Interpretative Guideline on Minimum Net Worth of Virtual Asset Service Providers

On July 15, 2025, the National Securities Commission (the “NSC”) approved Interpretative Guideline 96, clarifying the requirements for demonstrating compliance with the Minimum Net Worth (“MNW”) of Virtual Asset Service Providers (“VASPs”) established in General Resolution 1058/2025.

The requirements are as follows:
– The entity’s share capital must be fully paid-in at the time of registration and while remaining on the VASP Registry.
– The share capital must be registered with the Public Commercial Registry (PCR).
– In the case of irrevocable contributions, they must be capitalized prior to the registration application in the VASP Registry. VASPs already registered under General Resolution 994/2024 must demonstrate that irrevocable contributions have been capitalized and that the resulting capital increase has been registered in the PCR.
– Irrevocable contributions received during the VASP Registry period must be capitalized within six months from their acceptance by the governing body.

VASPs registered under General Resolution 994/2024 must demonstrate compliance with the MNW before November 30, 2025. Remaining documentation must be submitted through the Financial Information Highway (FIH) by August 1, 2025, or September 1, 2025, as applicable, in accordance with General Resolution 1058/2025.

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