Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the BCU authorisation, including banking and payment rails.
Get a payment license in Uruguay.
Uruguay authorises electronic money issuers through its central bank under the financial-inclusion law of 2014. Article 4 of Ley 19.210 asks for the prior authorisation of the Banco Central del Uruguay, and Article 86 of the payment-systems rulebook adds a separate habilitación from the payment systems division before the first instrument is issued. The rulebook prints no minimum capital, no decision period and no fee. Twelve issuers hold the authorisation today, out of forty-nine payment-system registrants.
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Uruguay in brief
One statute, one rulebook, and a capital figure the text does not print.
Ley N° 19.210, the financial-inclusion law promulgated on 29 April 2014, is where the regime starts. Article 4 says an issuer of electronic money must obtain the prior authorisation of the Banco Central del Uruguay, decided on grounds of legality, opportunity and convenience. The detail sits in the central bank's payment-systems rulebook, the Recopilación de Normas de Sistema de Pagos, Libro VII. Article 82 sets who may apply: any commercial company form Uruguayan law provides, with a statute stating the e-money object of Article 93 and providing that issuing new shares or transferring existing ones needs the bank's prior authorisation. Article 84 has the Gerencia de Sistema de Pagos send an opinion to the board on the quality of the administration and the technology, the state of risk management and, where it applies, the cash-withdrawal network. Article 86 then requires a separate habilitación from the same division, tied to the category of e-money issued, before a single instrument reaches a customer. The rulebook prints no minimum capital and no minimum net worth for issuers. That is an absence in the text, not a figure we could not find.
What the rulebook does quantify is other people's money. Article 99 puts client funds in accounts at licensed banks used for nothing else. Article 100 makes those balances a patrimonio de afectación independiente, separate from the issuer's own estate until the holder spends them. Article 101 allows the administered funds to be invested only in placements of no more than twelve months, and only in bank placements and public securities, with the prior authorisation of the payment systems division and proof of liquidity. One figure is quantified: Article 93.3 asks issuers that place e-money balances in investment-fund units for a guarantee in favour of the central bank of UI 2,000,000, plus 0.5% of the nominal value of the units issued at each quarter end. Twelve e-money issuers hold the authorisation, out of forty-nine payment-system registrants. No article prints a decision period and no fee schedule is published, so the file has to be right at first reading. The central bank presented its payments roadmap for 2026 to 2030 on 23 March 2026. Tax is IRAE at 25%, IVA at 22% with a 10% minimum rate, and 7% on dividends to non-residents. We run the file from Madeira, in Spanish.
Ley 19.210, Article 4: prior authorisation from the Banco Central del Uruguay. Article 86 of the payment-systems rulebook adds a separate habilitación before issuing. Any Uruguayan commercial company form qualifies under Article 82. Libro VII prints no minimum capital and no minimum net worth, and no decision period.
Client funds sit at licensed banks under Article 99 and form a patrimonio de afectación under Article 100; placements are capped at twelve months and limited to banks and public securities. Twelve issuers of forty-nine registrants. IRAE 25%, IVA 22%. Six to nine months realistic. We run it from Madeira.
The routes
The e-money issuer, or one of the other seven register categories.
The BCU register carries eight payment-system licence types. One of them issues stored value and the other seven move, switch, acquire or collect it. We fix the route first, then build once.
The e-money issuer authorisation, or one of the other seven categories on the same register.
01 - E-MONEY ISSUER
Institución Emisora de Dinero Electrónico
The Article 4 authorisation of the Banco Central del Uruguay, granted on grounds of legality, opportunity and convenience, followed by the separate habilitación of Article 86 before issuing. Any Uruguayan commercial company form qualifies under Article 82, and Libro VII sets no capital floor.
The Article 4 authorisation of the Banco Central del Uruguay, granted on grounds of legality, opportunity and convenience, followed by the separate habilitación of Article 86 before issuing. Any Uruguayan commercial company form qualifies under Article 82, and Libro VII sets no capital floor.
- ✓Any commercial company form Uruguayan law provides (Article 82)
- ✓No minimum capital and no minimum net worth in Libro VII
- ✓Client funds at licensed banks, used for nothing else (Article 99)
- ✓Balances form a patrimonio de afectación independiente (Article 100)
- ✓Investment only in bank placements and public securities to 12 months (Article 101)
- ✓Separate habilitación per e-money category before issuing (Article 86)
02 - PAYMENT SYSTEM PARTICIPANT
Seven other categoriesProveedores de servicios de pago y cobranza
A business that processes, switches, acquires or collects without issuing stored value applies in one of the register's other seven categories. A licensed bank needs no e-money authorisation at all under Article 82, only the habilitación of Article 86.
