On October 15, 2026, Argentina's Official Gazette published General Resolution 1172/2026 of the National Securities Commission (CNV). The resolution replaces, in full, Chapter III of Title XIV of the CNV Rules, which contains the regime for Virtual Asset Service Providers (VASPs, known locally as PSAV) adopted in March 2025 by General Resolution 1058. It entered into force on October 16. The new monthly reporting format applies from November 1, 2026.
The PSAV category was created by Law 27,739, which added it to Argentina's anti-money laundering statute and gave the CNV responsibility for registering and supervising providers of virtual asset services, crypto exchanges included. Foreign firms often ask about an Argentine "VASP license". In practice the regime works as a registration with the CNV's PSAV Registry, with entry requirements and ongoing supervision, and Resolution 1172 changes several of those requirements.
The CNV describes the resolution as part of its regulatory simplification effort. The structure of the regime stays in place. What changes is the detail: positions that lived in interpretive criteria move into the rules, the registry exclusions are redefined, there are now procedures to change categories and to deregister, and the monthly report, which already existed, gets a detailed methodology and standardized file formats. For registered VASPs, the changes reach their bylaws, capital, internal procedures and reporting systems.
I. What stays the same
Resolution 1172 keeps the five activity categories: exchange between virtual assets and fiat currency, exchange between virtual assets, transfer, custody or administration, and financial services related to an issuer's offer or sale of a virtual asset. Individuals may only register for the first two, and only when their transactions exceed the equivalent of 35,000 UVA (an inflation-indexed unit) per calendar month.
Minimum net worth requirements are also unchanged: USD 150,000 for categories 1, 2 and 4; USD 75,000 for category 3; and USD 35,000 for category 5. For categories 1 to 4, the requirement drops to 50% when the volume traded or held in custody over the last twelve months is below USD 2,500,000, and a VASP registered in more than one category only has to meet the highest applicable minimum. Segregation of client assets and funds, cybersecurity rules, the annual systems audit and the nexus tests that require a foreign company to register all remain in place: use of a ".ar" domain, on-ramp arrangements to receive local funds, services or advertising clearly aimed at Argentine residents, or Argentine business volume above 20% of the total.
II. Corporate requirements: interpretive criteria become rules
The CNV moved Interpretive Criteria 95, 96 and 97 into the text of the rules and revoked them. What was until now the regulator's interpretation is, since October 16, a binding requirement.
On corporate purpose, companies incorporated in Argentina must expressly provide for acting as a VASP. Generic or ambiguous wording that could be read as an implicit authorization is not accepted. For branches and permanent representations of foreign companies, it is enough that the parent's corporate purpose covers the activity, expressly or implicitly, provided this is consistent with the law of its home jurisdiction. In all cases, the restated bylaws, as registered, must be published on the CNV's filing platform (the Financial Information Highway, or AIF) and kept current for as long as the registration lasts.
Share capital must be fully paid in and registered with the Public Registry, both at registration and throughout. Irrevocable capital contributions must be capitalized, with the capital increase registered, before the application is filed. Contributions received later must be capitalized within six months of their acceptance by the board.
Branches need capital assigned in Argentina that is paid in, shown in the branch's financial statements and not lower than the minimum net worth. A permanent representation that cannot be assigned capital must earmark assets located in Argentina, held by the representation and not by the representative, through a security trust, for a value that covers the minimum at all times. If the financial statements filed are more than eight months old, a certification of net worth by a public accountant, as of a date no older than two months, is also required, expressed in US dollars at the exchange rate of BCRA Communication "A" 3500.
For individuals, the rules specify that the 35,000 UVA threshold is computed with the UVA value of the last day of each month, and the application must include a certification by a public accountant, with a legalized signature, showing transactions on behalf of third parties above that amount.
Our reading. For registered VASPs, corporate purpose is the most sensitive point. The rules require these conditions throughout the registration, not only when applying, so they also reach companies registered with a broad purpose clause or with uncapitalized irrevocable contributions.
