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Vermont has no bespoke EMI/PI regime; nonbank payment and virtual-currency businesses are licensed as money transmitters under 8 V.S.A. Chapter 79. Act 142 (H.648, signed June 16, 2026) extended the virtual-currency-kiosk moratorium from July 1, 2026 to July 1, 2027, materially delaying market access for that channel.
Act 110, enacted in 2024, was the most significant recent legislative event in this module. Its Sections 29 through 49 conformed Vermont's money-transmission statute to the Conference of State Bank Supervisors' Model Money Transmission Modernization Act, while Section 48 created a new Chapter 79 subchapter setting bespoke virtual-currency business activity requirements distinct from the model law itself. This dual move — harmonizing with the multistate model law on one hand while retaining Vermont-specific virtual-currency provisions on the other — reflects a state that has been regulating virtual-currency business activity for several years and was not starting from a blank slate.
On the compliance-cost side of licensing, a licensing-guide source indicates that Vermont MTL applicants must maintain a minimum tangible net worth of $100,000, post a surety bond of the same minimum amount, register with FinCEN under the Bank Secrecy Act, and expect a licensing process of approximately three months. This figure comes from a single secondary licensing-guide source rather than a primary statutory citation checked this cycle, and should be treated as indicative rather than confirmed pending direct statutory cross-check.
Outlook
With Act 110's CSBS-model conformance now in force, Vermont's licensing architecture is unlikely to see further structural change in the near term; the module's live edges are downstream in the virtual-currency subchapter it created rather than in the core MTL framework itself.
Licensing, Authorisation & Market Access
Vermont's Act 142 (H.648), signed June 16, 2026, extends the moratorium on new virtual-currency-kiosk operations under 8 V.S.A. Section 2577(f) from July 1, 2026 to July 1, 2027. Kiosks operational on or before June 30, 2024 are grandfathered and may continue operating; the restriction applies only to new deployment. This is the third consecutive annual amendment to Chapter 79's virtual-currency provisions, following prior amendments in 2024 and 2025, and represents a sustained tightening of market access specific to the kiosk channel.
Outside the kiosk-specific restriction, Vermont's general money-transmitter licensing regime remains structurally stable and CSBS Model Act-aligned. A money transmitter licence costs two thousand one hundred dollars in total fees (one thousand dollars licensing, one thousand dollars investigation, one hundred dollars NMLS processing), requires a surety bond starting at one hundred thousand dollars and scaling to a Commissioner-set cap of two million dollars, and requires tangible net worth of the greater of one hundred thousand dollars or three percent of the first one hundred million dollars in total assets. Act 110 of 2024 rebuilt this framework onto the CSBS Model Act and codified virtual currency as a permissible investment only to the extent it matches outstanding transmission obligations in identical denomination — a reserve-matching mechanic rather than a dedicated stablecoin regime. No separate crypto-specific licence class exists; virtual-currency businesses, including exchanges and custodians, operate under the same general money transmitter licence as other payment companies.
Outlook
The kiosk moratorium is due to expire July 1, 2027 absent further legislative extension. Given three consecutive years of annual extension, continued tightening into the 2027 legislative session is plausible, though not certain from the statute itself. This is the principal near-term item determining whether new kiosk-channel market access becomes available in Vermont for the first time since the restriction was imposed.
2 earlier distinct update(s)
Licensing, Authorisation & Market Access
Vermont Act 142, an omnibus statute signed by Governor Scott on June 16, 2026, makes three distinct changes to the state's payments and money-transmission licensing perimeter. First, it imposes a permanent, statewide prohibition on virtual-currency kiosks; kiosk operators' existing registrations expire and terminate on July 1, 2026, closing what had been a licensed or registered activity outright rather than tightening its conditions. Second, it creates an entirely new commercial-financing-provider licensing and disclosure regime, which becomes operative on July 1, 2027, a substantially longer runway than the kiosk and money-transmission provisions already in force. Third, it amends the money-transmitter licence application provisions, the check-casher and currency-exchange activity provisions, and the virtual-currency conditions-precedent provisions of Title 8, Chapter 79, formalising that control of virtual currency, including control exercised through a private key, is dispositive of money-transmission activity.
Each of these three changes is High confidence and rests on the enacted statutory text itself, a Tier 1 primary source. Read together, they describe a licensing perimeter that is tightening unevenly: the kiosk channel faces an immediate and permanent bar with no cure path, the money-transmission definition is broadened to capture private-key custodial control that might otherwise have sat in a definitional gray area, and an entirely new nonbank licence class is introduced on a delayed, multi-year timeline. All three changes affect nonbank market participants specifically; none of the claims here bears on bank-chartered payment activity, which is licensed and supervised through a separate federal and state banking framework untouched by Act 142.
