errors, alterations to the code, inaccurate oracle data and the loss or compromise of private keys will give rise to new disputes over liability, unfair terms and risk allocation.

^[1] C Mirassou Canseco and A Hadad, ‘Nuevo paradigma contractual: los smart contracts’, Sup Esp LegalTech II, 11 January 2019, AR/DOC/3578/2019; GE Bielli, CJ Ordoñez and FO Branciforte, Blockchain y Derecho (Thomson Reuters La Ley, 2022), vol I, ch 1; C Tur Faúndez, Smart contracts. Análisis jurídico (Reus, 2018), p 59.

Argentina has no corporate form, register or specific legal regime for DAOs, and there is no reported case law on the subject. Therefore, their treatment depends on how the arrangement would be characterised under general corporate and civil law, which in turn depends on the specific structure, the relationships among participants, whether a legal wrapper exists and the activities carried out. This characterisation has direct consequences for the members’ liability.

Under the GCL, a company exists when one or more persons, organised under one of the entity types provided by law, undertake to make contributions for the production or exchange of goods or services and share profits and losses (article 1)^[1].

A DAO with an economic purpose, whose participants contribute assets and share in its results, could arguably meet that definition. Since it has no registered entity type, it would fall within Section IV of Chapter I GCL (articles 21–26), which governs companies that were not incorporated under a statutory entity type or that omit essential requirements or formalities. Under those rules, the agreement may be invoked among the members, but may be enforced against third parties only if it is proved that they had actual knowledge of it when the contract was entered into or the obligation arose (article 22); the company’s existence may be proved by any means (article 23); and members are liable to third parties severally and in equal shares, unless joint and several liability or a different proportion arises from an express stipulation, the partnership agreement or the rules of the entity type the members intended to adopt (article 24).

Nevertheless, this framework may change. In May 2026, the Executive Branch sent Congress a bill that would replace the GCL entirely (the ‘Bill’) and introduce DAOs as a new entity type^[2]. The Bill is under review by the Senate Committee on General Legislation and, at the time of writing, no committee report had been issued.

Under the Bill, DAOs may be fully or partially autonomous and decentralised, following the governance, operation, decision-making and profit-distribution rules set out in their constitutive instrument or protocol (article 258). Members’ interests may be represented by certificates or tokens on distributed ledgers or other technologies and are acquired and transferred by registration on the network declared by the DAO, without further formal notice; a transfer is enforceable from registration, provided the system ensures traceability (article 259). The DAO itself would be liable with its own assets for obligations and damages arising from its activity, including those executed automatically by the protocol (article 262), and would be subject to beneficial ownership and anti-money laundering obligations (article 264).

The most debated provision is article 261(7), which requires the protocol to ensure that only members previously identified under applicable due diligence standards can acquire or transfer interests, and to maintain at all times the link between each interest and its holder’s identity. Failure to comply is a ground for refusing or cancelling registration and, if the protocol is not deployed at registration, the mechanism must be operational within six months. Academic opinions have argued that the requirement conflicts with the pseudonymous, freely transferable nature of governance tokens, and that identity-bound token solutions are not yet mature^[3].

^[1] General Companies Law No 19550 (consolidated text approved by Decree No 841/1984), Articles 1, 21–26 and 118–124; Civil and Commercial Code, Articles 168–192 and 1666 et seq.

^[2] Bill for a new General Companies Law, dated 28 May 2026, sent to Congress by message of the Executive Branch of 29 May 2026 (INLEG-2026-53661873-APN-PTE), Articles 258–264.

^[3] P Breuer Moreno, ‘Las DAOs no son sociedades comerciales: lo que el proyecto de ley argentino entendió mal’ (22 June 2026); A González Rossi, ‘Organizaciones autónomas descentralizadas (DAO) y el proyecto de Ley General de Sociedades’, Abogados.com.ar (12 June 2026); M Davo, ‘Proyecto de Reforma de la Ley General de Sociedades: DAOs’ (4 June 2026).

There are no recorded enforcement actions targeting the use of blockchain technology itself; the known measures focus on the activities of PSAVs and on certain virtual assets offered as securities without authorisation.

In this regard, enforcement activity has been limited to date, which is consistent with a recently established regulatory framework. The known measures are concentrated primarily within the CNV.

Blockchain projects in Argentina must also be assessed against generally applicable data protection, consumer, electronic-signature, civil liability and insolvency rules, several of which can conflict with the immutable characteristics of DLTs.

The Personal Data Protection Law, Law No 25326 (PDPL), its Regulatory Decree No 1558/2001 and the guidance of the Agency for Access to Public Information (Agencia de Acceso a la Información Pública or AAIP), including AAIP Resolution No 47/2018 on security measures, apply to on-chain processing of personal data.

Public-key addresses and transaction histories linked to identified users would arguably constitute personal data. Three tensions stand out: the rights of rectification, updating and erasure (article 16 PDPL) are difficult to reconcile with immutable ledgers, and it has not been tested whether the accepted mitigations (storing personal data off-chain with only hashes on-chain, as in the BFA model; permissioned architectures; and encryption with key destruction) satisfy the right to erasure; in permissionless networks it is hard to identify the data controller and to register databases with the AAIP; and international transfers are restricted to countries with adequate protection unless an exception or contractual safeguards apply (article 12 PDPL), which is difficult to comply with where nodes are distributed globally^[1].

The Bankruptcy Law, Law No 24522 (BL), contains no crypto-specific rules. General Resolution No 1058/2025 of the CNV requires PSAVs to segregate customer VAs and not to use them, which facilitates their identification and their de facto separation. However, the treatment of customer VAs in the event of a PSAV’s insolvency may give rise to disputes before the courts. No Argentine insolvency court has yet ruled on the point.

^[1] Law No 25326, Articles 12 and 16; Decree No 1558/2001; AAIP Resolution No 47/2018.

Some Argentine courts have begun to rule on VAs. The precedents are few, but no less relevant, and concern three issues: the evidentiary value of blockchain records, the liability of exchange platforms towards their users, and the jurisdiction of local courts over providers established abroad.

In one of the precedents, the Civil and Commercial Court of Appeals of Morón ruled on the evidentiary value of blockchain records and was the first to define what blockchain is^[1]. Assessing the evidence under the sound judgement standard, the court accepted that a document hash timestamped on BFA proves that the document existed at a given moment and has not since been altered, but held that the timestamp does not prove performance, signature, the identity of the signatory or the accuracy of the content.

As regards jurisdiction, recent case law has accepted that neither the fact that the PSAV is established abroad nor the stipulation of a foreign governing law or of foreign arbitration prevents the consumer from suing before Argentine courts. In Biquard v Xapo Bank Limited, the defendant argued that, by accepting the terms and conditions with a simple click, the claimant had consented to any dispute being resolved under the law of Gibraltar and by arbitration; local jurisdiction was upheld^[2]. For foreign PSAVs directing their services to Argentine residents, the practical conclusion is that they should assume the application of the consumer protection regime and the potential jurisdiction of local courts, regardless of what their terms and conditions provide.

^[1] Civil and Commercial Court of Appeals of Morón, Buenos Aires Province, Chamber 2, R S G D J c/ B A V, Herederos de V y otro s/ Daños y perjuicios, 22 February 2024.

^[2] National Court of Appeals in Commercial Matters, Chamber A, Biquard, Carolina c/ Xapo Bank Limited y otro s/ ordinario, 10 March 2026.