III. Who falls outside the registry
Article 2 changes the test for decentralized finance. General Resolution 1058 excluded decentralized protocols as long as there was no "identifiable service provider". Resolution 1172 excludes them only if no individual or legal entity with control or sufficient influence over their operation provides services covered by the VASP definition. The question is no longer whether someone can be identified, but whether someone controls the protocol or has sufficient influence over it.
Self-custody wallets now have a definition as well. General Resolution 1058 excluded providers acting exclusively as self-custody wallet providers, without defining the term. Resolution 1172 requires that the user keeps control of the assets and of the means of access, and that the provider has no custody, administration or disposal powers. Along the same lines, category 4 excludes services in which the user keeps exclusive control of the assets.
For foreign companies, advertising aimed at Argentine residents remains a nexus that triggers registration, unless the client is the one who contacts the provider (reverse solicitation). Resolution 1172 adds that the contact must happen "on the client's exclusive initiative". The exemption for foreign groups also remains: a foreign company that holds an interest, directly or through another group company, in an Argentine company incorporated under section 123 of the General Corporations Law and registered as a VASP does not need to register itself, provided it has no direct contractual relationship with clients in Argentina and does not meet any of the nexus tests in Article 4.
Our reading. The "control or sufficient influence" test is the one the FATF uses for decentralized finance. A team that controls the front end, holds admin keys or can upgrade the smart contracts will find it hard to rely on the exclusion. As for reverse solicitation, the "exclusive initiative" wording takes out of the exception contacts that a client starts after receiving the provider's own advertising or campaigns.
IV. Changing categories, changing names and deregistering
Until now there was no specific procedure for a registered VASP to change its categories. Article 42 now sets one. The VASP first notifies the Registry's mailbox (RegistroPSAV@cnv.gov.ar) of the intended change, files through the AIF the documents showing compliance with the requirements of the categories involved and, once the CNV confirms compliance, reports the change as a material event, identifying the corporate resolution that approved it (date and body). It must also update Form PSAV_003 listing all its categories. A change of corporate name is reported through the AIF with the registration certificate issued by the Public Registry (Article 43).
Voluntary deregistration now has preconditions (Article 44). Before applying, the VASP must notify clients of the cessation at least 30 calendar days in advance, put in place mechanisms for clients to withdraw or transfer their balances, and send periodic communications during that period. The application must include a sworn statement confirming that activities have ceased and those steps were taken, together with evidence of the signatory's authority. A decision to cease activities, in full or for one or more categories, must also be reported as a material event with the expected date. The other two grounds for cancellation remain: revocation by the CNV, and a request from the Financial Information Unit (UIF) for breaches of its reporting regime, including the identification of beneficial owners. In every case, cancellation is ordered by an administrative act of the CNV.
Our reading. The 30-day notice applies to full deregistration. For ceasing a single category, the rules require the material event filing but set no client notice period. The gap matters when the category being dropped is custody and clients still hold balances.
V. Material events, conduct, advertising and referrals
Article 40 adds a non-exhaustive list of material events that a VASP must report immediately through the AIF. It includes changes to the corporate purpose or activities, the actual start date of operations, losses above 15% of net worth compared with the last financial year-end, litigation or claims exceeding 10% of net worth, insolvency, substantial system outages, cyberattacks or fraud that materially compromise client funds or data, problems with custody, transfer or exchange services, a decision to cease activities, measures to restore minimum net worth, and termination of agreements with third parties.
On conduct, General Resolution 1058 already prohibited offering services, tools or mechanisms designed to hinder the identification of the source and destination of transactions. Article 25(q) now names the cases covered: mixers or tumblers, collaborative transaction mixing mechanisms and other anonymization services that make it harder to link source and destination addresses.
Article 33 keeps the rule that whoever promotes a VASP's activities cannot promote capital markets activities, and vice versa. What is new is an exception for promoting services involving digitally represented securities under Title XXII of the CNV Rules, limited to what the VASP is authorized to do. Article 38, in turn, prohibits offering virtual assets that are securities without public offering authorization and sets the test to identify them: the legal and economic nature of the rights they grant and how they actually operate, regardless of their commercial name or the technology used.