For market-access purposes, the practical effect is a net narrowing for cash-to-crypto conversion operators and a net broadening of scope for virtual-currency custodians whose arrangements rely on private-key control without falling within a traditional money-transmission structure. The commercial-financing-provider licence class introduces an entirely new category of regulated activity into Vermont's nonbank licensing perimeter, with the eighteen-month gap before its 2027 commencement leaving providers in that sector without a dedicated state licensing or disclosure obligation in the interim.
Outlook
The principal item to track is the eighteen-month gap between the July 2026 kiosk-ban and money-transmission-scope changes and the July 2027 commercial-financing-provider licensing commencement, including whether the Department of Financial Regulation issues interim guidance for commercial financing providers ahead of the statutory effective date. A second item is whether the Department publishes interpretive guidance narrowing or clarifying the newly formalised private-key control test as it might apply to staking, custodial, or other emerging virtual-currency arrangements not contemplated by the kiosk-focused drafting record.
Licensing, Authorisation & Market Access
Vermont enacted Act 142 on June 16, 2026, an omnibus payments and financial-services law that takes effect July 1, 2026, with one component, the commercial-financing licensing and disclosure regime, deferred to July 1, 2027. Three of the law's provisions amend the state's existing money transmitter licence statute directly, and a fourth creates an entirely new non-bank licensing category. All four provisions apply to non-bank money-services businesses; Vermont's money transmitter licence is, and remains, a non-bank authorisation distinct from any bank-chartered payments activity, and Act 142 does not alter that boundary.
The first amendment, to 8 V.S.A. Section 2107, changes the state's change-of-control review process. Persons or groups acting in concert who seek to acquire control of a licensed money transmitter must now submit a request to the Commissioner in advance of the transaction. This formalises a pre-transaction review gate over ownership changes at Vermont-licensed non-bank payments entities, giving the state visibility into, and a checkpoint over, acquisitions and control changes affecting the licensed population.
The second amendment, to 8 V.S.A. Section 2110, updates the Commissioner's authority to suspend, revoke, or issue cease-and-desist orders against money transmitter licensees. Read alongside the change-of-control amendment, this pairs a stronger entry-side control, who may acquire a licensee, with a stronger exit-side control, how the state can act against one, a combination consistent with the broader pattern of states adopting elements of the Conference of State Bank Supervisors' Model Money Transmission Modernization Act to standardise and strengthen non-bank payments supervision.
Third, a new automatic-expiration rule provides that a licence lapses on December 31 if the annual renewal fee has not been paid by December 1. This converts licence renewal from what may have been a more forgiving administrative process into a hard annual deadline with an automatic, not discretionary, consequence for non-payment, adding a compliance-calendar item for every Vermont money transmitter licensee.
Fourth, and structurally distinct from the money-transmission amendments, Act 142 creates a new licensing and disclosure regime for commercial financing providers, a category of non-bank finance that did not previously require state authorisation in Vermont. This new regime becomes effective July 1, 2027, a year after the rest of the Act, giving affected firms a defined runway to prepare for licensing. Taken as a whole, the four provisions move in the same direction: tighter entry-side and exit-side controls over the existing non-bank licensee population, plus an entirely new category of non-bank finance brought inside Vermont's licensing perimeter for the first time.
Outlook
The commercial-financing licensing and disclosure regime is the next dated event on Vermont's non-bank market-access calendar: it becomes effective July 1, 2027, and firms currently operating without Vermont authorisation in that category should expect to need one from that date. In the nearer term, the change-of-control and enforcement-authority amendments are already in force, meaning any pending or contemplated ownership change at a Vermont-licensed money transmitter is now subject to the Commissioner's advance-review requirement, and any licensee facing a compliance issue is now subject to an updated suspension, revocation, or cease-and-desist framework. Vermont's move fits a broader pattern of states adopting stronger non-bank supervisory tools, and the next material development to watch is any implementing guidance the Department of Financial Regulation issues ahead of the 2027 commercial-financing effective date, as well as whether change-of-control filings under the new Section 2107 process begin appearing in licensee-population data.
Sources and findings (5)
- T1https://legislature.vermont.gov/statutes/chapter/08/079retrieved
- T1https://dfr.vermont.gov/industry/banking/financial-services/money-servicesretrieved
- T1https://legislature.vermont.gov/Documents/2024/Docs/ACTS/ACT110/ACT110%20Act%20Summary.pdfretrieved
- T3https://faisalkhan.com/solutions/licensing/money-transmitter-license-mtl/vermont-money-transmitter-license/retrieved
- T1https://dfr.vermont.gov/industry/banking/financial-institutionsretrieved