Uruguay’s Law No. 20,345, titled “Regulación de los activos virtuales,” established a statutory basis for supervising virtual-asset service providers and recognizing securities recorded on distributed ledgers. Promulgated on September 19, 2024, and published on September 27, it remains part of Uruguay’s legal framework as of September 28, 2026, with subsequent amendments. Its original supervisory provisions must now be read alongside the replacements introduced by Law No. 20,446. The 2024 statute contains no express commencement date. IMPO law record; current supervisory perimeter.
What Uruguay’s virtual-assets law changed
The three-article law amended existing financial legislation. Articles 1 and 2 replaced Articles 37 and 38 of the Central Bank of Uruguay’s charter, Law No. 16,696. Article 3 amended Article 14 of the securities-market law, Law No. 18,627. The Banco Central del Uruguay (BCU) exercises the relevant supervision through its Superintendencia de Servicios Financieros (SSF). Article 1; Article 2; Article 3.
Under the original 2024 wording, providers handling virtual assets that included assets classified as financial by BCU regulation entered the financial-system supervisory perimeter. A separate provision covered other providers buying and selling virtual assets defined by the BCU, limiting that supervision to anti-money-laundering and counter-terrorist-financing purposes. The statute therefore left important classification decisions to the regulator. This distinction describes the original law, rather than the broader perimeter applying in 2026. Original Article 1; current Article 37.
Authorization and enforcement powers
Article 2 expressly placed the providers listed in Article 37(H) within the SSF’s authorization powers. It empowered the supervisor to authorize operations, regulate their functioning and revoke authorization for serious infringements. The replacement text also set out prudential, information-gathering, consumer-protection and AML/CFT powers, including warnings and fines, and the ability to propose stronger measures to the BCU board. The SSF can also require records and documents, establish accounting-information requirements, assess the financial condition of supervised entities and address complaints from their consumers. These provisions established regulatory authority; they did not themselves supply a complete provider application procedure. Original Article 2.
Recognition of distributed-ledger securities
Article 3 recognized decentralized book-entry securities: securities represented by account entries and issued, stored, transferred and traded electronically using distributed-ledger technology. They remain subject to applicable securities-law requirements and BCU regulation. This amendment continues to appear in the current securities-market statute. Its effect is to accommodate this method of recording securities, without automatically classifying every cryptoasset as a security. Current Article 14.
Subsequent amendments and implementation
Law No. 20,446 subsequently replaced the charter’s Articles 37 and 38, with its general commencement set at January 1, 2026. The revised perimeter includes virtual-asset service providers generally and separately identifies stable-virtual-asset issuers. Accordingly, the narrower 2024 distinction should not be presented as the current licensing boundary. Revised Article 37; revised Article 38; commencement provision.
BCU Circular No. 2507, dated July 16, 2026, implements provider authorization and operating requirements under that revised framework. It covers professional exchange, transfer, custody and specified issuance-related services. Mere software development without active service provision is excluded; activities involving decentralized book-entry securities or electronic money remain governed by their specific regimes. Circular 2507, Articles 127.22–127.23.
Applications opened on September 1, 2026. Existing providers have until March 31, 2027, to apply and may continue operating while their applications are processed. The circular sets a general adaptation deadline of June 30, 2027, subject to provision-specific exceptions. Circular No. 2508 also confirms a December 31, 2027, systems-adaptation deadline for outgoing and incoming virtual-asset transfer identification rules. These are implementing-regulation deadlines, not the commencement date of Law No. 20,345. Circular 2507, Article 127.27 and paragraph 43; Circular 2508, Articles 198.2–198.3.
