Allende & Brea – Estudio Jurídico

This report cannot be considered as legal or any other kind of advice by Allende & Brea. For any questions, do not hesitate to contact us.

New Central Bank regulation applicable to prepaid cards

On December 19, 2024, through Communiqué “A” 8162, the Argentine Central Bank amended the rules of the National Payment System (SINAP), establishing the following:

1. Prepaid cards issuers must credit the amount of each sale made using prepaid cards to the bank or payment account of the merchant within 2 (two) business days from the date of the transaction with the prepaid card. This obligation shall become effective as of August 1, 2025, except for payments made to merchants classified as MSMEs, in which case it shall become effective as of March 1, 2025.

2. Sub-acquirers or payment aggregators must credit the amount of payments made through their intervention to the affiliated merchant account within 1 (one) business day from the date the sub-acquirer or aggregator receives the funds. This obligation shall become effective as of August 1, 2025, except for payments made to merchants classified as MSMEs, in which case it shall become effective as of March 1, 2025.

The following payments processed through sub-acquirers or aggregators are excluded from this requirement:

a. Purchases made through e-commerce platforms; and/or

b. Immediate transfers, which in all cases must be made available to the payment beneficiary within 15 seconds, even if the payment is processed without the intervention of an administrator of the immediate transfer scheme (i.e., in a closed-loop modality).

3. To repeal the obligation established in the consolidated text of the National Payment System – Transfers – Complementary Rules on the acceptor to charge equal fees to merchants within each merchant category.

4. As of June 1, 2025, card issuers and account providers must include in the statement of account, and any other settlements delivered to their clients, a clear and unequivocal identification of the merchant where the payment was made. In this respect, all parties involved in payment processing—including acquirers, sub-acquirers, acquiring processors, issuing processors, issuers, and account providers—must include, transmit, and process the necessary information for this purpose.

5. As of June 1, 2025, when the messaging from card scheme administrators includes fields and/or codes that allow identifying the interoperable digital wallet from which the payment originated and that a QR code was used as the initiation method, all parties involved in payment processing—including acquirers, sub-acquirers, acquiring processors, issuing processors, and issuers—must use these fields when transmitting and processing the information for each transaction involving this payment method.

This report cannot be considered as legal or any other kind of advice by Allende & Brea. For any questions, do not hesitate to contact us.

Related areas