Argentina

The defining development of this cycle is the maturation of the conduct layer sitting atop that registration duty. CNV General Resolution 1058/2025's Chapter III conduct requirements -- which had previously existed on the books without being fully exigible -- became exigible for already-registered PSAVs on 31 December 2025, and current reporting describes the regime as fully in force and operational as of June 2026. This is the difference between a registry (a market-access gate) and a supervised conduct regime (an ongoing custodial and disclosure relationship), and it represents Argentina's clearest tightening signal this cycle. The CNV sits as the standing supervisory authority for this framework.

A de-minimis carve-out tempers the perimeter's reach at its margins: CNV General Resolution 994/2024 exempts aggregate PSAV activity not exceeding 35,000 UVA per calendar month from the registration requirement, giving genuinely marginal or occasional activity room to sit outside the regime without formal registration. This threshold-based exemption is a deliberate design choice rather than a gap, and it should be read as calibrating the perimeter's edge rather than weakening its substantive core.

Taken together, the licensing framework now combines three elements operating simultaneously: an effects-based extraterritorial registration duty, a de-minimis exemption preserving proportionality at the margin, and an exigible conduct code governing custody, segregation, and disclosure once a provider is registered. The reliance on secondary (T4) sourcing for the underlying CNV resolution text -- rather than confirmed review of CNV's own published resolutions -- is the principal limitation on how firmly the exigibility and full-operation claims here can currently be held.

Outlook

The near-term trajectory for crypto licensing in Argentina is tightening, not stabilising. With the conduct regime now exigible, the next material development to watch is less likely to be a new registration requirement and more likely to be enforcement activity, supervisory guidance clarifying the Chapter III conduct obligations in practice, or amendments narrowing or widening the de-minimis threshold. Direct confirmation of CNV RG 994/2024, RG 1058/2025 and RG 1137/2026 against CNV's own published resolution text remains an open verification item and should be prioritised before treating the 'fully operational since June 2026' characterisation as definitively settled.

Against that gap, the CNV's tokenization regulatory sandbox occupies a distinct, security-token-adjacent regulatory track. Established under General Resolution 1069/2025 and subsequent instruments, the sandbox has now been extended by General Resolution 1137/2026 through 2027, and it permits tokenized securities to trade through registered PSAVs. The sandbox functions as an experimental space for tokenized-securities activity that sits alongside, rather than substitutes for, a comprehensive taxonomy -- it lets the CNV observe and calibrate tokenized-securities practice without first resolving the broader classification question for the entire token universe.

The extension itself is a meaningful signal. Rather than allowing the sandbox to lapse or converting it into permanent rules this cycle, the CNV has chosen to keep the experimental track open for a further period, which suggests that any comprehensive taxonomy effort, if and when it arrives, is not imminent within the current horizon.

Outlook

The token classification module is likely to remain a persistent structural gap in the near term. The sandbox extension through 2027 is the operative horizon marker: watch for whether experience gained through the sandbox feeds into a future comprehensive taxonomy, or whether the sandbox itself becomes a semi-permanent parallel track for tokenized securities rather than a transitional bridge to one. Until either resolves, tokens outside the sandbox's tokenized-securities scope continue to be classified, if at all, through the general PSAV lens rather than through instrument-specific rules.

The one dedicated stablecoin-adjacent development this cycle is CNV RG 1125/2026, which formally recognises bitcoin, ether and stablecoin holdings as countable patrimony for purposes of reaching the 350,000 UVA net-worth threshold required to qualify as a sophisticated or qualified investor. This is a Probable-confidence, T4-sourced claim, and it is properly understood as an investor-status recognition mechanism rather than a prudential stablecoin regime: it affects who counts as a qualified investor for other regulatory purposes, not how stablecoin issuers themselves are regulated.

Taken together, the regime for stablecoins in Argentina is best characterised as emerging and indirect: enforcement (ARGt) has moved faster than dedicated rulemaking, and the one rule specifically naming stablecoins (RG 1125/2026) addresses investor qualification rather than issuance or redemption standards. This leaves an open question of how a stablecoin structured differently from ARGt — for instance, one not offering a yield and not structured as a security — would be treated, since the current enforcement precedent is securities-law-specific rather than a general stablecoin standard.

Outlook

The absence of a dedicated stablecoin statute means the regulatory treatment of any new stablecoin product in Argentina will likely continue to depend on its specific structure and whether it triggers securities-law classification, as ARGt did. Watch for whether the CNV or BCRA moves toward a more general stablecoin framework, particularly given the BCRA's own characterisation of crypto operations as FX transactions, which could eventually intersect with stablecoin-specific cross-border considerations.

Together these two obligations convert PSAV registration from a market-access formality into an ongoing custodial and service-standard relationship supervised by the CNV. This is a materially tighter posture than existed before Chapter III became exigible, and it is the clearest consumer-facing manifestation of Argentina's broader licensing tightening this cycle.

What is not yet independently confirmed is the granular content of the disclosure and complaints-handling standard -- what must be disclosed, on what timeline complaints must be resolved, and what recourse exists if a PSAV fails to comply. The claims underlying this module rest on secondary reporting of RG 1058/2025's Chapter III rather than direct review of the CNV's own resolution text.

Outlook

The consumer protection posture should be expected to firm up further as the conduct regime beds in operationally through the remainder of 2026. Watch for CNV enforcement actions or guidance addressing specific custody or segregation failures, which would be the clearest signal of how seriously the Chapter III conduct rules are being supervised in practice rather than merely codified. Direct confirmation of the CNV's own resolution text remains the priority verification gap for this module.

The material new development this cycle is RG 5804/2025, an information-reporting regime requiring exchanges and virtual-asset wallets to report user crypto-asset movements to the tax authority -- now ARCA, following AFIP's institutional succession -- on a monthly basis, effective from May 2026. This is a visibility instrument rather than a rate change: it does not alter what is taxed or at what rate, but it substantially increases ARCA's ability to observe on-platform crypto activity at the individual level and cross-reference it against capital-gains and wealth-tax filings. Read together, the capital-gains rates, the wealth-tax treatment, and the new reporting obligation constitute a coordinated tightening of the fiscal perimeter around registered intermediaries operating in Argentina, even though none of the three, taken alone, represents a rate increase.

Outlook

The tax-treatment trajectory is tightening through visibility rather than through rate escalation. The May 2026 effective date for RG 5804/2025 reporting means the regime should already be generating monthly reporting flows by the time of this cycle's coverage; the next material development to watch is whether ARCA begins using that reporting data for enforcement or cross-matching against capital-gains and Bienes Personales filings. Direct confirmation of RG 5804/2025's exact text and in-force date against ARCA's own circular remains an open verification item.

This test is confirmed rather than newly introduced this cycle, but it remains the operative mechanism through which cross-border virtual-asset activity touching Argentina is drawn into the domestic regulatory perimeter, and it continues to interact with adjacent frameworks -- most notably BCRA's payments regulation for payment-account-adjacent virtual-asset services -- in ways that mean cross-border providers assessing their Argentine exposure need to read the CNV capture test alongside, not instead of, central-bank payments oversight.

Outlook

The cross-border capture test is unlikely to loosen in the near term given the broader tightening trajectory evident across Argentina's licensing and conduct modules this cycle. Watch for CNV guidance or enforcement clarifying how the 'significant volume' and 'targeting' prongs of the test are applied in practice, since these are the most fact-dependent and least self-executing criteria in the test as currently described.