Armenia: A MiCA-Style Framework Arriving Alongside a Ban on Buying Crypto With Cash

Armenia just passed a MiCA-style crypto law — but a separate ban on cash crypto payments could shut cash-to-crypto ATMs out entirely once the temporary exemption expires in January 2027.

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0% Tax on crypto gains (individuals)

$790 Cash cap during exemption (2026–27)

Jan 2027 Cash exemption expires

Armenia has built the first comprehensive, standalone crypto-asset framework in the South Caucasus, and it is closely 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 On paper this is exactly the kind of clear, EU-aligned regime this series usually welcomes. For a cash-to-crypto ATM specifically, however, there is a problem that overrides everything else: a separate Armenian law on non-cash transactions, in force from 1 January 2026, prohibits crypto trades using fiat cash.³ Recognising the disruption, the CBA introduced a temporary exemption permitting cash crypto payments up to 300,000 drams (roughly USD 790) between January 2026 and January 2027, which CBA Chairman Martin Galstyan described as a compromise workable only if buyers and sellers using cash are identified.^3,4 The advantage is genuine regulatory quality and an unusually attractive tax position: crypto gains for non-entrepreneur individuals are taxed at 0%.⁵ The obstacle is that Armenia is deliberately legislating against the exact transaction a crypto ATM exists to perform, with the current carve-out capped at under USD 800 per transaction and scheduled to expire. As in most markets on our legislation map, General Bytes as a hardware and software vendor is not itself performing a licensable activity; it is the in-country operator of the machines who must hold the CBA licence. For GENERAL BYTES, Armenia is a market where the licensing regime is workable but the underlying cash-payment policy points the wrong way, and the single most important thing to establish is what happens to the cash exemption in January 2027.

Last updated: August 2026

Regulatory Framework and Its Evolution

Armenia moved quickly. Amendments to the Civil Code in 2024 recognised crypto-assets as personal property, the government filed a draft law with the National Assembly in April 2025, and the Law on Crypto-Assets was adopted on 29 May 2025, taking effect on 4 July 2025.^6,2 The law mirrors MiCA in both structure and content, defines ten distinct crypto-asset service categories, sets minimum capital standards 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 transactions law takes effect, prohibiting cash-based crypto trades
31 Jan 2026	CBA Regulations 7/01, 7/02, 7/04 and 7/05 enter into force
31 Jan 2027	One-year licensing deadline and temporary cash exemption both expire

The implementing detail arrived in early 2026. The CBA Board approved Regulation 7/01 on licensing procedure by resolution of 30 December 2025, published it on 21 January 2026, and it entered into force alongside Regulations 7/02, 7/04 and 7/05 on 31 January 2026.^7,8 The CBA's own announcement is explicit on the deadline: entities that were providing crypto-asset services when the law took effect must be registered and licensed within one year of 31 January 2026, meaning by 31 January 2027, or cease providing such services.⁹ The CBA has framed the framework around the principle of "same activity, same risk, same regulation."¹⁰ Further rules are still coming: draft Regulation 7/07 on the activities of crypto-asset service providers was put out for public discussion in August 2026.¹¹

The Cash Problem

This deserves its own section because it is the deciding factor for this business model. Armenia's law on non-cash transactions, effective 1 January 2026, requires that transfers linked to digital assets must not involve cash payments.³ That is a direct prohibition on the core function of a cash-to-crypto machine. The CBA acknowledged a discrepancy between this law and the Law on Crypto-Assets, and responded with a temporary exemption: cash crypto payments up to 300,000 drams (approximately USD 790) are permitted from January 2026 until January 2027.^3,4

A compromise workable only if buyers and sellers using cash are identified.
— Martin Galstyan, Chairman, Central Bank of Armenia

Two things follow. First, even during the exemption window, an Armenian ATM would face a hard per-transaction ceiling well below what machines in most markets in this series handle. Second, and more importantly, the exemption is time-limited by design, and Chairman Galstyan's framing (a compromise conditional on identifying cash buyers and sellers) suggests the policy direction is toward eliminating anonymous cash crypto purchases rather than accommodating them.⁴ This article found no source indicating what replaces the exemption in January 2027. That is the single question worth putting to the CBA before any commitment.

