Argentina (AR)

Licensing, Authorisation & Market Access

Argentina has no single EMI/PI licence; the BCRA operates a functional PSP registration regime under the Financial Entities Law with multiple registrable roles (flagship PSPCP plus payment initiators, acquirers, aggregators/sub-acquirers, transfer-payment acceptors, ATM/EFT networks). This is the defining feature of market access for any non-bank payment institution or EMI-type operator: entry runs through registration of one or more functions rather than acquisition of a unified prudential authorisation. Registration with BCRA is not a prudential banking licence; VASPs register separately with the CNV. Applicants must disclose 10%+ owners/ultimate controllers, designate infosec and payment-system responsible persons, and accept BCRA's regulatory/sanctioning regime, with deregistration for non-compliance. The bank-PSP versus non-bank-PI/EMI distinction is sharp here: a registered PSPCP is a non-bank payment institution operating without the prudential banking licence held by bank PSPs.

The live in-cycle development is the addition of a new regulated category. On 6 May 2026 the BCRA published Communication "A" 8432/2026 updating the PSP framework and adding a new regulated category, "PSP as a Service" (a PSPCP offering payment accounts to clients of a third party via an integrated interface), with a 90-day adaptation window for existing registrants. This formalises a white-label, BaaS-style provisioning model, enabling third-party brands to offer payment accounts without their own registration — a structural market-access shift for embedded finance.

Sequencing matters for time-to-market. Communication "A" 8102 (September 2024) ended simultaneous multi-function PSP registrations: a PSP must complete and obtain certification for one function before initiating registration for another, and imposed a detailed quarterly informational regime on PSPCPs. For a multi-role non-bank operator this lengthens onboarding and raises the ongoing compliance-reporting burden.

Outlook

The near-term anchor is the close of the 90-day PSP-as-a-Service adaptation window in the third quarter of 2026, by which existing PSPCP registrants must align with the new category. The combination of a formalised embedded-finance route and the sequenced multi-function registration regime points to a maturing but increasingly administratively demanding market-access surface for non-bank operators.

Stablecoins & Digital Money

Argentina's crypto perimeter is now governed by a fully operative VASP/PSAV regime. Law 27,739 (sanctioned 14 March 2024) added PSAVs to AML Law 25,246 and created the CNV registry; CNV RG 994/2024 launched registration and RG 1058/2025 (published 14 March 2025) added operating, custody, governance, cybersecurity and reporting rules, with staggered compliance deadlines (individuals 1 July 2025, AR legal entities 1 August 2025, foreign legal entities 1 September 2025) and most Chapter III requirements exigible for registered PSAVs from end-2025. As of the cycle date those deadlines have passed and the regime is fully in force, affecting exchange and custody operators directly.

The payments perimeter is firewalled from crypto facilitation. Stablecoins are not legal tender but may be held/used by private agreement; banks (Com. "A" 7506) and regulated PSPCPs (Com. "A" 7759, 4 May 2023) are barred from offering or facilitating client crypto transactions (including making automated purchase buttons available), with no Argentina-specific reserve/prudential regime for stablecoin issuers and no statutory par-redemption right. This bar separates the regulated payment rail — where non-bank PSPCPs operate — from the crypto perimeter, blocking wallet-embedded stablecoin buy buttons despite high de facto adoption.

That adoption is the market backdrop. Stablecoins account for a majority share of local crypto transaction volume as a de facto digital dollar; UIF Resolution 49/2024 requires PSAVs to run a risk-based program, designate an MLRO and report virtual-asset operations at/above defined thresholds with travel-rule obligations. The illicit-finance dimension of this de facto digital-dollar use is routed to the Financial Integrity Monitor.

Outlook

With the PSAV regime fully exigible, the trajectory is consolidation of the registered crypto perimeter alongside a maintained payments-rail bar on in-app facilitation. The tension between strict facilitation prohibition and majority-share stablecoin adoption is the durable structural feature to watch.

Payment Corridor Dynamics

The corridor environment has been transformed by FX liberalisation. As of 14 April 2025 Argentina lifted most currency controls ('cepo cambiario') via Com. "A" 8226 and Decree 269/2025, removing the USD200 monthly cap, prior 30-day import waiting periods and most repatriation restrictions, eliminating the SIRA/SIRASE import system, and permitting dividend transfers abroad for profits from fiscal years beginning on/after 1 January 2025, supported by a USD20bn IMF agreement; September 2025 eased most remaining controls. This reopens cross-border corridors for both individuals and businesses and is the single most structurally significant payments development for providers serving Argentina.

