ARCA General Resolution 5804/2025: New Reporting Regime for Digital Platforms and PSPs

ARCA General Resolution 5804/2025: New Reporting Regime for Digital Platforms and PSPs

ARCA redefined reporting obligations for digital wallets, exchanges, and payment platforms: user-centric approach, new thresholds, and enhanced data requirements.

On December 23, 2025, Argentina's Revenue and Customs Control Agency (ARCA) issued General Resolution No. 5804 (hereinafter "GR 5804"), published in the Official Gazette the following day. The regulation amends General Resolution 4,614 and its supplements, which since 2019 have governed the reporting regime applicable to entities that manage, administer, or process asset movements through electronic or digital platforms, including Payment Service Providers (PSPs) offering payment accounts.

According to its recitals, the update responds to the need to adjust the required information to sector changes and improve the analytical value of the data the agency receives. In practice, the reform is deeper than that generic justification suggests: it shifts the regime's focus (from account to user), sets new thresholds, broadens the typology of reportable transactions, and strengthens traceability in third-party operations. The enhanced data requirements apply to informational tax returns due from May 2026 onward.

From Account to User: The Shift in Approach

The most significant conceptual change in GR 5804 is the abandonment of the per-account transactional approach in favor of a comprehensive per-user approach. Under the prior regime, reporting obligations were triggered account by account. Now, the analysis of inflows, outflows, and month-end balances considers all of the user's accounts at the reporting platform.

This has a direct practical consequence: a user who fragmented operations across multiple accounts within the same platform can no longer fall below reporting thresholds simply through that dispersion. ARCA now looks at the account holder, not each account separately.

Scope of Covered Entities

The regime covers entities that manage, administer, control, or process asset movements through electronic or digital management platforms, on behalf of individuals or legal entities, whether or not they are resident in Argentina. The regulation expressly includes PSPs offering payment accounts.

A point worth noting: the reporting obligation also covers accounts granted or hosted at other entities, provided they are managed, administered, or controlled through the reporting platform. If a PSP allows users to operate an account that is technically hosted at another entity, the PSP has a duty to report that account as its own for purposes of the regime.

New Reporting Thresholds

GR 5804 sets the thresholds that trigger the reporting obligation. Platforms must report data on users whose total inflows, outflows, or month-end balance (across all their accounts) equal or exceed ARS 50,000,000 for individuals and ARS 30,000,000 for legal entities.

Another relevant change: the regulation eliminates the automatic CPI-based threshold adjustment clause that existed in the prior version (semi-annual). The new amounts are fixed, meaning that with accumulated inflation, the universe of covered users will tend to expand over time unless ARCA issues an express update.

What Information Must Be Reported

Account Holder Data

GR 5804 expands and systematizes the monthly information detail that platforms must provide about each user. The list includes: the individual's relationship to the account (holder, co-holder, authorized representative, legal representative), nationality, identifying data, CUIT, CUIL, or CDI (or, alternatively, CIE, passport, or NIF from the country of residence), account opening and closing dates, and number of accounts associated with the user.

Transactions and Balances

The regulation requires reporting all inflows and outflows processed by the user through the platform that modify the available balance and are visible to the user. The type of inflow or outflow, the currency used, and its Argentine peso equivalent must be itemized. Balances, including platform-visible investments, are consolidated.

When a transfer between bank accounts (CBU) or virtual accounts (CVU) exceeds 5% of the threshold established for individuals, the platform must report the originating or destination CBU or CVU. This traceability requirement supplements the general transaction detail and aims to enable ARCA to reconstruct fund flows between platforms.

Currency Conversion

The resolution sets precise conversion criteria. Foreign currency amounts are converted at the Banco de la Nacion Argentina's buyer rate in effect at the close of the last business day of the reported month. For digital currencies or cryptocurrencies, conversion uses the last buyer quotation price set by the obligated entity itself on the last day of the month.

This last point is noteworthy. The crypto pricing reference rests with the platform, introducing some variability depending on which exchange or PSP is reporting. ARCA chose not to set a single reference price, likely because the dispersion of quotations across platforms would have made it impracticable.

Effective Date and Timeline

GR 5804 took effect the day after its publication in the Official Gazette (December 25, 2025). However, the enhanced data detail requirements apply to informational tax returns due from May 2026 onward. This gives platforms time to adjust their report generation systems to the new framework.

Implications for PSPs and Fintechs

GR 5804 fits within a clear ARCA trend: consolidating all information by taxpayer ID (CUIT), cross-referencing it with declared revenue, and detecting inconsistencies. For a PSP or exchange, the regime has concrete operational implications.

The first is technical: report generation systems must adapt to the new per-user approach and the expanded data detail. Platforms need to consolidate balances and user-visible investments, categorize transactions according to the new typology, and report originating or destination CBU/CVU when the 5% threshold is exceeded. All of this requires software development and testing before May 2026.

The second is regulatory: the fact that accounts hosted at other entities but operated through the reporting platform fall within the regime requires PSPs to map all products and accounts that the user sees and operates from their interface, even when technical account ownership lies with a third party. Delineating reporting responsibilities between platforms may generate contractual friction.

The third concerns the fixed thresholds. The elimination of automatic CPI adjustments means that as nominal amounts grow with inflation, more users will exceed the reporting floor. This could translate into a progressive increase in the volume of reportable information, with the associated operational cost for platforms.

Tax Impact for Users

It is worth clarifying what GR 5804 does not do: it does not create any new tax. It is a reporting regime, not a withholding or collection mechanism. However, the information platforms report feeds ARCA's databases and is cross-referenced with Income Tax, Personal Assets Tax, and VAT returns. In practice, a user operating amounts above the thresholds whose tax filings do not reflect those transactions is exposed to audits, Monotributo recategorization, or ARCA inquiries.

Summary

GR 5804 updates the GR 4,614 reporting regime with three structural changes: reporting shifts to a per-user basis (not per-account), thresholds are set at ARS 50M / 30M with no automatic adjustment, and data detail requirements are expanded (transaction typology, balance and investment consolidation, CBU/CVU traceability). Platforms have until May 2026 to adapt their systems.

For PSPs and exchanges, the immediate work falls along two axes: adapting reporting systems to the new technical format, and reviewing contractual relationships with entities whose products are operated through the platform to define reporting responsibilities. For users, the regulation does not change their tax obligations, but it does increase ARCA's capacity to detect discrepancies between what is declared and what is transacted.

This note is for informational purposes only and does not constitute legal advice. For a specific analysis, please contact our team at contact@jfcattorneys.com.