Crypto-asset regulation and tokenization in Argentina

A business seeking to tokenize debt, shares or interests in Argentina must address two connected files: the issued instrument and the providers distributing or holding it. VASP registration does not turn any token into a security with authorized digital representation.

The CNV framework allows certain digital representations within defined infrastructure and participants. Technical design must accommodate those restrictions from the outset, particularly where an offering uses an automatic authorization route.

How to coordinate tokenized issuance and VASP registration

Argentina regulates virtual asset services through Law 27,739 and the CNV's VASP rules, developed by General Resolution 1058/2025. The framework covers exchange, transfer, custody and financial services connected with issuers' offerings through distinct categories. Registration includes capital, organization, systems and ongoing controls; describing it solely as an anti-money-laundering register omits material operating requirements.

Digital representation of securities follows Title XXII of the CNV rules. General Resolution 1150/2026, effective from 12 June, expands eligible instruments and issuances and extends the sandbox. Not every token falls within this framework: the represented right, instrument and functions actually performed by each participant must be assessed.

Which authority supervises each activity

The National Securities Commission, CNV, administers the public VASP register, supervises requirements and regulates securities offerings. Its authority over providers does not mean it individually approves every asset available on a platform. Registration neither grants general banking permission nor replaces authorizations required for other activities within the business model.

The Financial Information Unit, UIF, establishes VASP preventive duties through Resolution 49/2024. CNV General Resolution 1139/2026 adds preventive information submitted to the CNV through its Financial Information Highway, AIF. Reports to these two authorities serve different obligations and must be incorporated into the compliance calendar.

Which permission the business model requires

Registration applications use the Trámites a Distancia platform. Articles 1 and 3 of the VASP chapter cover domestic providers and foreign companies with specified connections: targeted solicitation, local fund-receipt arrangements or other prescribed links. Foreign entities require the corporate structure or local representation contemplated by the rules. Locating servers abroad is insufficient.

The monthly 35,000 UVA exemption applies exclusively to natural persons; low transaction volume does not exempt a company. Own-account trading, specified payments for goods or services, providers solely offering self-custody wallets and protocols without an identifiable provider have specific exclusions. Adding intermediation or asset control may change the assessment of a technology product. The tokenization rules say so expressly: a party that merely provides technology services for a digital representation later marketed by a VASP need not register as one, but a party performing any of the activities listed in Article 4 bis of the anti-money-laundering law must register.

Articles 8 and 9 distinguish categories and minimum net worth: USD 150,000 for exchange or custody, USD 75,000 for transfers and USD 35,000 for offering-related services. Conditional reductions apply to certain categories and volumes; combining categories attracts the highest requirement. These amounts represent required net worth, not registration fees or a complete launch budget.

How holder rights are documented

The digital representation framework admits specified securities, including shares, corporate bonds, CEDEARs, trust securities and fund interests defined by the rules. The 2026 expansion adds units of FCIA ETFs and CEVA ETPs and opens the automatic authorization regimes, except those applicable to FCIA. The exclusions are specific and should be considered when designing the structure: social, green, sustainable or sustainability-linked securities cannot be tokenized, nor can other countries' government debt, which also cannot form part of a trust's underlying assets or a fund's portfolio, the sole exception being sovereign securities of MERCOSUR States Parties and Chile. For covered private issuers, an automatic offering still requires prior digital representation authorization; low-impact offerings must voluntarily prepare the prospectus prescribed for medium-impact offerings.

Digital representation is additional to the traditional security deposited with a collective deposit agent. It creates no second independent security. The record holder acts on behalf of investors and may be one or more VASPs, an agent for the administration of collective investment products, a depositary company or a comprehensive settlement and clearing agent (ALyC integral). A specialized distributed ledger technology entity must also participate; it generates the digital representations and need not be registered as a VASP, but must demonstrate recognized standing, verifiable experience and an adequate organizational structure. Participating VASPs must be registered simultaneously in every category. Functional equivalence is subject to rules governing economic and voting rights; holding a token does not itself establish ownership of a trust's real estate.

Article 12 requires disclosure of the separation between record holder and beneficiary and the risk that courts may classify the rights as unsecured claims in a dispute or insolvency. This warning prevents treating the structure as absolute insolvency protection. Issuance documentation must explain rights, participants, technology, risks and mechanisms for evidencing holdings.

Which obligations continue during operations

Articles 11–20 and 38–39 of the VASP chapter require procedures, cybersecurity, segregation, annual systems audits and record retention. Delegation does not remove the provider's responsibility. UIF Resolution 49/2024 adds due diligence, monitoring and reporting; Article 37 refers to the arrangements established by the UIF for transfer information, so current exchange and validation instructions must be checked.

For tokenization, General Resolution 1150/2026 limits designated VASPs to five per issuance and requires interoperability and synchronization. It prohibits transfers or trading outside participating providers or through decentralized protocols and requires smart-contract controls. The sandbox ends on 31 December 2027 without automatically invalidating earlier issuances; continuation for new issuances depends on subsequent rulemaking. A separate deadline also shapes the issuer's timetable: securities that obtain digital representation authorization but are not digitally represented within the following two years are excluded from the framework by operation of law, without canceling the public offering under the other forms of representation.

What to prepare before launching the project

Identify the security, its traditional representation and its link to the digital representation. Document the holder of record, how investors exercise rights and what happens if systems diverge or a participant becomes insolvent.

Select VASPs by current categories and specify interoperability, transfer permissions and issuance documents. Check both digital representation approval and the sandbox timetable before fixing a launch date.

PAGBAM also documents a July 2026 digital representation authorization, with commencement to be announced afterwards. That case establishes neither unrestricted access for every platform nor actual issuance on an unverified date. Each transaction requires verification of current registration, categories and the specific authorization, alongside its own tax and foreign-exchange obligations.

To understand how this framework applies to your project, discuss your case with our team.