Payment and collection services, POS networks, switches, processors and acquirers - the register's other seven categories. Banks take only the Article 86 habilitación.
- ✓Payment and collection service providers
- ✓POS terminal network administrators and automated clearing houses
- ✓Switch providers and processors of electronic payment means
- ✓Acquirers, including acquirers of payments by domestic funds transfer (PCT)
- ✓Banks take the habilitación without a separate IEDE authorisation (Article 82)
- ✓Forty-nine registrants across the eight categories at September 2026
Costs and timelines are confirmed for your case before any work begins. The central bank publishes no application or supervision fee for e-money issuers, so the state charges, the segregation set-up and substance are itemised in your quote.
Why Uruguay
A short register, segregated client money, and no capital to fund.
Uruguay is the small, orderly end of the region: twelve authorised issuers, a rulebook that puts client money outside the insolvency estate, and no figure to raise before the file is read.
✓
No capital floor in the rulebook
Libro VII sets no minimum capital and no minimum net worth for e-money issuers. The file is judged on administration, technology and risk management under Article 84 instead.Libro VII prints no figure.
✓
Client money out of the insolvency estate
Article 7 of Ley 19.210 keeps segregated funds out of the concurso estate and has them handed back to holders without delay, with no prior court order.Article 7 returns them to holders.
✓
Twelve issuers on the register
Twelve e-money issuers out of forty-nine payment-system registrants at September 2026 - a supervisor that reads each file itself rather than through a queue.Forty-nine registrants in total.
✓
E-money split into four categories
Article 81 divides instruments into special, general, mixed and meal money. Salary, professional fees, pensions and social benefits form their own class, with the habilitación granted per category.Salary money has its own class.
✓
The basic instrument is free by decree
Decreto 263/015 gives the basic instrument no opening, maintenance or closing cost and eight free domestic transfers of up to UI 2,000 each, charged to neither party.Eight free transfers by decree.
✓
A published payments roadmap
The central bank presented its Hoja de Ruta del Sistema de Pagos 2026-2030 on 23 March 2026, with faster payments among the work streams it names.Presented 23 March 2026.
How it compares
How Uruguay differs from its neighbours.
Uruguay sells a small careful register and no capital figure. Its neighbours sell scale, a printed clock or a lower rate. The honest comparison is below.
Uruguay vs other jurisdictions
| Feature |  Uruguay | Other jurisdictions |
|---|---|---|
| Capital | Not printed in the rulebook | S/ 2.89M in Peru · R$ 2M in Brazil |
| Client funds | Patrimonio de afectación · Arts. 99-101 | Trusts and central-bank deposits |
| Decision period | None in Articles 82 to 86 | Argentina: 10 + 20 business days of admin |
| Corporate tax | IRAE 25% · IVA 22% | 27% to 35% across the region |
Capital
UruguayNot printed in the rulebook
Other jurisdictionsS/ 2.89M in Peru · R$ 2M in Brazil
Client funds
UruguayPatrimonio de afectación · Arts. 99-101
Other jurisdictionsTrusts and central-bank deposits
Decision period
UruguayNone in Articles 82 to 86
Other jurisdictionsArgentina: 10 + 20 business days of admin
Corporate tax
UruguayIRAE 25% · IVA 22%
Other jurisdictions27% to 35% across the region
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Uruguay | IEDE (BCU) | 25% · IVA 22% | No capital printed · funds segregated |
 Argentina | PSP registration (BCRA) | 25/30/35% | No capital · 100% in sight accounts |
 Paraguay | EMPE (BCP) | 10% · IVA 10% | No capital printed · 100% guaranteed |
 Brazil | Instituição de pagamento (BCB) | ≈34% | R$ 2M per modality · R$ 1M ITP |
UruguayLicense typeIEDE (BCU)
Taxation25% · IVA 22%
RequirementsNo capital printed · funds segregated
ArgentinaLicense typePSP registration (BCRA)
Taxation25/30/35%
RequirementsNo capital · 100% in sight accounts
ParaguayLicense typeEMPE (BCP)
Taxation10% · IVA 10%
RequirementsNo capital printed · 100% guaranteed
BrazilLicense typeInstituição de pagamento (BCB)
Taxation≈34%
RequirementsR$ 2M per modality · R$ 1M ITP
Before you apply
Requirements for the BCU authorisation.Requirements for the authorisation.
Article 82 of the payment-systems rulebook lists the file and Article 84 the test the payment systems division applies. The checklist below is what a passing file contains.
01
A company in any of the commercial forms Uruguayan law provides, with a statute stating the corporate object of e-money activities under Article 93.
02
A statute clause requiring the prior authorisation of the central bank for issuing new shares and for transferring existing ones (Article 82(ii)).
