Armenia licenses crypto providers under a MiCA-style law and limits cash purchases to AMD 300,000
Armenia’s crypto-asset law, modelled on MiCA, makes the Central Bank the sole licensing authority. Separate rules require crypto transactions to be settled cashlessly, with cash allowed only up to AMD 300,000 through a licensed provider. The cash exception is temporary, and published sources give different end dates.
● Red
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0%
Tax on crypto gains for non-entrepreneur individuals
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AMD 300k
Per-transaction cash ceiling (about USD 780), the only cash permitted
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31 Jan 2027
CBA licensing deadline for providers already active
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Armenia has a standalone crypto-asset law modelled on the EU's MiCA. The Law on Crypto-Assets (HO-159-N) was adopted on 29 May 2025 and entered into force on 4 July 2025, with the Central Bank of Armenia (CBA) as sole licensing and supervisory authority.1,2 A separate amendment to the law on non-cash operations has applied since 1 January 2026. It requires crypto-asset transactions to be settled by cashless means, such as bank card or electronic wallet, irrespective of amount. Cash is allowed only for transactions of up to AMD 300,000 (roughly USD 780), made through a registered crypto-asset service provider that identifies the customer and keeps records.3 The cash exception is temporary, and published sources disagree on when it ends: January 2027 in some, 1 January 2028 in others.3,4,11,12 Non-entrepreneurial individuals pay no tax on gains from standard crypto-asset trading.5 GENERAL BYTES, as a hardware and software vendor, does not perform a licensable activity itself; the licence is held by the in-country operator of the machines.
Last updated: October 2026
Regulatory Framework and Its Evolution
Amendments to the Civil Code in 2024 recognised crypto-assets as personal property, and the Law on Crypto-Assets took effect on 4 July 2025.6,2 The law mirrors MiCA in structure, defines ten crypto-asset service categories, sets minimum capital by activity, and requires either a full licence or a lighter permission depending on the service.6
| Date | What happened |
|---|---|
| 2024 | Civil Code amended, crypto-assets recognised as personal property |
| 29 May 2025 | Law on Crypto-Assets (HO-159-N) adopted |
| 4 Jul 2025 | Law enters into force; CBA becomes sole licensing and supervisory authority |
| 1 Jan 2026 | Non-cash operations amendments take effect: crypto transactions must be cashless, except cash up to AMD 300,000 through a registered provider |
| 31 Jan 2026 | CBA Regulations 7/01, 7/02, 7/04 and 7/05 enter into force |
| 31 Jan 2027 | Licensing deadline: providers active when the law took effect must be licensed or cease activity |
| Jan 2027 or Jan 2028 | End of the AMD 300,000 cash exception: sources give January 2027 or 1 January 2028; one law-firm guide says July 2026. Not confirmed against the law text |
The CBA Board approved Regulation 7/01 on the licensing procedure by resolution 227-N of 30 December 2025. It was published on 21 January 2026 and entered into force on 31 January 2026, together with Regulations 7/02, 7/04 and 7/05.7,8 Entities that were providing crypto-asset services when the law took effect must be registered and licensed within one year of 31 January 2026, that is by 31 January 2027, or stop providing those services.9 The CBA describes its approach as "same activity, same risk, same regulation."8 Draft Regulation 7/07 on the activities of crypto-asset service providers was put out for public discussion in August 2026, and we did not find a notice that it has been adopted.10
The Cash Restriction
Under the amended law on non-cash operations, in force since 1 January 2026, crypto-asset transactions must be conducted by cashless methods irrespective of amount. Cash is allowed only for operations not exceeding AMD 300,000, carried out through a person providing crypto-asset services, who must identify customers with official documents and keep records of all transactions for CBA oversight.3 The default rule is therefore cashless settlement, and the cash exception is both capped and temporary.
The end date of the exception is not consistent across sources. Crowe (February 2026) and Andersen (April 2026) describe a transitional period valid until 1 January 2028.3,4 The CBA Governor described a one-year window ending on 1 January 2027 when the measure was before parliament in December 2025, and reports on parliament's final vote and CivilNet in February 2026 also give January 2027.11,12,13 One Armenian law-firm guide states that the cash allowance ended in July 2026.15 We could not check these against the consolidated text of the law. Anyone planning cash operations should confirm the operative date with the CBA or Armenian counsel.
