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Ohio regulates money transmission under the state Money Transmitters Act (ORC Chapter 1315), administered by the Division of Financial Institutions (DFI) via NMLS. Licensure is required of any person receiving money for transmission from a person located in Ohio regardless of the licensee's own location, subject to bank/credit-union and other statutory exemptions. Minimum net worth of $500,000 and a security device (surety bond) of $300,000-$2,000,000 are standing capital/security requirements. HB 116 (Ohio Blockchain Basics Act) is in the General Assembly review stage and would exempt pure crypto mining/staking/exchange activity from MTL requirement.
Licensees must also maintain a minimum net worth of $500,000 and a surety bond ranging from $300,000 to $2,000,000, calibrated at the Superintendent's discretion to reflect transaction volume.
A pending bill, HB116 (the Blockchain Basics Act), passed the Ohio House 68-26 in June 2025 and would carve crypto mining, staking, and exchange activity out of the MTL requirement, but it remains stalled in the Senate; the carve-out is not yet operative and its current committee status was not independently re-verified this cycle.
Outlook
The determinative near-term event for this module is Ohio Senate floor action on HB116: enactment would activate the crypto carve-out and meaningfully narrow the MTL perimeter, while continued inaction preserves the current blanket licensing requirement for any crypto-asset activity that meets the statute's money-transmission definition.
Licensing, Authorisation & Market Access
Ohio's baseline money-transmission licensing framework already covers crypto-adjacent activity: the Division of Financial Institutions' Money Transmitters Section regulates money transmitters doing business in Ohio, including businesses that buy or sell cryptocurrency. This is confirmed, established regulatory ground administered under the state's general money-transmitter licence category, and it sits within a much larger nonbank licensing apparatus, the Division administers twelve distinct consumer-finance licensing regimes and held over 28,000 licenses as of the most recent count, indicating that money transmission is one of several licensing lines the same regulator manages at scale. Applications for the Ohio money-transmitter licence are accepted exclusively through the Nationwide Multistate Licensing System, the shared multistate application channel used by most U.S. states, meaning entrants seeking Ohio authorization already interact with a familiar, standardized process rather than a bespoke state-specific portal.
The cycle's substantive development is Ohio House Bill 648, which would extend a specific registration obligation to owners and operators of digital-asset kiosks, requiring them to register as money transmitters and to provide mandatory pre-transaction risk disclosures. The stated rationale is elder-fraud prevention, reflecting documented concern about the use of unattended crypto kiosks to defraud vulnerable consumers. The bill is currently pending in the House Financial Institutions Committee and has not been enacted. Because HB648 operates as an extension of the existing general money-transmitter licence category rather than the creation of a wholly new licence type, its effect, if enacted, would be to close a device-specific gap in the current perimeter rather than to restructure Ohio's money-transmission licensing regime as a whole. The distinction carries through the bank-versus-nonbank frame that structures this module: kiosk operators captured by HB648 would fall within the nonbank_pi_emi category already used for general money-transmitter licensees, with no separate bank-channel implication evidenced this cycle.
Outlook
HB648's progress through the House Financial Institutions Committee is the item to watch, with an estimated resolution window as far out as 2027 Q1 and a correspondingly wide, year-scale uncertainty band reflecting the bill's early legislative stage. Passage would formalize kiosk-specific money-transmitter registration as a distinct sub-category of Ohio's existing licensing perimeter; continued pendency would leave kiosk operators subject only to whatever general money-transmitter obligations already apply to them under current law.
1 earlier distinct update(s)
Licensing, Authorisation & Market Access
Ohio's money-transmitter licensing regime already operates on a receipt-based extraterritorial trigger: any person receiving money for transmission from a person located in Ohio must be licensed under the Ohio Money Transmitters Act, regardless of where the transmitting entity itself is domiciled. This structural feature means the licensing perimeter already reaches non-bank payment institutions and e-money issuers transacting into Ohio from outside the state, not only Ohio-domiciled firms. Applicants face a five-thousand-dollar new-licence application fee and a twenty-five-hundred-dollar change-of-control application fee, and licensees are expected to register federally with FinCEN as money-services businesses and to screen counterparties against the OFAC Specially Designated Nationals list.
This cycle's material development is Ohio House Bill 648, which would extend this same non-bank licensing perimeter to a category not currently captured by it: owners, operators, and facilitators of digital-asset kiosks. Under the proposal, kiosk operators would need money-transmitter licensure plus mandatory KYC, consumer disclosures, and elder-focused transaction-approval holds. The bill has not been enacted and remains before the House Financial Institutions Committee; its introduction follows the bankruptcy and cessation of operations of a nationwide crypto-ATM kiosk operator, which exposed the absence of a distinct licensed category for the kiosk channel under the existing statute. This extraterritorial trigger and the pending kiosk extension are both coded at an elevated impact level in this cycle's tracking, reflecting the potential breadth of firms brought within scope: the extraterritorial receipt-based rule already has broad application to any entity receiving Ohio-originated funds for transmission, and the kiosk extension would materially widen the population of digital-asset intermediaries subject to state licensure. The DFI's fee schedule and federal-registration expectations, by contrast, are tracked at a monitored rather than elevated level, reflecting their status as standing operational requirements rather than a new source of regulatory change this cycle. All of this activity sits within the non-bank PI/EMI segment specifically — bank-chartered payment providers' Ohio market access runs through separate banking-law channels untouched by this cycle's developments.
Outlook
HB648's expected resolution window is 2026 Q4, carrying a half-year uncertainty band, and its committee trajectory is not yet determinable from current sourcing. If enacted, kiosk operators would become the newest addition to Ohio's non-bank money-transmitter population, subject to the same fee schedule and federal MSB-registration and OFAC-screening expectations already borne by existing licensees. Market entrants and existing licensees operating adjacent digital-asset infrastructure in Ohio should treat the bill's committee progress as the clearest near-term signal of whether the state's licensing perimeter formally captures the kiosk channel.
Sources and findings (7)
- T1https://com.ohio.gov/divisions-and-programs/financial-institutions/money-transmitters/money-transmitters
- T1https://codes.ohio.gov/ohio-revised-code/chapter-1315
- T3https://www.bondexchange.com/ohio-money-transmitter-bond-a-comprehensive-guide/
- T1http://archives.legislature.state.oh.us/analysis.cfm?ID=126_HB_454
- T3https://cryptoslate.com/ohio-passes-blockchain-bill-allowing-200-tax-free-bitcoin-payments/
- T3https://www.chaincatcher.com/en/article/2169351
- T3https://moneytransmitterlaw.com/state-laws/ohio/