Asset Tokenization in Argentina 2026: Regulatory Framework, Technical Architecture, and Why the Fideicomiso Is the Legal Vehicle

Argentina has one of the most advanced tokenization regulatory frameworks in Latin America right now — and it has an expiration date. The CNV (Comisión Nacional de Valores, Argentina's securities regulator) opened a DLT sandbox via Resolutions 1069, 1081, and 1087 that allows fully tokenized securities issuance: trust participations, bonds, commercial paper, and fund shares — all without listing on a traditional market. The sandbox closes in August 2026. Companies that build the infrastructure today get first-mover advantage in a market that will have explicit rules by then. Companies that wait will be building under pressure, or worse, regulated out.

The regulatory landscape: three pillars, one window

Understanding what's legal — and what's about to be — is the prerequisite for any tokenization project in Argentina. Three regulatory bodies shape the landscape.

CNV — Securities tokenization

• Resolution 1069: Establishes the DLT sandbox for fideicomisos financieros (financial trusts) and FCIs (mutual funds). Allows fully on-chain issuance without traditional market listing.
• Resolution 1081: Defines operational parameters and infrastructure requirements for DLT-based issuance.
• Resolution 1087 (October 2025): Expands the sandbox to include shares, obligaciones negociables (bonds), commercial paper from trusts, and fund shares (cuotapartes).
• Settlement agents (agentes de liquidación) are registered as on-chain titleholders — bridging the legacy registry with the blockchain ledger.
• The sandbox is active until August 2026. Issuances within it are 100% tokenized with no parallel traditional issuance requirement.

Ley 27.739 — PSAV (Virtual Asset Service Providers)

• Mandatory registration with the CNV for any entity handling virtual assets above 35,000 UVA/month.
• Full KYC/AML obligations, fund segregation, and UIF (financial intelligence unit) reporting.
• Cybersecurity requirements: mandatory penetration testing and vulnerability management.
• Applies to platforms offering tokenized asset trading, custody, or exchange.

BCRA — Banks and crypto (April 2026)

• Banks are now authorized to trade and custody crypto assets via separate regulated entities.
• Elevated capital, security, and liquidity requirements apply to these entities.
• Opens institutional distribution channels: banks can offer tokenized assets to their client base.
• Bridges traditional finance and DLT — the missing piece for mass distribution of tokenized securities.

Why the fideicomiso financiero is the legal vehicle

Of all the legal structures available for asset tokenization in Argentina, the fideicomiso financiero (financial trust) is the one the CNV has explicitly sanctioned for DLT-based issuance. It's not a workaround or a creative interpretation — it's the designated vehicle in Res. 1069.

A fideicomiso has four core parties: the fiduciante (settlor — transfers the assets), the fiduciario (trustee — manages the trust), the beneficiarios (investors — receive returns), and an optional auditor. In a tokenized structure, each party is represented by a blockchain wallet. The fideicomiso agreement itself can be partially or fully represented as a smart contract, with automatic distributions triggered by on-chain events.

The critical legal innovation is the blockchain signature. Under Argentine digital signature law (Ley 25.506), a cryptographic signature generated by a wallet has legal validity equivalent to a handwritten signature — provided it meets the requirements of a 'firma digital' (qualified electronic signature). When each party signs a transaction with their wallet, they are signing the juridical act. This replaces or complements notarial intervention, reducing friction, cost, and intermediary dependency.

Technical architecture: from network to token

The architecture for a tokenized fideicomiso has four layers, each with deliberate technology choices.

• Layer 1 — Blockchain network: EVM-compatible, either public (Ethereum L2 for cost efficiency) or permissioned (Hyperledger Besu for maximum control). The choice depends on whether the issuance requires public verifiability or institutional privacy. Both are valid under the CNV framework.
• Layer 2 — Identity and wallets: DID-based identity (QuarkID or equivalent) + MPC wallets for institutional-grade key management + multisig governance for critical operations. The identity layer maps physical persons to on-chain wallets via verifiable credentials.
• Layer 3 — Token standard (ERC-3643 / T-REX): The only standard designed specifically for security tokens with embedded compliance. Restricts transfers on-chain: only whitelisted, KYC-verified wallets can receive tokens. Supports lock-up periods, jurisdictional restrictions, and investor qualification checks — all enforced by the contract, not by a manual process.
• Layer 4 — Application portal: Web interface for fiduciante, fiduciario, and beneficiarios. Wallet connection, signature flows, distribution dashboards, and audit views. The portal doesn't hold custody — it's a window into the on-chain state.

ERC-3643: why not ERC-20 or ERC-1400

ERC-20 is a fungible token standard with no compliance logic. Anyone can transfer to anyone. For a security token subject to Argentine regulation, that's a non-starter — you need transfer restrictions enforced at the protocol level, not at the application level.

ERC-1400 was an attempt at a security token standard but never achieved broad adoption or tooling maturity. ERC-3643 (branded T-REX by Tokeny) is the production-grade alternative: it embeds identity verification into the transfer logic, supports modular compliance rules, and has been used in regulated issuances across Europe and now Latin America.

• On-chain KYC/AML: investor wallets are linked to verified identities via claim issuers. Transfers are only possible between verified wallets.
• Transfer restrictions: lock-up periods, maximum holder counts, jurisdictional blocks, qualified investor checks — all enforced by the smart contract.
• Modular compliance: rules can be updated without redeploying the token. New regulations can be added as new compliance modules.
• CNV/UIF reporting: on-chain events generate audit trails that map directly to regulatory reporting requirements.
• Auditability: every operation is immutable. External auditors and the CNV can verify the complete history without accessing internal systems.

From specification to MVP: a phased path

A tokenization project is not a 'deploy a contract and go' operation. It requires legal structuring, technical architecture, compliance embedding, and regulatory alignment — all before the first token is minted. The proven approach is phased:

• Phase 0 — Discovery (4 weeks): Legal-technical diagnostic, blockchain architecture, smart contract design, tokenomics, and MVP roadmap with budget. Investment: USD 8,000–12,000.
• Phase 1 — Core infrastructure (6-8 weeks): Smart contract deployment, wallet infrastructure, on-chain signature flows.
• Phase 2 — Portal and UX (4-6 weeks): Web portal for all parties, distribution dashboards, signature workflows.
• Phase 3 — Compliance integration (3-4 weeks): KYC/AML on-chain verification, UIF reporting automation, audit interfaces.
• Phase 4 — Pilot: Real asset, real parties, real regulator interaction. Go/no-go on full production deployment.
• Full MVP investment range: USD 40,000–150,000 depending on legal complexity, blockchain choice, and asset volume.

What we've built: EPEC, QuarkID

This isn't theoretical for us. Two production systems directly inform our approach to tokenization.

• EPEC — Energy tokenization: Token system (PUG/ERI/REC) on Polygon for 438+ households across 4 solar parks in Córdoba province. First government-backed energy tokenization in LATAM. Proof that on-chain token economics work at civic scale.
• QuarkID — Sovereign identity: Self-sovereign identity protocol for millions of citizens in Buenos Aires. Recognized as a Digital Public Good. The same DID infrastructure is reusable for on-chain identity of fideicomiso parties.

If you're evaluating asset tokenization under the Argentine regulatory framework and want a technical partner with production experience in regulated blockchain systems, let's talk. The sandbox window is open — but not for long.