The Central Bank of Uruguay (BCU) finalized the new regulatory framework for virtual asset service providers (VASPs) in Resolution SSF No. 2026-444. After two rounds of public consultation and almost a year of discussion with the industry, Uruguay for the first time has comprehensive VASP regulations.  
 
The approval of the regulations marks the start of a new stage for the sector. Companies  already operating in Uruguay or planning to do so must assess whether their activity is covered by the regime and prepare the necessary documentation in a timely manner to obtain BCU authorization.
 
Below we summarize the main aspects of the regulations and the most relevant new features of their final version.

What is regulated

The regulation adds the new Title VII-TER to the Compilation of Securities Market Regulations and establishes the regime applicable to VASPs.
 
VASPs are understood as legal entities that, on a regular and professional basis, provide one or more of the following services:
  • exchange between virtual assets and fiat currencies;
  • exchange between virtual assets;
  • transfer of virtual assets;
  • custody, administration or other mechanisms affording control over virtual assets;
  • participation in or provision of financial services related to the offering or sale of virtual assets. 
Activities conducted under protocols that allow their direct execution between users via smart contracts are also included.

Timeframes for requesting authorization

One of the most relevant aspects of the final version is that it sets timeframes for the implementation of the regime.
 
Companies already operating may apply for authorization between September 1, 2026 and March 31, 2027, and may continue to perform their activity while the BCU analyzes the application. New operators will be able to apply for authorization from September 1, 2026, before starting activities. 
VASPs  must be organized as business companies under Uruguayan regulations,  or as branches of foreign entities. To obtain authorization, the applicant must submit corporate information, including shareholders, corporate governance, systems, compliance, prevention of money laundering, and operations, among other requirements established by the regulations.

What changed in the final version?

While the general structure of the regime is maintained, the final version incorporates some relevant adjustments:
  • it specifies that the prohibition of financial intermediation refers specifically to transactions involving virtual assets;
  • it simplifies some of the documentation required to apply for authorization;
  • finally, it establishes timeframes for submission of authorization applications, which the previous version had not yet defined. 

The regime’s main pillars remain in place

The regulations retain the central aspects already in the draft version submitted for analysis, including:
  • minimum equity for certain VASPs, guarantees and deposits with BCU;
  • separation of own and customer funds and assets;
  • rules on financial services outsourcing and correspondents;
  • obligations in terms of corporate governance, information security, customer protection and prevention of money laundering;
  • sanctioning regime applicable to authorized providers. 

Next steps for existing or future VASPs

With the regulations approved, companies already operating – or planning to operate – with virtual assets in Uruguay are encouraged to assess as soon as possible whether their activities are covered by the new regime and to begin planning the authorization process. In particular, it will be important to review the business model, prepare the required documentation, and to plan to submit the application within the timeframes established.
 
At FERRERE we advise local and international companies on all stages of the VASP authorization process with the Central Bank. If your company already provides virtual asset services or is evaluating entering the Uruguayan market, do not hesitate to contact us.