Maryland Virtual Currency Kiosk Registration Regime

The statute defines a virtual currency kiosk as a stand-alone automated platform through which a consumer may deposit or receive cash, or use a credit or debit card, to obtain virtual currency services. Covered services include the conversion of one virtual currency to another and the purchase, sale, exchange, swap, or transfer of virtual currency by any means.

Maryland separates the kiosk regime from the state money transmission framework. COMAR 09.03.16 states that kiosk registration does not exempt a person from money-transmission licensure if the kiosk facilitates money transmission, and a money transmission license or exemption does not replace kiosk registration when the person operates a kiosk offering virtual currency services.

• Operator registration: A person may not operate a kiosk in Maryland after January 1, 2026 unless registered as an operator with the Commissioner through NMLS.
• Kiosk registration: Each kiosk must be separately registered through NMLS, with fixed-location or mobile-location information and unique identifying data.
• Registration fees: The regulations set a non-refundable $2,000 operator registration fee and a $200 fee for each registered kiosk, plus applicable NMLS fees.
• Annual renewal: Operator and kiosk registrations renew through NMLS, and operators must submit annual kiosk-level reporting as part of the renewal or expiration process.

The law limits same-day cash, prepaid-access, or credit activity through one or more kiosks for a single Maryland user. The statutory limit is $2,000 for a new user and $10,500 for an experienced user. It also caps transaction fees at the greater of $5 or 15% of the virtual currency service transaction amount and requires fee refunds for transactions verified as fraudulent through procedures established by the Commissioner.

Operators must collect specified user identifying information before accepting cash or credit, provide receipts, maintain live toll-free customer support during weekday hours, and display on-screen risk disclosures before each virtual currency service transaction. The regulations add detailed refund-claim procedures, receipt contents, disclosure timing, required signage, wallet-blocking controls, third-party blockchain-analysis screening for high-risk or sanctioned wallets, and a chief compliance officer requirement.

SB 741, Chapter 417 of 2026, amends the regime effective October 1, 2026. It broadens “virtual currency kiosk operator” to include a person who installs or operates software enabling a stand-alone automated device to provide virtual currency services in Maryland. It also excludes accepting or dispensing cash in connection with a credit, deposit, or convenience account from “virtual currency service” and clarifies that a kiosk may not provide the same services as an automated teller machine.

Editors should classify the regime as an in-force Maryland licensing, registration, consumer-disclosure, and fraud-prevention framework for virtual currency kiosks, with a future amendment milestone on October 1, 2026.