Crypto Law Profile
Maryland’s virtual currency kiosk regime requires operator and kiosk registration, sets transaction and fee limits, mandates disclosures and fraud-refund processes, and adds OFR enforcement rules.
Maryland Virtual Currency Kiosk Registration Regime is a state-level United States crypto law created by Maryland SB 305, Chapter 117 of the Acts of 2025. The law added Financial Institutions Article §§ 12-1201 through 12-1209 under a new subtitle for virtual currency kiosks and took effect July 1, 2025. Its core operating rule applies beginning January 1, 2026: a virtual currency kiosk operator must register a kiosk with the Maryland Commissioner of Financial Regulation before operating it in the state.
This profile treats the regime as Maryland law within the United States, not as a federal crypto ATM statute. As of June 4, 2026, the regime is in force, COMAR 09.03.16 regulations are effective, and later SB 741 / Chapter 417 alterations have been enacted with an October 1, 2026 effective date.
The statute defines a virtual currency kiosk as a stand-alone automated platform through which a consumer may deposit or receive cash, or use a credit or debit card, to obtain virtual currency services. Covered services include the conversion of one virtual currency to another and the purchase, sale, exchange, swap, or transfer of virtual currency by any means.
Maryland separates the kiosk regime from the state money transmission framework. COMAR 09.03.16 states that kiosk registration does not exempt a person from money-transmission licensure if the kiosk facilitates money transmission, and a money transmission license or exemption does not replace kiosk registration when the person operates a kiosk offering virtual currency services.
The law limits same-day cash, prepaid-access, or credit activity through one or more kiosks for a single Maryland user. The statutory limit is $2,000 for a new user and $10,500 for an experienced user. It also caps transaction fees at the greater of $5 or 15% of the virtual currency service transaction amount and requires fee refunds for transactions verified as fraudulent through procedures established by the Commissioner.
Operators must collect specified user identifying information before accepting cash or credit, provide receipts, maintain live toll-free customer support during weekday hours, and display on-screen risk disclosures before each virtual currency service transaction. The regulations add detailed refund-claim procedures, receipt contents, disclosure timing, required signage, wallet-blocking controls, third-party blockchain-analysis screening for high-risk or sanctioned wallets, and a chief compliance officer requirement.
SB 741, Chapter 417 of 2026, amends the regime effective October 1, 2026. It broadens “virtual currency kiosk operator” to include a person who installs or operates software enabling a stand-alone automated device to provide virtual currency services in Maryland. It also excludes accepting or dispensing cash in connection with a credit, deposit, or convenience account from “virtual currency service” and clarifies that a kiosk may not provide the same services as an automated teller machine.
| Date | Event | Status |
|---|---|---|
| January 13, 2025 | SB 305 first read in the Maryland Senate and referred to Finance. | Introduced |
| April 22, 2025 | Governor approved SB 305 as Chapter 117. | Adopted |
| July 1, 2025 | Chapter 117 took effect. | In force |
| January 1, 2026 | Operator and individual kiosk registration requirement became operational. | In force |
| March 30, 2026 | COMAR 09.03.16 final regulations became effective. | Effective |
| May 12, 2026 | Governor approved SB 741 as Chapter 417, with October 1, 2026 alterations. | Adopted |
Editors should classify the regime as an in-force Maryland licensing, registration, consumer-disclosure, and fraud-prevention framework for virtual currency kiosks, with a future amendment milestone on October 1, 2026.
Operators must register with the Commissioner and separately register each Maryland virtual currency kiosk before operating.
COMAR 09.03.16 requires NMLS registration and sets a $2,000 operator fee and $200 per-kiosk fee, plus NMLS fees.
Daily limits apply to new and experienced users, and fees may not exceed the greater of $5 or 15% of the transaction amount.
Operators must display risk disclosures, provide transaction receipts, and maintain live toll-free customer support during weekday hours.
Regulations add fee-refund procedures, wallet-blocking controls, blockchain-analysis screening, and compliance officer requirements.
The Commissioner may investigate and enforce the subtitle and assess civil penalties up to $1,000 per knowing and willful violation.
Chapter 417 broadens operator coverage to certain software operators and clarifies ATM-related exclusions and limits.
SB 305 was first read in the Maryland Senate and referred to Finance.
Governor approved SB 305 as Chapter 117, creating the virtual currency kiosk subtitle.
Chapter 117 took effect under its statutory effective-date clause.
Operators could not operate a Maryland kiosk unless properly registered.
Final COMAR 09.03.16 regulations for virtual currency kiosks became effective.
Governor approved SB 741 as Chapter 417, with scope clarifications effective Oct. 1, 2026.
Maryland Commissioner of Financial Regulation, Maryland Department of Labor, Maryland General Assembly, Maryland Office of Financial Regulation
Crypto assets, Digital assets, Virtual currency
State-level Maryland law within the United States. Treat separately from proposed or pending federal crypto ATM legislation and from other states’ kiosk laws.