03
Shareholders incorporated abroad organised as commercial companies under the law of their own country, documented to the central bank.
04
No minimum capital to raise: Libro VII prints none, so the money in the file is the money the business plan actually needs.
05
The Article 82 documents: identification and tax and social-security registration, notarial testimony of the statute, shareholder and director details with capital contributed and the percentage held, CVs and a senior-management schedule.
06
A description of the administration and the technology, and of the state of risk management - the three points Article 84 has the payment systems division report on to the board.
07
Client funds placed in accounts at licensed banks used for no other purpose (Article 99), forming a patrimonio de afectación independiente under Article 100.
08
Any investment of administered funds limited to bank placements and public securities of no more than twelve months, with the prior authorisation of the payment systems division and proof of liquidity (Article 101).
09
For issuers taking the Article 93.2 option of placing balances in investment-fund units, the Article 93.3 guarantee of UI 2,000,000 plus 0.5% of the nominal value of units issued each quarter.
10
An AML and counter-terrorist-financing system under Articles 114 and following, with a compliance officer answerable for its implementation, monitoring and control, and annual accounts carrying an external audit opinion under Article 113.
01
Uruguayan commercial company (Article 82).
02
Statute states the Article 93 e-money object.
03
Share issues and transfers need BCU consent.
04
Foreign shareholders documented as companies.
05
No minimum capital in the rulebook.
06
Client funds at licensed banks (Article 99).
07
Patrimonio de afectación (Article 100).
08
Placements capped at 12 months (Article 101).
09
AML system and compliance officer (Arts. 114 ff.).
10
Article 86 habilitación before issuing.
Reflects Ley N° 19.210 of 2014 as amended by Ley N° 19.478 (2017) and Ley N° 20.446 (2025), Decreto N° 263/015 and the Recopilación de Normas de Sistema de Pagos, Libro VII, as of 2026.Ley N° 19.210 (2014, amended 2017 and 2025); Decreto N° 263/015; RNSP Libro VII.
How it works
From first call to the BCU register.
01
Route and category
E-money issuer or one of the other seven register categories; the Article 81 instrument type; the route and budget fixed in writing.IEDE or another register category.
02
Company and statute
Uruguayan commercial company formed, the Article 93 object and the share-transfer clause in the statute, tax and social-security registration done.Object and share clause in place.
03
The application file
Article 82 documents complete: notarial testimony, shareholders and directors with CVs, management schedule, administration, technology and risk description.Article 82 documents complete.
04
BCU review
The payment systems division reports to the board under Article 84 and question rounds are answered. No clock is printed; plan on six to nine months.No printed clock; 6-9 months.
05
Habilitación and launch
Authorisation granted, the Article 86 habilitación taken for the e-money category, segregated accounts opened, the first instrument issued.Article 86, then first issue.
Quick facts
RegulatorBanco Central del Uruguay
LawLey 19.210 (2014) · RNSP Libro VII
AuthorisationArticle 4 · habilitación Article 86
CapitalNone printed
Client fundsSegregated at licensed banks
DecisionNo statutory period
Timeline6-9 months realistic
Corporate taxIRAE 25% · IVA 22%
Articles 82 to 86 print no decision period, which puts the whole weight on the first filing. A file the payment systems division can report on without a second round is what keeps the review short, and our job.
Your Uruguay desk
Run from our Americas desk.
Prifinance - Americas desk
Madeira · coordinating Uruguayan mandates in Spanish
Rua da Alegria 31, 1F, Madeira
01
Uruguayan company formation
A commercial company under Article 82 with the Article 93 object and the share-transfer clause written into the statute from the start, plus tax and social-security registration.Article 93 object; share-transfer clause.
02
The BCU file
Shareholder and director schedules with CVs, the administration, technology and risk description Article 84 is judged on, and the AML manual - drafted by us and defended through the question rounds.Article 82 documents, Article 84 test.
03
Segregation and investment
The dedicated bank accounts of Article 99, the patrimonio de afectación of Article 100 and, where balances are placed, the Article 101 authorisation from the payment systems division.Bank accounts; Article 101 placements.
04
Substance in Uruguay
A compliance officer answerable for the AML system, an external auditor for the accounts under Article 113, and the Montevideo presence the register entry is built on.Compliance officer, auditor, Montevideo.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Uruguay.
IRAE at 25%, IVA at 22% with a 10% minimum rate, and 7% withholding on dividends to non-residents - read off the DGI's Texto Ordenado rather than a summary of it.
IRAE 25%
Título 4, Article 23: 25% on net fiscal income. No reduced corporate rate appears anywhere in that title.Título 4, Article 23.