The cap is also a limit on each transaction: AMD 300,000 is roughly USD 780. The head of the Crypto Entrepreneurs Union has said the cash restrictions disadvantage crypto firms compared with banks and exchange offices, which can still operate in cash.12
Getting Licensed
The CBA gives minimum capital requirements of about USD 30,000 to USD 530,000, depending on the type of business.12 Regulation 7/01 covers registration and licensing of domestic providers, permits for branches and representative offices of foreign providers, and prior consent to acquire a qualifying holding in a provider's capital.7
Existing providers that are not registered and licensed by 31 January 2027 must stop providing crypto-asset services.9 The licence sits with the in-country operator of the machines, not with GENERAL BYTES as hardware and software vendor.
AML and KYC
The cash exception is conditional on identifying the customer with an official document and keeping transaction records for CBA oversight, so even the permitted cash transactions are not anonymous.3 The CBA says the regime is meant to address money laundering and criminal financing risk.12
Banking
The CBA supervises the banking sector, and we found no official guidance on bank accounts for crypto providers. A local law firm reports that banks screen for crypto activity as part of AML procedures and may refuse or close accounts of unlicensed providers, so licensing status is likely to matter.16
Tax
Non-entrepreneurial individuals pay no tax on gains from standard crypto-asset trading under Article 150 of the Tax Code. A reduced 1% income tax applies to the alienation of crypto-assets created as rewards for mining and staking. Legal entities, and individuals whose trading crosses business-activity thresholds, pay the standard 18% profit tax. Crypto losses cannot be offset against other business income.5
Outlook
The licensing regime is in force, the deadline for existing providers is 31 January 2027, and further CBA rules are still being drafted.9,10 The net inflow of cross-border transfers to individuals through the Armenian banking system reached USD 1.38 billion in January–June 2026, 2.3 times the USD 587.6 million of a year earlier.14 For cash-to-crypto machines, the open question is the end date of the cash exception, which should be confirmed with the CBA before any commitment.
Sources and references
1. Law "On Crypto-Assets" adopted by the National Assembly on 29 May 2025; CBA as licensing authority — gratanet.com
2. Law "On Crypto-Assets" (HO-159-N) in force as of 4 July 2025 — ilex.am
3. Amendments to the Law on Cashless Transactions: cash permitted only up to AMD 300,000 through a crypto-asset service provider; in force 1 January 2026; transitional period valid until 1 January 2028 — Crowe Armenia (26 February 2026)
4. Cash arrangement described as a sunset period until 1 January 2028 — Andersen in Armenia (29 April 2026)
5. Tax treatment: no tax for non-entrepreneurial individuals on standard crypto trading gains; 1% on mining and staking rewards; 18% profit tax for legal entities and business-level traders; losses not deductible (Art. 113). Law-firm summary, not the statute — armenian-lawyer.com
6. Civil Code amendments 2024; ten service categories; MiCA alignment; full licence or lighter permission — Andersen in Armenia
7. CBA Board Resolution 227-N of 30 December 2025 approving Regulation 7/01; published 21 January 2026 — cba.am
8. Regulations 7/01, 7/02, 7/04, 7/05 in force 31 January 2026; "same activity, same risk, same regulation" principle — finport.am (26 January 2026)
9. CBA announcement: existing providers must be registered and licensed within one year of 31 January 2026 — cba.am
10. Draft Regulation 7/07 on the activities of crypto-asset service providers presented for public discussion — armbanks.am (13 August 2026)
11. CBA Governor Martin Galstyan, December 2025: cash purchases of crypto allowed up to AMD 300,000 during a one-year transitional period, with a ban from 1 January 2027 — armenpress.am (16 December 2025)
12. Minimum capital about USD 30,000 to USD 530,000 depending on business type; cash allowed up to about USD 800 until 31 January 2027, as the article states; Crypto Entrepreneurs Union on the cash restrictions — civilnet.am (17 February 2026)
13. Parliament's final approval of the crypto and non-cash transaction amendments: cash up to AMD 300,000, transition "from January 2026 to January 2027" — armbanks.am (17 December 2025)
14. Net inflow of cross-border transfers to individuals: USD 1.38 billion in January–June 2026 vs USD 587.6 million a year earlier, per CBA data — armbanks.am (3 August 2026)
15. Law-firm guide stating the temporary cash allowance ended in July 2026 — MB Legal, Armenia
16. Banks screen for crypto activity and may refuse accounts of unlicensed providers. Law-firm commentary — armenian-lawyer.com
Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Armenia's exception permitting limited cash crypto payments is temporary, and published sources give different end dates for it (January 2027 and 1 January 2028, with one source giving July 2026); this article could not resolve the difference against the consolidated law. Always consult specialised local legal counsel and confirm the current position of the Central Bank of Armenia before considering market entry.