Updated October 10, 2026. Rewritten with the final 2026 Maryland regulations, the October 2026 law change, current fraud data and links to the official sources. Several figures in earlier versions could not be verified and have been removed. Earlier versions also gave the wrong date for when registration became mandatory: it was January 1, 2026, not July 1, 2025.
Maryland now has one of the most detailed rulebooks in the country for crypto kiosks, the machines often called Bitcoin ATMs. If you want to run one, or already do, here is what the law requires as of October 2026. This is an overview, not legal advice: talk to a lawyer who handles Maryland financial services before you invest.
Why Maryland regulated kiosks
Crypto kiosks let people turn cash into crypto in seconds, and scammers have learned to exploit that. Victims are told to take cash to a kiosk and send coins to an address the scammer controls. The FBI received more than 13,400 complaints about crypto kiosk scams in 2025, with reported losses above $388 million, up 58% from 2024. More than half of the complaints came from people over 50.
The law and the rules
- SB 305 (2025): Maryland’s virtual currency kiosk law, codified at Financial Institutions Article §12-1201 and following. Since January 1, 2026, no one may operate a kiosk in Maryland unless the operator and each machine are registered.
- COMAR 09.03.16 (2026): the Office of Financial Regulation adopted detailed kiosk rules in early 2026; they took effect March 30, 2026.
- SB 741 (2026): signed May 12, 2026 and effective October 1, 2026. It widens the definition of a kiosk operator to include companies that provide the software running stand-alone kiosks, and clarifies the difference between crypto kiosks and traditional ATMs.
Step by step
1. Form a business. Set up an LLC or corporation in Maryland or register a foreign entity through the state’s Business Express portal. Regulators and banks will expect a formal business with its own records and accounts.
2. Register with FinCEN. Kiosk operators are money services businesses under federal law. You must register with FinCEN, renew every two years, and run an anti-money-laundering program: identify customers, monitor transactions, file suspicious activity reports and keep records.
3. Register as a kiosk operator with Maryland. Apply through the Nationwide Multistate Licensing System (NMLS). The operator registration fee is $2,000, plus $200 for each kiosk. Each machine is registered separately as a fixed-location or mobile kiosk and may only operate at its approved location or area. Registrations renew every year between November 1 and December 31.
4. Get a money transmitter license if your machines can transmit money. Kiosk registration does not replace a Maryland money transmitter license. If your kiosks are capable of money transmission, you need the license even if you do not plan to offer that service. The only way around it is to disable money transmission on every Maryland kiosk and file a declaration in NMLS saying so.
5. Meet the operating rules. Under the 2026 regulations, operators must:
- Screen customer wallets against high-risk and sanctioned addresses using blockchain analytics, and monitor transactions based on risk
- Name a chief compliance officer
- Show fraud warnings and fee disclosures on screen for a minimum time, and print detailed receipts
- Meet ATM-style lighting, safety and signage standards, including signs telling customers how to complain to the state
- Follow set timelines for investigating fraud reports and refunding fees, without charging customers for the investigation or requiring a police report
- File annual kiosk-level reports on volumes, fraud notices, refunds and fees
6. Handle local and host requirements. Check county and city business licensing and zoning, and sign a written agreement with each store that hosts a machine covering responsibilities, revenue share and liability.
Is it worth it?
Compliance is now a real cost: registration fees, a money transmitter license in most cases, analytics tools, compliance staff and refund obligations. Operators who can carry those costs gain banking access and retailer trust; small operators should run the numbers carefully. Federal rules may also change, since the market structure bill advanced by the Senate Banking Committee in May 2026 included kiosk registration and consumer protection provisions, though it has not passed.
Sources
- Maryland Office of Financial Regulation: Virtual currency kiosk registration advisory (October 27, 2025)
- Maryland Office of Financial Regulation: Notice of final action, virtual currency kiosks
- COMAR 09.03.16: Virtual Currency Kiosks
- Maryland General Assembly: SB 305 (2025)
- Sheppard Mullin: Maryland finalizes rules governing virtual currency kiosks (January 23, 2026)
- National Law Review: Maryland expands scope of virtual currency kiosk law (May 28, 2026)
- BleepingComputer: FBI says Americans lost over $388 million to crypto ATM scams in 2025 (May 19, 2026)
- Davis Wright Tremaine: Senate Banking Committee advances market structure bill (May 21, 2026)
This article is for informational purposes only and is not legal advice. Requirements change; confirm current rules with the Maryland Office of Financial Regulation and a qualified attorney before operating. DynamicACG does not endorse any kiosk operator or service.