Armenia's 31 January 2027 crypto licence deadline: what an existing exchanger has to change in its technology

If you run a crypto exchange office, an OTC desk or an online exchanger in Armenia, and you were operating before the Law on Crypto-assets took effect on 4 July 2025, you have until 31 January 2027 to be registered and licensed by the Central Bank of Armenia (CBA). After that date, a business without a licence has to stop providing and offering crypto-asset services. That is the CBA’s own wording on its crypto-asset service providers page.

The legal half of the application belongs to your lawyer. This article covers the other half: what the law expects your systems to do, how that depends on the services you provide, and what can realistically change in the three months that are left.

It is a technical reading of the law and the CBA’s rules, not legal advice. Article numbers refer to the official English text of the Law on Crypto-assets on ARLIS.

The dates that matter

Date	What happened
29 May 2025	The National Assembly adopts the Law on Crypto-assets (HO-159-N)
4 July 2025	The law enters into force
30 December 2025	The CBA Board adopts Regulation 7/02 on minimum capital (Decision 228-N)
31 January 2026	The CBA’s licensing and capital regulations (7/01, 7/02 and the rest of the package) take effect
31 January 2027	The one-year transition ends for businesses that were already operating: licensed, or stop

The deadline comes from Article 94(2). A legal person that already provided crypto-asset services has one year after the CBA’s licensing regulation takes effect to be registered and licensed. That regulation took effect on 31 January 2026, which gives 31 January 2027. Individual entrepreneurs get the same year to wind down, but they cannot be licensed: the CBA registers joint-stock companies and limited liability companies only.

How long review takes

Article 20(8) gives the CBA two months from submission to license or reject an applicant. One Yerevan law firm puts the practical figure at three to six months for a complete file (MB Legal), because rounds of questions add up.

Count back from 31 January. A file that goes in during November is already in the window where review can run past the deadline, and one that goes in during December almost certainly will. Ask your counsel what a pending application means for your right to keep operating: Article 94(2) speaks of being licensed by the date, not of having applied.

Which licence you need

Article 16 lists the services that need a licence, and Regulation 7/02 sets a minimum capital for each (official text):

Service	Minimum capital
Advice on crypto-assets	AMD 10 million
Executing orders for clients, receiving and transmitting orders, placement, portfolio management, transfers	AMD 20 million
Dealing on own account, custody	AMD 50 million
Operating a trading platform	AMD 70 million
Issuing asset-referenced tokens	AMD 200 million

The requirement is the higher of the service threshold and 25% of your fixed costs. If you provide several services, the strictest threshold applies. AMD 50 million is roughly USD 130,000 and AMD 70 million roughly USD 180,000.

Most exchangers have never described their business in these terms, so map it before anything else:

• You buy from customers and sell to them from your own inventory. The classic exchange office: the customer sells you USDT, you pay dram. That is dealing on own account.
• You hold customer balances between trades, or keep coins for customers. That is custody. Many online exchangers do this without calling it custody.
• Customers trade with each other on your order book. That is operating a trading platform. Article 51(5) bars the operator from buying or selling the platform’s crypto-assets on its own account, so if you want an order book and a principal desk, treat them as separate activities and ask counsel how the CBA wants them structured.
• You send coins to third parties on customers’ instructions. That is a transfer service.

A typical online exchanger that buys and sells from inventory and keeps balances lands at AMD 50 million. Add an order book and it is AMD 70 million.

The people side scales the same way. Every provider registers its CEO and AML officer with the CBA. Trading platform and custody providers also appoint and register a risk manager and a cybersecurity officer, need an independent internal audit function (in-house or outsourced), and submit a three-year business plan that is updated every year (Andersen in Armenia). The executive body has to sit at a place of business in Armenia. Each of those people will ask your system for data: the risk manager for exposure and limits, the cybersecurity officer for access logs, the auditor for a trail of every change.