Liberalisation does not fully resolve operational friction. Personal remittance inflows were ~USD1.04bn in 2024 (~0.2% of GDP); even after the April 2025 reform, cross-border payments often involve costly intermediary hops (ARS to USD to a third currency) and significant currency risk, with stablecoins used informally to hedge peso risk and move value over weekends. Residual intermediary-hop friction sustains demand for stablecoin-based informal corridors and fintech cross-border solutions. The informal stablecoin corridor dimension carries illicit-finance significance routed to the Financial Integrity Monitor.

Outlook

The access direction is opening, but the corridor remains shaped by intermediary-hop cost and currency risk that liberalisation alone does not dissolve. Quantitative corridor-flow data beyond the ~USD1.04bn 2024 remittance figure remains under-indexed; the durable watch item is whether formal-rail cost compression displaces informal stablecoin transfer over time.

Legal & Litigation

The institutional foundation of payments antitrust has shifted. The National Competition Authority (NCA) began exercising enforcement functions on 17 November 2025, replacing the CNDC which ceased to exist after 45 years. As of the cycle the NCA is the operative antitrust authority; any ongoing competition matters, including the MercadoLibre/MODO dispute filed with the CNDC in 2024, are now under NCA jurisdiction. This corrects any assumption that the CNDC remains the relevant authority for payments-market disputes.

The live clash is the central payments-antitrust matter. In May 2024 MODO (a bank-owned digital-wallet consortium) complained that MercadoLibre monopolises digital payments; in August 2024 MercadoLibre counter-complained that the banks 'cartelise' through the consortium to undermine fintechs, citing the 2018 Prisma precedent. The dispute, filed with the CNDC, now falls under NCA jurisdiction. Its outcome could reshape the bank-fintech competitive balance and set precedent on consortium wallets.

The landmark precedent gives the clash its analytical roots. The Prisma case (CNDC investigation opened 2016) led to a 2018 divestment remedy — the banks' sale of Prisma Medios de Pago, the unique Visa acquirer/processor — the first divestment remedy in an Argentine conduct case, opening the acquiring market, accompanied by the May 2018 Antitrust Law 27442 introducing leniency and ex-ante merger control. That remedy is now directly relevant context for Visa's 2026 reacquisition of Prisma under NCA merger review.

Outlook

The trajectory is updated: jurisdiction has migrated to the NCA and ex-ante merger control is becoming operative. No source quantifies the timeline or substantive scope of the MercadoLibre/MODO transfer or any NCA ruling, so procedural status remains inferred rather than confirmed. The watch items are NCA review of the Visa-Prisma/Newpay deal and any progression of the MercadoLibre/MODO matter.

Commercial Intelligence (M&A, Investment & Product)

The standout commercial event of the trailing window is a card-processing M&A deal. On 19 February 2026 Visa announced a definitive agreement to acquire Prisma Medios de Pago and Newpay from Advent International, and subsequently announced completion of the transaction (subject to Argentine competition-authority review); Prisma provides credit/debit/prepaid card issuer processing; Newpay operates real-time payments, the Banelco ATM network and PagoMisCuentas. Financial terms were not publicly disclosed. Advent had bought 51% of Prisma at a USD1.42bn valuation in 2019. The deal status is completed, with deal value not publicly disclosed; the only valuation anchor available is the 2019 Advent transaction.

This is a discrete M&A event, distinct from the structural market-landscape view carried under W6. Visa reuniting major Argentine card-processing infrastructure (6bn+ annual transactions, Banelco ATM network, PagoMisCuentas) reverses the 2018 antitrust divestment and concentrates processing — a structural market-power shift now under NCA scrutiny. The parties are Visa (acquirer), Prisma Medios de Pago and Newpay (targets) and Advent International (seller).

Outlook

The escalating trajectory reflects the re-concentration of card-processing infrastructure under Visa, subject to NCA merger review. The watch item is the competition-authority assessment of a transaction that partially reverses the landmark 2018 divestment remedy; deal-terms signal remains under-indexed given undisclosed financial terms.

