Digital Payments & Fintech · Cuba
Fintech & digital payments rules in Cuba (2026)
Cuba shaded by its digital payments & fintech status
Cuba's digital payments landscape is almost entirely state-controlled, with the Banco Central de Cuba acting as the sole financial regulator. A formal licensing regime exists for virtual asset service providers (established 2021–2022, first license issued 2025), while domestic electronic payments are channelled through two government-backed platforms, Transfermóvil and EnZona. There is no independent payment-institution or e-money framework, no open banking, and no BNPL regulation; Decree-Law 113/2025 adds foreign-currency transaction rules but does not open the market to private fintech operators.
Key points
Resolution 215/2021 (BCC, in force August 2021) established licensing requirements for virtual asset service providers (VASPs), including AML/KYC obligations. By April 2022 the BCC began issuing one-year renewable licenses; in early 2025 it granted its first license — to Lithuanian firm EBIORO UAB under BCC Resolution 134/2025 — to operate as a crypto exchange and custodian in and from Cuba.
Transfermóvil (linked to state bank accounts for utility bills, top-ups, and peer transfers) and EnZona (a domestic mobile wallet for P2P and small-business payments) are the primary retail digital-payment channels. Both operate under BCC supervision; no private domestic payment institution licensing exists.
Decree-Law 113/2025, published in Official Gazette No. 89 and in force from 17 December 2025, establishes the legal framework for managing, controlling, and allocating foreign currency in Cuba's national economy. Complementary BCC resolutions (125, 126, 140) govern foreign-currency bank accounts and allocation; non-state entities (SMEs, cooperatives) may retain up to 80 % of foreign-currency export/e-commerce income in Cuban bank accounts.
Agreement 10216, adopted August 2025 and published in the Official Gazette February 2026, requires all e-commerce operators receiving foreign-currency payments from abroad to route revenue through Cuban banks or BCC-approved mechanisms, register with the Central Commercial Registry and the Ministry of Communications, and pay taxes in foreign currency.
In March 2026 the Cuban government authorised micro, small, and medium enterprises (MIPYMEs) to use licensed cryptocurrencies for international payments, extending the practical scope of the VASP licensing regime beyond individuals to the private business sector.
Cuba has no open-banking mandate, no independent payment-institution or e-money-institution (EMI) licensing framework comparable to the EU PSD2/EMD model, and no BNPL-specific regulation. The BCC also expanded RED S.A.'s mandate to handle inbound electronic payments from abroad (Instrucción 1/2025), further consolidating state control rather than liberalising market access.
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