Can a foreign fintech lend in Argentina using crypto? The honest answer: there is no crypto lending license here, and that is exactly why the question needs care. Two separate regimes can reach the same product, one for the lending and one for the virtual assets, and the structure decides which of them applies.
The lending leg: OPNFC registration before the BCRA
You do not need to be a bank to lend in Argentina. Companies that offer credit to the public on a habitual basis without a financial license fall under the BCRA's framework for non-financial credit providers, the PNFC. For a fintech lending its own capital, the usual category is OPNFC, Otros Proveedores No Financieros de Crédito.
The category is broad. It can cover consumer loans, merchant financing, BNPL-style products, working-capital lines, payroll advances and digital credit offered through an app or website. Funding the loans with the company's own equity or group treasury does not take the lender out of the framework. Registration brings reporting duties, total cost of credit and transparency rules, and consumer protection obligations. Our consumer lending service page covers the framework in detail.
The sector this framework governs is anything but marginal. The BCRA's latest report counts 585 registered PNFC companies, with the fintech group growing 47% year on year and passing 7 million clients. We covered the numbers, including a delinquency rate that reached 26.9%, in our note on the BCRA report.
The crypto leg: PSAV registration before the CNV
Argentina regulates virtual-asset services through the CNV's PSAV registry, created by Law No. 27,739 and regulated by CNV General Resolution No. 1058/2025. The perimeter covers exchange between virtual assets and fiat currency, exchange between virtual assets, transfer, custody or administration of virtual assets, and related financial services. Registration also brings anti-money-laundering obligations before the UIF.
Using blockchain or stablecoins somewhere in the operation is not what triggers registration. What matters is whether the company provides one of those virtual-asset services in or from Argentina, or to Argentine users. There is no discretionary license involved: a company inside the perimeter registers and complies. Our PSAV service page explains the filing and what comes after.
When one product touches both
Picture three configurations of the same business idea. (i) The company lends pesos through an app and simply keeps part of its treasury in crypto: the lending leg points to OPNFC, and holding crypto for itself does not, on its own, place the company inside the PSAV perimeter. (ii) The company disburses loans in stablecoins, or takes crypto from borrowers as collateral and holds it: now it is transferring or custodying virtual assets for clients, and the PSAV analysis becomes unavoidable, alongside the lending framework. (iii) The company also lets users buy, sell or store crypto in the same app: that is exchange and custody, squarely PSAV territory, on top of OPNFC for the credit.
Same idea, three different regulatory maps. That is the general rule for fintech in Argentina: what the product actually does, function by function, determines which regulators and registrations apply. Our fintech regulation guide maps both perimeters with their obligations and frequent questions.
What to review before launch
A crypto lending product coming into Argentina should test (i) whether the lending activity requires OPNFC registration with the BCRA, (ii) whether any leg of the product touches the PSAV perimeter before the CNV, and (iii) how AML, consumer protection, tax, foreign exchange and data rules land on the specific structure. The order matters: the registrations shape the corporate setup, the flow of funds and even the product's unit economics, so the perimeter analysis belongs at the design stage, not after launch.
At JFC we run this analysis for foreign and local fintechs, handle OPNFC and PSAV registrations, and structure the corporate and funding side. If you are weighing a crypto lending product for Argentina, you can write to us at contact@jfcattorneys.com.