Conduct, Safeguarding & Promotions

Safeguarding is the binding conduct constraint on non-bank payment institutions in Argentina. PSPCP regulation (Com. "A" 6859, January 2020) requires 100% of customer funds to be held at all times in on-demand peso accounts at Argentine financial institutions, individualised per customer, available instantly on request, and segregated from the PSP's own funds; balances may not be used as treasury, and any return must be passed through to customers (Com. "A" 7825, August 2023). For a non-bank PI/EMI this removes float economics entirely: operators cannot monetise customer balances as treasury, which directly shapes wallet business models. The mechanism is full segregation into sight accounts held at regulated banks — a structural dependency of the non-bank on the bank layer.

Conduct and anti-fraud obligations sit alongside safeguarding. During 2022 the BCRA set special authentication and cybersecurity requirements for PSIs and PSPCPs, defined consumer-protection responsibilities and required anti-fraud measures, strengthened for all PSPs in 2023, applying a functional 'same function, same risk, same rules' approach across banks and PSPs. This functional-parity stance is the analytical key to the bank-versus-non-bank distinction in conduct: the same authentication and anti-fraud duties apply to a bank PSP and a non-bank wallet performing the same function, levelling the conduct playing field even where prudential treatment differs.

Outlook

The safeguarding standard remains stable as the live W1b anchor; full 100% peso segregation with mandatory return pass-through is the durable fund-protection baseline. The functional 'same function, same risk, same rules' conduct posture is likely to continue narrowing the conduct gap between bank and non-bank providers as the BCRA extends authentication and anti-fraud expectations across the perimeter.

Operational Resilience & Critical Infrastructure

Operational-resilience obligations now reach both bank and non-bank operators on a functional basis. Com. "A" 8280 updated the cyber incident response/recovery Guidelines (originally Com. "A" 7266, April 2021), applying mandatorily to banks, PSPs (digital wallets, aggregators, facilitators) and systemically important payment systems, with an express duty to notify the BCRA of incidents (including loss/unauthorised disclosure of critical customer data) plus a final root-cause report within five calendar days. The five-calendar-day final-report deadline and broad PSP scope materially raise resilience-compliance obligations for non-bank wallets and facilitators that were historically outside such reporting regimes.

The underlying ICT-risk standard sets the baseline. Com. "A" 7724 (enforceable from 6 September 2023, replacing "A" 4609) sets minimum IT and security risk-management requirements aligned with operational resilience, a three-lines-of-defence scheme, and specific controls over AI/ML, technological obsolescence and cyber-incident scenarios. This standard applies across banks and PSPs, establishing a common resilience floor that both layers must meet.

Outlook

The escalating trajectory reflects a tightening incident-reporting and ICT-risk regime that progressively extends bank-grade resilience expectations to the non-bank payments layer. The five-calendar-day reporting clock and three-lines-of-defence expectation are the operative compliance anchors going forward.

Scheme & Network Compliance

Argentina's instant-transfer scheme is the central compliance object of this module. For the instant-transfer scheme the BCRA mandates interoperable QR acceptance, caps merchant fees (typically 6-8 per thousand) as fixed-per-transaction (not ad valorem) amounts plus interchange paid by recipient to originator; transfers are free for receivers in the first three months up to a UVA threshold. Transfers 3.0 credits within 15 seconds, 24/7, push and pull, with irrevocable instant merchant crediting. Fixed-per-transaction fee caps and mandated interoperable QR materially compress acquiring economics and let fintechs compete with banks on a low-cost rail.

The QR-interoperability mandate has been progressively extended into card rails. Communication "A" 7769 (18 May 2023) expanded QR-code interoperability so any digital wallet can read QR codes for credit-card payments, aligned acceptor/acquirer/sub-acquirer registration requirements, and required CIMPRA technical-standard compliance; from April 2025 the BCRA required interoperable wallets to enable debit-card QR payments (pesos and dollars, merchant-optional for dollars) and extended credit-card fraud-liability and commission-limit rules to debit, assigning fraud liability to the interoperable-wallet provider in defined cases. Mandated cross-wallet QR for credit and debit dismantles closed-loop QR moats and shifts fraud liability onto the interoperable-wallet provider.

