New Interpretative Criterion for VASP

The Argentine Securities Commission (CNV) published Interpretative Criterion 100 On October 22, 2025. This Criterion establishes that when a foreign company registered as a Virtual Asset Service Provider (VASP) chooses to conduct its activities through a company incorporated in Argentina, and such local entity obtains its registration after October 15, 2025, the new local company will not be required to pay the 2025 annual fee again, provided that the foreign company has already made such payment and its registration remains valid as of October 15.

As a result, local entities will not be required to pay the 2025 supervision and oversight fee, if they obtain their registration as VASPs after October 15, 2025, and the foreign company has paid the corresponding fee within the established deadline.

Finally, the Criterion provides that, starting in fiscal year 2026, the general annual and individual payment regime established under the current regulations will be applied, and the registered—local or foreign—entity will be responsible for paying the fee corresponding to each fiscal year.