Maryland Legal Alert for Financial Services
Maryland Proposes New Virtual Currency Kiosk Regulations
On December 1, 2025, the Maryland Commissioner of Financial Regulation has issued a Notice of Proposed Action to adopt new regulations under COMAR 09.03.16, titled Virtual Currency Kiosks.
Under the proposed regulations, operators must register with the Commissioner through the Nationwide Multistate Licensing System (NMLS) before operating a kiosk in Maryland, and each kiosk—whether fixed or mobile—must also be registered. Operators are also required to provide information including ownership, kiosk location or geographic area, services offered, and any other information requested by the Commissioner.
The proposed regulations also address procedures for handling fraudulent transactions, including electronic and non-electronic fraud notices, investigation timelines, and fee refund requirements. Operators are prohibited from charging users for investigations, requiring a police report to process claims, or using certain factors to deny refunds.
Communication requirements mandate that operators provide notices and disclosures using information collected from users while allowing users to select preferred methods of communication. Kiosks must comply with lighting, safety, and signage standards comparable to ATMs, including conspicuous disclosure of operator information, registration verification, and contact information for the Commissioner. On-screen disclosures must remain visible for a minimum time based on word count, and receipts must contain detailed transaction information, including fee and refund notice instructions. All transactional data must be retained for seven years.
Operators are also required to prepare an annual report for each kiosk listing transaction volumes, fraud notices, refund denials, fee refund, and other relevant data, which must be submitted through NMLS at the time of registration renewal or expiration.
These proposed regulations constitute Maryland’s first comprehensive framework for virtual currency kiosk operations and may have significant compliance implications for offering virtual currency services.
Comments on the proposed regulations will be accepted through January 2, 2026.
For more information concerning this topic, please contact Tamia J. Morris