Fintech & payments regulation in Cuba (2026)
Fintech and digital payments in Cuba: partial.
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.
Legal framework
Banco Central de Cuba (BCC), Resolution 215/2021 (virtual asset service providers), Decree-Law 113/2025 (foreign currency transactions), Resolution 134/2025 (first VASP license); state-operated platforms Transfermóvil and EnZona under BCC oversight
Key points: digital payments & fintech in Cuba
Virtual asset licensing regime
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.
State-run domestic payment platforms
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.
Foreign-currency transaction framework (Decree-Law 113/2025)
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.
E-commerce foreign-payment rules (Agreement 10216/2025)
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.
Crypto authorised for SME international payments (2026)
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.
Gaps: no open banking, no EMI regime, no BNPL rules
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.
Timeline of decisions
- Law176-Measure Reform Package: Cuba Authorizes Private Banking for First Time Since 1959
Cuba's National Assembly approved 176 sweeping economic reforms — the most profound since the Revolution — including authorization of private banks operating under BCC oversight, removal of bank transfer and withdrawal limits, regulation of virtual assets and fintech under 'Axis 11,' and establishment of a real-time digital currency exchange market.
PBS NewsHour / Granma
- LawResolution 111/2023: Mandatory Electronic Payments and CUP 5,000 Cash-Transaction Cap
Published in Extraordinary Official Gazette No. 55, Resolution 111/2023 required all state and private companies to accept electronic transfers and capped cash transactions at CUP 5,000 per operation, with fines up to CUP 60,000 and potential business closure for non-compliance. By official admission, only 3.77% of transactions became digital — widely declared a policy failure.
Caribbean Council / BCC Official Gazette No. 55
- Decision · officialMLC Store Network Launched: Cuba's First Mass Card-Only Payment Mandate
Cuba opened at least 77 state-run retail stores accepting only card payments denominated in Moneda Libremente Convertible (MLC) — a virtual dollar-equivalent currency linked to special BCC-issued MLC debit cards. This created Cuba's first large-scale mandatory card-payment environment and drove mass adoption of bank-card infrastructure across the population.
Granma (Official PCC organ)
- Law · officialDecrees 359 & 360: Cuba's First Comprehensive ICT and Digital Economy Legal Framework
Cuba enacted Decrees 359 and 360 — the first normative instruments at Council of Ministers level governing the digital economy. Decree 359 established the concept of a software industry; Decree 360 regulated secure ICT use and cyberspace defense. Together they provided the legal scaffolding for subsequent fintech and e-payment regulation.
Granma (Official PCC organ)
- Decision · officialEnZona Mobile Wallet Launched by State IT Firm XETID
Cuba's state Defense Information Technology Company (XETID) launched EnZona, a mobile wallet functioning as a domestic PayPal/Venmo equivalent. EnZona grew to over one million users and enabled peer-to-peer transfers and merchant payments within both the CUP and MLC ecosystems, complementing Transfermóvil's utility-payment focus.
Portal del Ciudadano en San Antonio (Cuban government portal, .gob.cu)
- Decision · officialTransfermóvil Launched: Cuba's First State Mobile Banking Application
ETECSA, in partnership with state banks BANDEC, BPA, and BANMET, launched Transfermóvil on February 10, 2015 — Cuba's first mobile banking app. It enabled utility bill payments, mobile top-ups, and bank transfers via linked debit cards, eventually reaching 5 million registered users and over 110 million transactions per month, becoming the backbone of Cuba's domestic digital payment system.
ETECSA (Cuba's state telecommunications operator, official)
Sources
- loc.gov/item/global-legal-monitor/2021-10-04/cuba-central-bank-issues-directi
- gacetaoficial.gob.cu/es/activos-virtuales
- gacetaoficial.gob.cu/es/instruccion-1-de-2025-de-banco-central-de-cuba
- www1.bc.gob.cu/noticia/publica-la-gaceta-oficial-el-decreto-ley-113-y-las-nuevas-nor
- lexlatin.com/opinion/cripto-en-cuba-regulacion-bcc-licencia-proveedor-extranjero
- en.cibercuba.com/noticias/2025-12-11-u1-e129488-s27061-nid316533-gobierno-cubano-anunc
- cubaheadlines.com/articles/321804
- en.cibercuba.com/noticias/2026-03-24-u1-e208574-s27061-nid323869-regimen-cubano-autori
- lightspark.com/knowledge/cuba-real-time-payments
- thefintechtimes.com/slightly-emerging-yet-stagnant-the-fintech-ecosystem-of-cuba/
- sanantonio.gob.cu/en/news/7453-transfermovil-y-enzona-plataformas-de-pago-cubanas-2
- cubaheadlines.com/articles/321765
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Next topicOrientation, not legal advice: verify against the primary sources linked above. Last verified 24 May 2026. Methodology & how to cite · State of Technology Regulation 2026