What the law asks your system to do

This is the part that takes engineering time. Each line below is an obligation in the law, what it means in software, and the evidence your technical file should carry.

Obligation	Article	In the system	Evidence for the file
Client assets kept apart from the company’s	38(3)–(5), 52(1), 52(4)	Own and client crypto on different accounts or addresses; a separate record for every client; client funds never used by the company	Wallet map (which wallet holds whose money), daily reconciliation of the client ledger against on-chain balances
Loss prevention in custody	52(5), 52(12)	Procedures against cyber-attacks, deception, negligence, and record-keeping or IT failures. You are liable at market value for losses within your control	Key management policy, withdrawal approval rules (limits, multi-person approval), cold storage share, incident runbook
Client statements and returns	52(8), 52(11)	An electronic statement on request and at least every quarter; assets returned on request as fast as possible	Statement generator, withdrawal processing times
Stable trading systems	51(6)	Adequate capacity, emergency procedures, rejection of erroneous orders, continuity rules	Load test results, price bands and maximum order sizes, a trading halt, continuity plan
Market abuse detection	51(6), 51(7), 74	Procedures that detect insider dealing and manipulation; suspicion reported to the CBA immediately	Surveillance alerts (wash trades, spoofing, unusual activity before listings), case log, report template
Market data publication	51(8)–(10)	Quotes and trades published; free of charge after 15 minutes at the latest; kept on the website for two years	Public trade history and order book endpoints, retention settings
Settlement	51(11)	Final settlement within 24 hours on the distributed ledger, or by the end of the day when settlement is off the ledger	Settlement design note, ledger timestamps
Records	51(13), 40(5)	Orders and trades kept for at least seven years; complaints logged in order and kept for seven years; complaint handling free of charge	Retention policy, tamper-evident audit log, complaint register
Information security and continuity	20(1)(12), 36(2), 32(5)	A statement of compliance with the CBA’s information security standards; a business continuity plan and information security policy in your rules	Architecture and data-flow diagrams, access control, backups with tested restores, penetration test summary
Outsourcing	43(4), 43(5)	Outsourcing needs the CBA’s prior consent, or the arrangement is void. You keep final liability	Register of third parties (hosting, KYC, blockchain nodes, software vendor) and what each one does
Listing rules	51(1), 51(3), 51(4)	Published admission and suspension rules; no crypto-assets that ensure anonymity unless you can identify holders and transaction history	Listing policy, asset review records
Transfers	58	Safe and fast transfer systems; the client is told the transfer method before the transfer	Withdrawal screens that show the network and fee

Two items sit outside the Law on Crypto-assets and still land on your engineers:

• AML. The AML law applies to licensed providers in full. MB Legal lists real-time transaction monitoring, risk-based due diligence and five years of KYC and transaction records as the baseline. If you do not screen deposit and withdrawal addresses yet, the vendor contract and the integration are long-lead items.
• Tax reporting. The same firm expects providers to report customer tax residence, tax ID and transactions to the State Revenue Committee from 2027, for tax year 2026 onwards. Collecting those two fields at onboarding costs little now and a lot later.

Where exchanger stacks usually fall short

Most exchangers were built to move money quickly, not to prove where it is. The gaps tend to be the same:

• One hot wallet holds the company’s money and the customers’ together, and the per-customer record lives in a spreadsheet.
• Balances and trades sit in a Telegram bot or a CRM that cannot keep seven years of orders or produce a quarterly statement.
• Rates are set by hand with nothing that rejects an erroneous order, so one misplaced decimal pays out at the wrong price.
• There is no log of who changed a rate, a limit or a withdrawal address.
• The platform is a SaaS run by a vendor abroad. Under Article 43 that is outsourcing, and the CBA has to consent before you rely on it.
• Backups have never been restored, and the continuity plan names nobody.
• The coin list includes privacy coins.

None of these is exotic. Together they are most of a re-platforming project, and that is why the technical side, not the paperwork, usually decides whether a file is ready in time.