IVA 22% and 10%
Título 10, Article 34 sets a basic rate of 22% and a minimum rate of 10%. Which fee lines fall where is mapped before you price the product.10% minimum rate.
Dividends 7%
Título 8, Article 18: dividends and profits paid or credited by IRAE taxpayers to non-residents are withheld at 7%.To non-residents.
Other non-resident income 12%
The general non-resident rate is 12%, rising to 25% for income obtained by residents of low-tax jurisdictions.25% low-tax jurisdictions.
Interest 0.5% to 12%
Interest on deposits and debt instruments paid to non-residents is withheld between 0.5% and 12%, depending on the instrument and its term.By instrument and term.
Payroll
Income tax and social-security contributions on Montevideo salaries. The operating budget prices them in with the compliance and audit hires.Income tax + contributions.
Tax summary
Corporate tax (IRAE)25%
VAT (IVA)22% · 10% minimum rate
Dividends to non-residents7%
Other non-resident income12% · 25% low-tax jurisdictions
Interest to non-residents0.5%-12%
PayrollIncome tax + contributions
*Figures as of 2026 per the DGI Texto Ordenado 2023. Treaty and regime positions are assessed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Uruguayan commercial company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, authorised issuer.
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The Uruguayan payment authorisation, answered.
What authorisation does an e-money business need in Uruguay?+
Prior authorisation from the Banco Central del Uruguay under Article 4 of Ley 19.210, and then a separate habilitación from the payment systems division under Article 86 of the payment-systems rulebook before any instrument is issued. The habilitación is tied to the category of e-money you issue.
How much capital is required?+
None is printed. Libro VII of the payment-systems rulebook sets no minimum capital and no minimum net worth for e-money issuers. The single quantified financial requirement is Article 93.3, and it reaches only issuers that place balances in investment-fund units.
What is the Article 93.3 guarantee?+
A guarantee in favour of the central bank of UI 2,000,000, plus 0.5% of the nominal value of the fund units issued at the end of each quarter. It is pledged over a UI-denominated deposit at the central bank or over UI-denominated quoted national public securities deposited there.
How are client funds protected?+
Article 99 places them in accounts at licensed banks used for nothing else. Article 100 makes the balances a patrimonio de afectación independiente, separate from the issuer's estate until they are spent. On insolvency, Article 7 of Ley 19.210 keeps them out of the concurso and returns them to holders without delay.
Can the issuer invest the balances?+
Only in placements of no more than twelve months, and only in bank placements and public securities, with the prior authorisation of the payment systems division and proof of liquidity (Article 101). Income and losses on those placements are the issuer's own account under Article 102.
How long does the central bank take?+
Articles 82 to 86 print no decision period and no processing statistics are published. Article 84 sets a test rather than a clock: administration, technology, risk management and, where it applies, the cash-withdrawal network. Plan on six to nine months end to end.
Are there limits on e-money balances?+
No balance or transaction cap appears in Libro VII or in Decreto 263/015. Cash withdrawal at a merchant is capped at 1,500 UI per withdrawal under Article 81.1, and the instrument pays no interest by definition under Article 2 of Ley 19.210.
What do the state fees come to?+
The central bank publishes no application or supervision fee for e-money issuers. We quote the professional work and the third-party costs we can price, and confirm the state charges with the regulator before you commit to a budget.
How are payment companies taxed?+
IRAE at 25% on net fiscal income, IVA at 22% with a 10% minimum rate, and 7% withholding on dividends paid to non-residents. Other non-resident income is 12% in general and 25% where the recipient sits in a low-tax jurisdiction.
Why Uruguay rather than Argentina or Brazil?+
Uruguay has the smallest register of the three, no capital figure to fund and client money written out of the insolvency estate. Argentina registers rather than licenses and carries 215 payment-account providers, so the market is deeper and the rules on client money stricter. Brazil asks for R$ 2 million per modality and supervises a far larger market. Groups that want a quiet base and a supervisor with twelve issuers start here.
Which authorisation?+
BCU under Article 4, plus the Article 86 habilitación.
Capital?+
None printed in Libro VII.
The 93.3 guarantee?+
UI 2,000,000 plus 0.5% for fund-unit placements.
Client funds?+
Licensed banks; patrimonio de afectación.
Investment?+
Banks and public securities to 12 months.
How long?+
No printed period; 6-9 months realistic.
Wallet limits?+
None; cash withdrawal capped at 1,500 UI.
Fees?+
None published; confirmed with the regulator.
Taxes?+
IRAE 25%, IVA 22%, dividends 7%.
vs Argentina / Brazil?+
Smallest register; no capital figure.
Client notes
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Banco Central del Uruguay or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.