Methodology and sources

Rules reviewed on 2026-11-09 against the text published on InfoLEG (Argentina's official legal database). The assessment is an estimate; the official criteria are those of the Comisión Nacional de Valores (CNV), Argentina's securities regulator.

Applicable rule

Digital representation of securities is governed by Title XXII of the CNV Rules (2013 consolidated text). It was created by RG 1069/2025 (financial trusts and closed-end funds only), extended by RG 1081/2025 (shares, corporate notes, CEDEARs) and reworked by RG 1150/2026, published in the Official Gazette on 11 June 2026 and in force since 12 June 2026.

Rules used

Admitted securities (art. 2). Shares, corporate notes (ON), CEDEARs, publicly offered financial trust securities and closed-end fund units backed mainly by real-world assets, FCIA ETF units and CEVA ETPs. Automatic-authorization regimes are admitted except those for open-end funds; the low-impact regime only with a voluntary prospectus following the medium-impact scheme.
Closed-end funds. At least 5 investors, none above 51% of votes.
Circuit (art. 3). Deposit with a central securities depository (ADCVN) in the name of registered holders; a specialized DLT entity generates the tokens; up to 5 interoperable, CNV-registered VASPs (PSAV) with real-time sync; transfers only among those VASPs, never to decentralized protocols, enforced by smart contracts; prior authorization of the digital representation, even where no prospectus is required.
VASPs (art. 5). Registered in all categories. Pure technology providers do not necessarily need to register as VASPs, unless they perform activities covered by AML law 25,246.
Meetings, certificates, suspension (arts. 6–8). Token lock-up and voting instructions at least 5 days ahead; per-investor holding certificates; trading suspension if the CNV suspends the offering.
Term (art. 9). Until 31 Dec 2027 inclusive; after that no new securities can be issued under the regime, except as needed to comply with art. 17. Securities not represented digitally within 2 years of authorization lapse automatically.
Backup VASP (RG 1081, art. 12 j). Issues above 7,000,000 UVA need at least one backup VASP; several VASPs may back each other up. Since the assessment takes the amount in USD, it reminds you from USD 5 million (own assumption) so you check it with the day's UVA.
Fit. "Would not fit" if the date is after 31 Dec 2027, or for fund units through an automatic regime (FCIA, excluded). "With conditions" if the asset is not usually issued through the chosen regime or a closed-end fund has fewer than 5 investors (the RG 1150 dispersion presumption does not apply).
Issue caps (Title II). Low-impact notes UVA 1,000,000 (20,000,000 if guaranteed); medium impact UVA 15,000,000; extended medium impact UVA 100,000,000; PyME CNV UVA 19,000,000, qualified investors only. UVA is an inflation-indexed unit; caps are not converted to dollars.

Timeline and cost

The rule sets no CNV response times, so stage durations are own assumptions; development runs in parallel with the authorizations. Technology cost = estimated hours per component (permissioned token 160–280 h, VASP interoperability 80–160 h, payment events 60–120 h except shares, meeting lock-up and voting 40–100 h always, since art. 18 covers all holders) times USD 25–99/h (Clutch, blockchain developers in Argentina), plus an external audit of USD 15,000–40,000 (Sherlock). Legal fees, CNV and depository fees and intermediary commissions are excluded.

ERC-3643

The rule does not mandate a technical standard. The assessment recommends a permissioned token such as ERC-3643 (T-REX), ERC-20 compatible, with identity registry, compliance checks on each transfer, freeze, forced transfer and pause. This is a technical recommendation, not a CNV requirement.

What could not be verified

The standalone text of RG 1172/2026 (the updated text of Title XIV, Ch. III was used).
CNV fee amounts and the day's UVA value: caps are not converted to dollars.
Actual CNV response times for the digital representation authorization.
Whether tokenizing PyME CNV notes (Ch. VI) has additional requirements.

Sources

Independent website. Not legal or financial advice.