Three ways to close the gaps

Fix what you have. This works when your system already keeps a real double-entry ledger. Segregated wallets, retention, an audit log and statements can be added to it. It does not work if the ledger itself has to be rebuilt: building a new ledger and moving balances onto it safely is hard to fit into three months.

Keep the front office, replace the back office. Many exchangers sell through Telegram, a website and a cash desk, and customers like that part. You can keep it and put a custody and ledger layer behind it that does segregation, reconciliation, limits, records and statements. Customers notice little; your technical file gets most of what it needs.

Move to a platform and migrate once. If you also need an order book, apps and surveillance, moving users, balances and history onto a platform that already has them is faster than adding them one by one. The migration happens in one announced freeze window, with a balance reconciliation before and after that you can show your customers and the CBA.

What it costs

Capital comes first, and it is held, not spent. The rest depends on the route. These are BitPolaris list prices on 27 October 2026, excluding VAT; the pricing page has the configurator.

Item	Amount	Note
Regulatory capital	AMD 50–70 million	Held in a bank in Armenia not affiliated with you
Technical file	€1,250	System description, custody, AML and KYC sections
Licence Technical Pack Pro, mapped to the CBA	€6,300	Optional regulator Q&A while under review: €1,450 a month
Exchange, self-hosted	€24,500 one-time	Plus 20% a year for updates and support
Exchange, cloud	€1,600 a month + €7,700 setup	Hosted by us, so plan for the CBA’s outsourcing consent (Article 43)
Custody, self-hosted	€15,400, or €14,000 with Exchange	Vaults, policy engine, approvals, reserve monitor
Migration from your current system	From €9,500, fixed after assessment	One freeze window, reconciliation before and after

Counsel, the external audit, the officers’ salaries and the KYC and screening vendors come on top, and they are yours to price.

A plan for the weeks that are left

With about three months to go, the order of work matters more than its speed:

1. Week 1. Map your services to Article 16 and fix the capital tier. Decide the route (fix, back office, platform). Start the AML screening vendor contract.
2. Weeks 1–2. Write the technical file against the system you will actually run at licensing, not the one you run today. Your counsel needs it to file.
3. Weeks 2–6. Segregate wallets, build the per-client ledger and its daily reconciliation, switch on the audit log and the seven-year retention. Request the CBA’s consent for anything you outsource.
4. Weeks 4–8. Erroneous-order controls, surveillance alerts, statements, the complaint register, the public market data endpoints.
5. Weeks 6–10. A restore drill and a continuity test with names and timestamps. A penetration test, then fixes.
6. Until the decision. Answer the CBA’s technical questions from the same file, and keep the evidence current while the review runs.

If a step will not fit, say so in the file and give a date. A regulator reading a technical file looks for a system that matches its description, and a gap with a plan reads better than a gap the reviewer finds alone.

What to ask a vendor

• Where exactly do client keys live, who can move funds, and how many people have to approve?
• Can it show the client ledger reconciled against the chain, per asset, every day?
• Does it keep orders, trades and every settings change for seven years, exportable?
• Does it reject erroneous orders, and can it halt a market?
• What does it detect as market abuse, and what does an alert contain?
• If the vendor hosts anything, will it support your outsourcing consent with the CBA?
• Will it write the technical sections of your file from the system you will run?

BitPolaris delivers a technical file with every deployment, and the Licence Technical Pack maps it section by section to the Central Bank of Armenia’s rules; your counsel files the application. If your current stack will not be ready by 31 January, Exchange migration moves users and balances in one window.

Compliance & licensing

Sources

• Central Bank of Armenia, Crypto-asset service providers
• Law of the Republic of Armenia on Crypto-assets, official English text, ARLIS
• CBA Board Decision 228-N of 30 December 2025, Regulation 7/02, ARLIS
• Andersen in Armenia, Entering the Armenian cryptoasset market: regulatory essentials
• MB Legal, How to obtain a crypto license in Armenia