On referrals, Article 35 allows a VASP to refer clients to registered agents and be referred by them, and also to be referred by third parties in Argentina or abroad, including its parent company or economic group. The referring party may only redirect the client and facilitate contact, without receiving, transmitting or executing orders, and all advertising must identify the registered VASP. Referral agreements and agreements with third parties, for example to delegate custody, must be reported through the AIF within five days of signing, and termination of third-party agreements must be reported as a material event.
Our reading. The prohibition in Article 25(q) targets services that a VASP offers and that are designed to break traceability. The text does not address the listing of assets with privacy features. On tokens, the substance-over-form test confirms that registration as a VASP does not, by itself, allow the offering of instruments the CNV treats as securities.
VI. The new monthly report: Form PSAV_014
This is the change with the largest operational impact. General Resolution 1058 already required a monthly report with the same items and the same 15-calendar-day deadline. What is new is the methodology. Form PSAV_014 is renamed "Monthly Report: Clients, Transactions and Custody" and must be completed under detailed instructions added as Annex I to the chapter. It is mandatory even without activity, reporting zero values. A registered VASP that has not yet started operating must say so through Form PSAV_015 and, once it starts, report that as a material event and begin filing.
The report has three blocks. The first, filed as a form, covers the number of active clients on the last day of the month, split between individuals and legal entities, and the volume traded. An active client is one who made at least one transaction or held assets in the last twelve months; in jointly held accounts, each holder counts as a client. Volume is reported in thousands of US dollars, gross (without deducting fees or spreads and without netting purchases against sales) and single-sided: each transaction counts once. It is split between spot trades and other contracts referenced to virtual assets, such as perpetuals, which are reported at notional value. Only trades for the account and on the order of clients are included. Proprietary trading, proprietary market making, internal wallet movements, transfers between accounts of the same holder and cancelled trades are excluded.
The second block is a text file (OPERADO_CUIT_AAAAMM.txt) listing at least the ten most traded assets by US dollar value. Here the method is two-sided: each crypto-to-crypto trade is split into its two legs. For each asset the VASP reports the quantity in native units (up to eight decimals), the amount in thousands of US dollars, the amount in thousands of pesos where there is an ARS leg, the average execution price and, if available, the DTI identifier.
The third block (CUSTODIA_CUIT_AAAAMM.txt) lists each asset held in custody by network, with its quantity and its value at 23:59 Argentina time on the last day of the month. If part of the holdings was deployed in a yield-generating protocol, the VASP reports the receipt tokens instead of the original asset. Balances must reconcile with the VASP's internal and accounting records.
For US dollar conversion, trades in pesos or another currency are valued at the exchange rate of each trade date, and assets with no direct US dollar quote are converted through their USDT or USDC price, at 1:1 parity. For this purpose Resolution 1172 adds definitions of BTC, USDT, USDC, ARS and USD to the general glossary of the CNV Rules.
Our reading. The heavy lifting is in the data, not in the form. Two counting methods coexist (single-sided for total volume, two-sided for the per-asset detail), and client trades must be cleanly separated from proprietary trades and from trades with affiliates made without a client order. The fact that the instructions provide for reporting perpetual contracts does not mean that offering them is authorized; that depends on other rules. One question also remains open. Article 4 of Resolution 1172 itself states that the reporting regime will apply "from November 1, 2026", but it does not say whether the first report in the new format is the one for October, due November 15, or the one for November, due December 15. The text supports both readings.
JFC advises local and foreign virtual asset service providers on registration with the CNV's PSAV Registry, the corporate adjustments the CNV requires, and ongoing compliance before the CNV and the UIF. For questions about how General Resolution 1172/2026 affects your operation, write to us at contact@jfcattorneys.com.
Source: CNV General Resolution 1172/2026 (RESGC-2026-1172-APN-DIR#CNV), Official Gazette, October 15, 2026.