The regulator in Argentina has advanced from merely issuing PSP licenses to operating controls regarding the integration of payment tools into the larger ecosystem. PSPs’ main dilemma has shifted from whether they are permitted to operate to whether their product performs well in a connected environment.
Participation in interoperable payment schemes requires compliance and technical onboarding in addition to an existing PSP license in Argentina. The article will familiarize you with the necessary information on this topic.
When the Extra Step Becomes Mandatory
If a software application enables a user to:
- make a payment via PCT,
- have the option to use numerous instruments,
- scan different QR codes of various acquirers,
then it will be impacted by the Central Bank’s interoperability framework.
In practice, two things can help to make the difference: isolated systems vs. connected ones. An ecosystem operating in a closed manner may be outside this framework, whereas enabling cross-network interaction and the firm is faced with the forced usage of the new step.
This implies that adding QRP feature:
- cannot just be looked at from a technical perspective as a mere upgrade;
- will influence the regulatory position of the whole product.
Major danger lies in the gradual addition of features without re-examination of legal implications
Who Falls Under This Framework
The rule is applicable to legal entities supplying payment applications that have the functionalities mentioned above.
The size, number of users, or amount of transactions can’t be used as a ground for exemption.
For instance, if a developing fintech company has a product that allows interoperable payments, it will be considered at par with the big players in the market. The regulator is concerned about the functionalities of a system irrespective of the size of a provider.
How the Process Works in Reality
Step 1 – Access Setup
The entity must:
- log in via a fiscal identification system (level 3),
- activate access credentials for the Central Bank interface.
This step can slow down foreign-backed ventures, especially when local tax access is not properly structured from the start.
Step 2 – Providing Entity and Infrastructure Details
The submission consists of:
- legal entity identification;
- brand and web presence;
- locations of primary and backup data processing centers;
- third-party technology and security providers;
- designated responsible individuals.
In effect, the regulator may request detailed information about infrastructure, providers, and operational dependencies.
Step 3 – Proof of System Readiness
One crucial factor is the assurance from each authorized transfer scheme administrator that:
- the integration has been successfully accomplished;
- the system is considered live and accessible to the public;
- QR-based payments operate seamlessly amongst all relevant acquirers.
The main risk is that third parties influence timelines, making planning inherently uncertain.
Step 4 – Submit the files
File submission requires uploading documents formatted and sized in a certain way via the platform.
Technical errors, rather than legal issues, are the main cause of rejection at this stage.
Step 5 – Review and Feedback Loop
The authority may review the submission and:
- seek clarifications;
- highlight discrepancies;
- hold the process until changes are done.
Approval does not usually come through the first time. A series of exchanges can be expected.
Step 6 – Final Inclusion in the List
Once everything is verified, the entity is added to the Central Bank’s list and assigned an ID number.
Only then can the interoperable functionality be considered fully aligned with regulatory expectations.
Key Risks and Strategic Points
Underestimating the extent of the changes
Many PSPs assume their existing status is covering their activities fully.
In practice, even the most ardent proponents of interoperability concede that it means there is an extra layer of control.
Dependence on External Integrations
Connecting to various payment transfer schemes is a must, which means:
- technical complexity;
- dependence on third-party schedules.
The main challenge: an internal team prepared thoroughly on their end might still not be able to control the entire process.
Transparency of Infrastructure
On revealing the service providers and system architecture:
- there is greater regulator visibility;
- the regulator could ask subsequent questions related to resilience and security.
Market Entry Timing
For new entrants, this could be the deciding factor when it comes to their launch plans.
This means that regulatory alignment should be a part of product development planning and not something to be done after deployment.
What This Means for PSP Strategy
The Central Bank is effectively drawing a line between isolated payment tools and those integrated into the national ecosystem.
In practice:
- interoperability leads to stricter oversight,
- standardized connections become unavoidable,
- early planning becomes a competitive advantage.
The key advantage is smoother long-term positioning once included in the system.
The trade-off is a more demanding entry phase.
Quick Overview Table
| Aspect | What it involves | In practice |
| Trigger | Interoperable features (PCT, QR, multi-instrument payments) | Even one added feature can change your regulatory position |
| Who is affected | Any PSP offering such functionality | Size doesn’t matter – functionality defines scope |
| Access | Entry via ARCA system with fiscal credentials | Foreign-backed setups often face delays here |
| Data submission | Entity details, infrastructure, responsible persons | Regulator sees full structure behind the product |
| System readiness | Confirmation of integration with payment schemes | Depends on third parties, which can slow timelines |
| Review process | Authority checks and may request corrections | Expect at least one revision cycle |
| Final status | Inclusion in the Central Bank’s list | Only then the product is fully aligned for market use |
How Eternity Law International Can Assist
Handling this process requires careful coordination between legal, technical and administrative departments.
We assist PSPs by:
- checking if a product is subject to the interoperability regime;
- planning the submission to minimize the risk of delays;
- engaging in communication with scheme administrators to get integration confirmation, etc.
Difficulties are more related to procedural issues than to legal ones. Targeted assistance is effective in preventing multiple submissions and also reducing the length of the process.
FAQ
What is a virtual wallet in Argentina?
These are programs that allow you to pay, make transfers and pay by QR or card.
They usually work by connecting with banks and payment networks. In the case of Argentina, these applications become part of the national payment system when they facilitate QR payments between different providers.
How do I register a digital wallet?
- Enter ARCA using the tax credentials,
- fill in the entity and infrastructure data,
- provide a list of responsible persons,
- confirm the integration of payment schemes,
- upload the required documents,
- wait for the review and the approval.
What are the three types of wallets?
- Closed: It can only be used within the ecosystem of a single company;
- Semi-closed: In addition to shopping at multiple merchants through the wallet, users may be allowed to make limited transfers outside of this network;
- Open: These wallets are the most feature-rich ones as they allow users to perform a wide range of operations through banks and payment networks.
Can digital wallets be used internationally?
Yes, but usually for card payments abroad or limited cross-border transfers only. Complete interoperability among countries is generally disrupted by banking and currency regulations.
