Argentina's CNV Expands the Securities Tokenization Regime: General Resolution 1137/2026, Sandbox Extended Through 2027 and New Eligible Instruments
General Resolution 1137/2026, published Monday in the Official Gazette, extends tokenization to all securities issued under automatic authorization regimes and prorogues the regulatory sandbox until December 31, 2027. What changes, what can be tokenized now, and what issuers and VASPs should consider.
On Monday, May 4, the Official Gazette published General Resolution 1137/2026 of Argentina's National Securities Commission (CNV), introducing two substantial changes to the country's securities tokenization regime: it expands the universe of instruments that may be digitally represented through Distributed Ledger Technologies (DLT) and prorogues the regulatory sandbox until December 31, 2027, extending a deadline that originally expired in August 2026.
General Resolution 1137 is part of a package of six general resolutions (1132 through 1137) by which the CNV redefines the logic of issuance authorization in the Argentine capital market. The remaining five resolutions create automatic authorization regimes for negotiable obligations, shares, financial trusts and mutual funds. Resolution 1137 connects those new regimes with tokenization: any security issued under automatic authorization may henceforth be digitally represented.
Where the tokenization regime comes from
Argentina built its tokenization framework in two stages. The first was General Resolution 1069/2025, published in June 2025, which set out the basic rules for the digital representation of securities using DLT. That resolution allowed tokenization of debt securities and participation certificates of financial trusts with public offering, following a model inspired by Brazil and Uruguay. Tokenization does not create a new security but is an additional form of representation of an existing security deposited with a Central Securities Depository Agent (ADCVN). In this sense, Virtual Asset Service Providers (VASPs) registered with the CNV became authorized depositories for digital custody.
The second stage came with General Resolution 1081/2025, in August 2025, which incorporated securities proper (shares, negotiable obligations and other instruments admitted to public offering) into the tokenization regime. That resolution also clarified that only VASPs registered in all categories of the CNV Registry can act as depositories, and introduced specific custody obligations equivalent to those of the traditional regime. The entire scheme was framed within a regulatory sandbox expiring in August 2026.
What changes with General Resolution 1137/2026
Resolution 1137 produces two main effects. The first is the expansion of the universe of securities eligible for tokenization. Until now, digital representation was available for instruments issued under specific regimes: Medium-Impact Automatic Public Offering, Frequent Issuers, Frequent Issuances of Financial Trusts, and units of closed credit mutual funds. Under the new resolution, tokenization extends to all securities issued under any Automatic Authorization Regime provided in the CNV Rules.
This includes two relevant additions. The first is the Public Offering Regime with Automatic Authorization for Securities Due to Their Low Impact, designed for smaller issuances and smaller issuers, which can now access the tokenized world. The second is the new Public Offering Regime with Automatic Authorization for Expanded Medium Impact, created by General Resolution 1132/2026, which allows issuance of shares or negotiable obligations of up to 100 million UVA (approximately USD 138 million at the current exchange rate) without prior CNV review. Securities issued under this new regime may also be tokenized. The only explicit exclusion is Open-Ended Mutual Funds (FCIA).
The second effect is the extension of the regulatory sandbox. The original deadline of the controlled testing environment was August 21, 2026. Resolution 1137 prorogues it until December 31, 2027. During that period, the CNV will monitor and evaluate how tokenized securities work in practice. Once the deadline expires, no new issuances with digital representation will be admitted unless the CNV decides to extend or modify the scheme.
The role of VASPs in the expanded regime
Virtual Asset Service Providers remain the central piece of the tokenization scheme. They are responsible for the marketing and digital custody of securities represented through DLT. Resolution 1137 does not modify the eligibility requirements established by previous resolutions: the VASP must be registered in all categories of the CNV's VASP Registry, and that registration must remain in force throughout the period during which the securities remain digitally represented.
Custody obligations are demanding. VASPs must guarantee a level of security equivalent to traditional custody, ensuring that neither own employees nor external agents can access instruments without authorization. Securities not effectively placed in the market and those blocked by contractual or regulatory restrictions require differentiated custody. The expansion of the tokenizable universe means that VASPs will need to prepare to custody a broader range of instruments, with their respective operational and legal particularities.
How the tokenization process works
The process maintains the structure of previous resolutions. The issuer must request from the CNV, simultaneously, the public offering authorization and the digital representation authorization. Securities are initially issued in book-entry or certificated form and deposited with the ADCVN through an authorized depository. From that deposit, digital representation is generated through DLT. The tokenized security is not a new instrument or a virtual asset: it is the same security, with an additional layer of representation that allows its circulation on digital platforms with the operational advantages of blockchain technology (fractionalization, 24/7 operation, real-time traceability, accelerated settlement).
Securities that have obtained authorization for digital representation but have not been effectively tokenized within the following two years are excluded from the regime by operation of law. That exclusion does not cancel the public offering of the instrument under its other forms of representation.
Argentina on the global tokenization map
With Resolution 1137, Argentina consolidates a position it has been building since 2025. The country is one of the few in Latin America with a specific regulatory framework for securities tokenization, alongside Brazil (which implemented its regime through the CVM) and Uruguay (which is advancing a similar scheme). Globally, sector projections place the tokenized assets market exceeding USD 10 trillion by 2030, with institutional players such as NYSE, S&P Dow Jones and Bitfinex Securities investing in tokenization infrastructure.
The CNV's strategy combines two elements: a sandbox that allows testing the regime under controlled conditions without compromising market stability, and a progressive expansion of the tokenizable universe that follows the maturation pace of the ecosystem. Extending the sandbox through December 2027 gives the market a 20-month additional certainty horizon to develop products, infrastructure and operational experience before the CNV decides whether the regime becomes permanent.
Public consultation and entry into force
The six general resolutions (1132 through 1137) were submitted to public consultation for 15 business days, expiring May 27, 2026. During that period, market participants may submit opinions and proposals through the CNV website. Once the consultation closes and observations are evaluated, the CNV will define the definitive implementation date. This means the rules are not yet in force in their final version: they may undergo adjustments based on the comments received.
Practical takeaway for issuers and VASPs
For issuers planning placements under the new automatic authorization regimes, tokenization becomes an option available from the moment of issuance. Simultaneously requesting public offering authorization and digital representation authorization allows reaching a broader investor audience, including those who operate exclusively on digital asset platforms. For low-impact or expanded medium-impact issuances (up to 100 million UVA), the combination of automatic authorization + tokenization drastically reduces the time between the decision to issue and effective placement.
For VASPs, the expansion of the tokenizable universe represents both a commercial opportunity and an operational burden. Greater variety of instruments implies more potential custody and trading volume, but also requires adapting custody, reconciliation and reporting systems to the particularities of each type of security. The immediate priority is to verify that registration in all categories of the VASP Registry is current and updated, and to participate in the public consultation before May 27 to influence the final configuration of the regime.
At JFC we advise issuers and VASPs on structuring tokenized issuances under the CNV regulatory framework, including instrument eligibility analysis, digital representation requirements and applicable custody and transparency obligations.
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.