On October 22, 2025, the National Securities Commission (“CNV”, after its spanish acronym) published Interpretative Criterion No. 100 (the “Criterion”), through which it clarified the scope of supervision and oversight applicable for the year 2025, as set forth in Article 8 of Section IV, Chapter XV, Title XVIII of the CNV Regulations (N.T. 2013, as amended).
Pursuant to the Criterion, if a Virtual Asset Service Provider (“VASP”) chooses to carry out its activities through a company incorporated in Argentina that was registered after October 15 of the current year, it shall not be required to pay the annual fee for the year 2025 again, provided that the foreign company has already made such payment and its registration remains in force as of October 15. In such case, the payment made by the foreign VASP shall be deemed to extend to the local successor entity for fiscal year 2025.
As from fiscal year 2026, the general regime of individual and annual payment provided for under the applicable regulations shall apply, with the local entity being responsible for the payment of the fee corresponding to each fiscal year.
