Crypto asset company registration has opened in Uruguay: what they must do before March 31

What this is about

The National Budget Law 2025–2029 (Law No. 20.446, art. 693) amended article 37 of the BCU's Organic Charter (Law No. 16.696) to include virtual asset service providers (VASPs) as a new category within the financial system. With this, Uruguay joins the regional trend of requiring prior authorization and prudential supervision for those operating with crypto assets, in line with FATF standards for anti-money laundering.

The Financial Services Superintendency (SSF) of the BCU approved the final regulations through Resolution SSF No. 2026-444 of July 10, 2026, published via Circular No. 2.507. On September 1, 2026, the digital channel for submitting authorization requests went live.

Who is covered

The regulations apply to anyone who provides, on a regular and professional basis, any of the following services:

Exchange of crypto assets for legal tender or between different virtual assets.
Transfer, custody, or administration of virtual assets on behalf of third parties.
Related financial services (e.g., participation in the offering or sale of a virtual asset).

Excluded from scope are those who only participate in the development of software without actively being involved in service delivery, activities already regulated by special laws (book-entry securities with decentralized registration, electronic money), and, in general, non-fungible tokens (NFTs), unless used as a means of payment, investment instrument, or digital representation of a security.

Key deadlines

September 1, 2026: Registration and digital application channel opened at the SSF.
March 31, 2027: Deadline for companies already in operation to submit their authorization request.
June 30, 2027: General deadline to fully comply with the new regulations, unless the rules set a different date for a specific obligation.

Certain specific obligations have their own extended deadlines: for example, originator and beneficiary information in virtual asset transfers (the so-called "travel rule") and certain contractual updates with existing clients may be implemented up to December 31, 2027.

One important point to keep in mind: submitting the application on time does not equal receiving authorization. The BCU has clarified that registration does not grant automatic approval or an immediate permit to operate; while the file is under review, the company may continue operating, but remains subject to the outcome of that review.

Main obligations and requirements

Among the most relevant points of the regulations:

Prior SSF authorization and adherence to principles of loyalty, commercial ethics, and prohibition of unauthorized financial intermediation.
Minimum equity requirements for custody service providers: 1,000,000 UI in equity, 600,000 UI in guarantees, and 50,000 UI in deposits.
Segregation of funds — own funds and client funds must be kept separate, with a 48-hour limit on the retention of third-party funds by the provider.
Corporate governance, technological security, and anti-money laundering as central pillars of the regime.
Mandatory white paper in Spanish or English, containing the information clients must receive before contracting.
Outsourcing permitted with prior notice to the regulator, except for client onboarding.
Automated terminals with a daily operating limit of USD 1,000 per client.

Non-compliance enables the BCU to issue warnings, reprimands, fines (ranging from 50 to 150 times the base fine under article 357 depending on the infraction), or the suspension or cancellation of activities.

Our recommendation

Companies already providing these services in Uruguay — or planning to launch an exchange, custody, or crypto wallet platform — should begin assessing their situation with the SSF right away: verify whether their activity falls within the VASP definition, review their corporate and equity structure against the minimum requirements, and prepare documentation for submission before the March 31, 2027 deadline. Arriving at the deadline in a process that also involves regulatory review is exactly the scenario to avoid.

At SDC, we support fintech and crypto companies through the authorization process before the Central Bank of Uruguay, from regulatory assessment to file submission. If your company provides or plans to provide virtual asset services, reach out and we'll review it together.

Source: Central Bank of Uruguay, Circular No. 2.507 (Resolution SSF No. 2026-444 of 07/10/2026).