Getting Licensed

Minimum capital requirements run from roughly USD 30,000 to USD 530,000 depending on the type of business, according to Vigen Shahnazaryan, head of the CBA's Securities Market Regulation Department.¹² Regulation 7/01 covers registration and licensing of domestic providers, permits for branches and representative offices of foreign providers, and the procedure for obtaining prior consent to acquire a qualifying holding in a provider's capital.⁷ The CBA has stated the framework is designed to admit only verified and transparent platforms, with minimum safeguards for customer rights and explicit attention to money laundering risk.^12,4

Operating without a licence after 31 January 2027 carries administrative and potentially criminal exposure.² As with the rest of our legislation map, this licence sits with the in-country operator of the machines, not with General Bytes as hardware and software vendor.

AML and KYC

Armenia's approach is built around traceability. Commentary on the framework describes it as mandating disclosure of cryptocurrency ownership and cutting through transactional anonymity, echoing MiCA's emphasis on traceability.¹³ The cash exemption itself is conditioned on identification of the parties, which means that even the limited cash transactions currently permitted are not anonymous ones.⁴ This places Armenia firmly in the full-KYC category, with the additional feature that the country is legislating against cash as a payment channel rather than merely applying thresholds to it.

Banking

Armenia has 17 banks supervised by the CBA, and specialist commentary notes that none has publicly positioned itself as crypto-friendly, though several are known to work with licensed entities on a case-by-case basis following internal risk assessment.¹⁴ Licensing status is now the gating factor: unlicensed crypto businesses face significant difficulty opening or maintaining accounts, since banks screen for crypto activity as part of AML procedures and may refuse or close accounts for unlicensed providers.¹⁴ Account opening for a licensed provider involves preliminary assessment, CASP licence evidence, beneficial owner disclosure, and AML/CFT and risk management documentation.

The Next 24 Months: A Good Framework Pointing Away From Cash

Armenia's broader crypto positioning is improving. The 0% tax on crypto gains for non-entrepreneur individuals is genuinely unusual and matches Georgia's treatment covered elsewhere in this series, and the ECOS Free Economic Zone offers incentives for blockchain startups.⁵ Cross-border transfer inflows to individuals more than doubled year on year in the first half of 2026, reaching USD 1.38 billion, which speaks to a growing remittance-adjacent market of the kind that supports ATM demand elsewhere in this map.¹¹ Binance has also had a visible presence in the market during this period.³

None of that changes the central issue. Armenia has produced a credible, MiCA-aligned licensing regime at the same time as legislating against cash-based crypto purchases, and the exemption that currently makes a small cash transaction possible expires in January 2027. For GENERAL BYTES, the recommendation is to treat Armenia as blocked for the standard ATM model unless and until the cash position is clarified, and to make that clarification, rather than licensing mechanics, the first question asked of the CBA or of Armenian counsel. If the cash prohibition is confirmed as permanent from 2027, Armenia becomes a market where the machines cannot legally do what they are built to do, regardless of how good the rest of the framework is.

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Sources and references

1. Law on Crypto-Assets (HO-159-N) adopted 29 May 2025, in force 4 July 2025; CBA as regulator — gratanet.com
2. First standalone framework in South Caucasus; 31 January 2027 deadline; criminal exposure — lexology.com
3. Non-cash transactions law prohibiting cash crypto trades from 1 January 2026; CBA acknowledgement of discrepancy — cryptopolitan.com
4. 300,000 dram (~USD 790) cash exemption, January 2026 to January 2027; Galstyan statement — crypto-economy.com
5. 0% tax on non-entrepreneur crypto gains; ECOS Free Economic Zone — cryptowisser.com
6. Civil Code amendments 2024; ten service categories; MiCA alignment — am.andersen.com
7. CBA Board Resolution 227-N of 30 December 2025 approving Regulation 7/01 — cba.am
8. Regulations 7/01, 7/02, 7/04, 7/05 in force 31 January 2026 — mail.finport.am
9. CBA announcement: one-year licensing deadline from 31 January 2026 — cba.am
10. "Same activity, same risk, same regulation" principle — mail.finport.am
11. Draft Regulation 7/07 public discussion, August 2026; H1 2026 cross-border transfer inflows — armbanks.am
12. Minimum capital USD 30,000 to USD 530,000; Shahnazaryan statement on framework aims — civilnet.am
13. Framework mandating disclosure of crypto ownership, traceability emphasis — onesafe.io
14. 17 banks, none publicly crypto-friendly; licensing as gating factor for accounts — 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 temporary exemption permitting limited cash crypto payments is scheduled to expire in January 2027 and this article found no information on what replaces it; always consult specialised local legal counsel and confirm the current position of the Central Bank of Armenia on cash-based crypto transactions before considering market entry.