Outlook

The escalating trajectory points to continued extension of interoperability obligations and fraud-liability allocation across instruments. The scheme-compliance surface is consolidating around mandated openness and capped, fixed-per-transaction economics — a durable structural pressure on closed-loop scheme economics.

Industry Structure & Commercial Dynamics

The Argentine PSP market is unusually dynamic. The PSP market is highly dynamic: Mercado Pago (Mercado Libre) is the dominant wallet, the bank consortium MODO competes, Ualá (9m+ customers since 2017) and others are significant; digital wallets account for nearly half of e-commerce spend (projected ~59% by 2027). PSP account ownership among adults rose from 7% in 2019 to 71% in 2024. Processing was historically concentrated in Prisma (divested after a 2018 antitrust remedy). The structural picture is one of explosive wallet adoption, a dominant non-bank platform, and a bank consortium positioned as the principal competitive response.

This structural landscape is distinct from the discrete Visa-Prisma transaction carried under W13: here the focus is on the competitive battleground itself. The near-tenfold rise in wallet ownership over five years and Mercado Pago's dominance define the field, while Transferencias 3.0 supplies the low-cost rail on which fintechs compete directly with banks.

Outlook

The trajectory is stable in structural terms — a maturing competitive duopoly-of-models between the dominant fintech wallet and the bank consortium, both operating on a mandated-interoperable rail. The competitive question to watch is whether interoperability and Open Finance erode platform-level advantages, redistributing share across the wallet and bank layers.

Merchant Acquiring & Risk

Acquiring roles in Argentina sit within the registrable perimeter. Acquiring, aggregation/sub-acquiring and acceptance roles are BCRA-registrable (Com. "A" 7769), with applicants reporting merchant fees, settlement times and POS terms. The market distinguishes acquirers (Payway/Getnet/Fiserv, ~0.8%-2%+VAT high volume) and integrated platforms (Mercado Pago ~4.32%-6.60%+VAT), with reference rates ~1.2%+VAT debit and ~4.5%+VAT credit; QR transfer payments are materially cheaper. BCRA chargeback windows tend to be shorter and consumer-favouring. The non-bank PI/EMI dimension is prominent here: integrated platform acquirers operate at materially higher take rates than traditional acquirers, while the QR rail undercuts both.

Card MDR spreads and consumer-favouring chargeback rules shape acquirer economics, and the QR rail's cost advantage pressures card acceptance directly. This is an under-evidenced area: merchant-acquiring operational detail — chargeback windows in days, decline-rate breakdown by MCC, sub-acquirer settlement timing — rests on flagged specialist/vendor sources without primary BCRA confirmation, so these positions are assessed rather than confirmed.

Outlook

The trajectory is stable, with the dominant structural pressure being the cost gap between card acceptance and the QR transfer rail. The watch item is the extent to which QR migration continues to compress card-acquiring volumes and take rates, against thin primary sourcing on acquiring operations.

Product Innovation & Market Development

The forward product development of the cycle is open finance. Decree 353/2025 (23 May 2025) created the Sistema de Finanzas Abiertas (Open Finance), with the BCRA as implementing authority, an API consent-based data-sharing model on the Brazil/Mexico/Colombia template operating on a reciprocity principle, with ARCA, CNV, the Insurance Superintendency and Anses participating and a Consultative Council to be created. The BCRA published its Principal Variables API as the first of a catalogue. A reciprocity-based open-finance regime opens consented data sharing for credit and competition — a structural opportunity for fintech and BaaS providers and a thematic product-access development distinct from any single product launch.

Recurring-payment and data products have also been added. From 28 February 2025 users can pay via Scheduled/Recurring DEBIN in fixed instalments (pesos or dollars) with one-time prior authorisation, and the BCRA published its Principal Variables API as the first of a catalogue toward Open Finance; dollar-denominated QR debit payments were also added. Recurring DEBIN and dollar QR debit broaden A2A use cases for subscriptions and dollarised payments.

Outlook

The escalating trajectory points to a progressive Open Finance API-catalogue rollout through the second half of 2026 as reciprocity-based data sharing operationalises beyond the Principal Variables API. The product surface is widening toward data-portability-enabled credit and account products.

