Second Phase of the Regulatory Framework for the Digital Representation of Marketable Securities through Distributed Ledger Technologies (DLT)

On August 21^st, 2025, the National Securities Commission (Comisión Nacional de Valores, or "CNV") issued General Resolution No. 1081 (the “Resolution”), whereby it implemented the second phase of the regulatory framework governing the digital representation of marketable securities through distributed ledger technologies (“DLT”).

This new regulation expands and deepens the regulatory framework established by General Resolution No. 1069/2025, by incorporating new financial instruments into the tokenization regime, adjusting operational and supervisory mechanisms, and introducing more robust investor protection standards. The main provisions and innovations introduced by the Resolution are summarized below:

Virtual Assets Service Providers (VASPs) are permitted to do so exclusively in relation to those marketable securities that will be digitally represented (e.g., tokens). The Resolution sets forth which securities may be tokenized, namely:

• Shares

• CEDEARs (Argentine Depository Certificates)

• Negotiable Obligations (Corporate Bonds)

• Debt securities or participation certificates of publicly offered financial trusts, whose principal underlying assets are real-world assets (“RWAs”) or other eligible assets

• Units of publicly offered closed-end mutual funds whose main underlying assets are RWAs or other eligible assets

The new regulation expressly prohibits the tokenization of so-called “Social, Green and Sustainable” (SVS) securities and those “Linked to Sustainability” (VS). Any VASP intending to offer tokens must first obtain authorization from the CNV to carry out both the public offering and the digital representation. Upon obtaining such authorization, the issuer must publish a “material fact” (hecho relevante), informing the investing public of the decision adopted, including at a minimum all applicable considerations related to the digital representation and identifying the VASPs responsible for commercialization.

Additionally, the Resolution establishes the requirements applicable to the digital representation of marketable securities.

Finally, only those VASPs duly registered with the CNV, in all their respective categories and for the duration of the applicable digital representation, may participate in this regulatory framework.