Consumer Protection & APP Fraud

Argentina's consumer-protection regime allocates fraud liability without a statutory reimbursement mandate. Financial consumer protection rests on BCRA user-protection rules plus Consumer Protection Law 24,240 and the Civil and Commercial Code. There is no UK-style statutory APP-fraud mandatory reimbursement scheme, but the BCRA assigned credit/debit-card payment fraud liability to the interoperable-wallet provider in defined cases, set maximum commissions, and requires banks to reimburse customers within 10 working days for incorrectly applied offers/discounts. The fraud-liability allocation to interoperable-wallet providers shifts loss exposure onto wallet operators absent an APP reimbursement mandate.

The fraud landscape is the pressing context. Under Transferencias 3.0, A2A payments clear instantly and are hard to reverse, so authorised push payment (APP) scams thrive — now called the fastest-growing fraud type in LATAM — with Buenos Aires fraud complaints rising over 43% in a year, mostly payment-related. Across Latin America ~20% of card transactions are declined as fraudulent (twice the global average). Rapid APP-scam growth on irreversible instant rails raises pressure for reimbursement frameworks and fraud-prevention investment. These fraud-trend figures rest on a single specialist source and are assessed rather than confirmed.

Outlook

The escalating trajectory reflects the structural mismatch between irreversible instant rails and the absence of a statutory APP reimbursement scheme. The watch item is whether scam growth prompts a move toward mandatory reimbursement or further fraud-liability reallocation.

AML/CFT & Financial Crime

This module carries the Sentinel.gi feed surface only; original illicit-finance analysis is routed to the Financial Integrity Monitor. Per the Sentinel feed (FATF/GAFILAT source), the December 2024 FATF/GAFILAT mutual evaluation found Argentina has a well-designed AML/CFT supervision framework but is not achieving greater effectiveness due to serious human and IT resource constraints, especially at the FIU (UIF); FATF approved the report and did not place Argentina on the grey list. The MER flagged gaps in assessing ML risks for informal financial services, corruption, trade-based ML and sectoral risks including VASPs. These supervision gaps are relevant to payments and crypto operators' AML exposure as carried provenance, not as a WPM illicit-finance conclusion.

The obligated-subjects perimeter is also carried via Sentinel. The UIF is the AML/CFT/proliferation-financing enforcement authority; PSPs, NFCPs, crowdfunding platforms and VASPs are obligated subjects under Law 25,246 (as amended by Law 27,739). Payments-relevant supervision is shared with the BCRA and ARCA. The bank-versus-non-bank spread is captured in this shared supervision: non-bank PSPs and VASPs carry full obligated-subject AML/CFT duties alongside bank entities.

Outlook

The trajectory is stable on the Sentinel surface: an off-grey-list status with persistent FIU resource constraints and developing VASP-risk understanding. Deeper analysis of illicit-finance use of payment instruments is a cross-reference to the Financial Integrity Monitor, not a WPM conclusion.

Correspondent Banking, Settlement & Access

The analytical spine of this module is the bank versus non-bank access asymmetry. Settlement of retail instant payments runs through BCRA-authorised clearing houses/administrators (Coelsa, Prisma, Red Link, Interbanking; the FPS is operated by competing schemes managed by Red Link, Newpay and Compensadora Electronica SA), with the BCRA setting regulation under a functional same-function/same-risk/same-rules approach. PSPCPs access settlement indirectly via mandatory 100% peso safeguarding accounts at financial institutions. That indirect access is the structural asymmetry: non-bank PSPs reach the instant rail only through accounts held at banks, while banks settle directly.

That dependency is sharpened by de-risking. Many Argentine banks refuse to onboard PSPs over AML concerns, pushing some firms to rely on EMI solutions or offshore banking; cross-border transactions face capital-control-linked scrutiny and documentation checks, and global rails such as PayPal, Wise or Stripe remain unavailable or severely restricted for Argentine business accounts — indicative of correspondent/settlement access friction. Bank de-risking and restricted global-rail access constrain PSP banking and cross-border options. These de-risking claims rest on low-tier vendor sources and are assessed rather than confirmed; the quantitative scale of bank-onboarding refusal is not corroborated by primary or specialist sourcing.

Outlook

The trajectory is stable, with the bank-onboarding-refusal dynamic persisting despite FX easing. The structural watch item is whether the non-bank layer's indirect-access dependency on banks tightens or loosens as correspondent and onboarding practices evolve.