Crypto ATM laws in Maryland: a guide for operators (2026)

Licensing in Maryland

Since 2026-01-01 every kiosk operator must register with the Office of Financial Regulation, and each kiosk must be registered separately, both through NMLS ($2,000 operator fee, $200 per kiosk, renewed annually Nov 1-Dec 31). Registration is separate from money transmission: a kiosk that can also facilitate money transmission needs a Maryland money transmitter license too, unless the operator disables those features and files a declaration in NMLS.

Regulator: Office of Financial Regulation (Commissioner of Financial Regulation), Maryland Department of Labor · License: Kiosk registration (plus MTL where needed)

Sources: OFR advisory: Virtual Currency Kiosk registration (2025-10-27) · OFR advisory: Operating Without Registration is Prohibited (2026-02-03) · Md. Code, Fin. Inst. §12-1203 (kiosk registration) · CSBS MTMA legislative update, August 2026 (Maryland full MTMA via COMAR 09.03.14, rules effective 2023-12-11) (secondary)

Maryland's kiosk law

Md. Fin. Inst. 12-1201 et seq. (SB 305, 2025; SB 741, 2026) · effective 2025-07-01

• No kiosk may operate in Maryland on or after 2026-01-01 unless the operator and the kiosk are registered; renewal is annual.
• Daily cash limit per person across one or more kiosks: $2,000 for a new user and $10,500 for an experienced user.
• A 'new user' is someone transacting with that operator for the first time or within 72 hours after their first transaction.
• Fees may not exceed the greater of $5 or 15% of the transaction.
• Fees on a transaction verified as fraudulent must be refunded, by a process set in OFR regulations.
• Before accepting cash, the operator must collect name, date of birth, mailing address, email, phone and a copy of government ID.
• Before each transaction the screen must show a fee schedule, a statutory 'not legal tender / not FDIC insured' statement, a statutory scam WARNING, operator contact information and hours, and current exchange rates, and the user must acknowledge each one.
• Receipts must show the coin type, value and exchange rate, date and time, kiosk identifier and the toll-free support number.
• Live customer support must be reachable at a toll-free number at least Monday-Friday, 8 a.m.-6 p.m.
• Registration must list each fixed address (kiosks at one place more than 30 days a year) or the geographic area for mobile kiosks.
• OFR regulations add rules on fee refunds, fraud prevention (including blockchain analytics screening and a chief compliance officer, per a secondary summary), minimum on-screen disclosure time, lighting, safety and signage, receipts and an annual kiosk-level report through NMLS.
• From 2026-10-01 (SB 741) the operator definition also covers anyone who installs or operates kiosk software, and kiosks may not provide the same services as an ATM.

Sources: Md. Code, Fin. Inst. §12-1204 (limits, fees, ID, receipts) · Md. Code, Fin. Inst. §12-1205 (on-screen disclosures) · Md. Code, Fin. Inst. §12-1206 (live customer support) · Md. Code, Fin. Inst. §12-1201 (definitions) · OFR: Notice of Emergency Regulation (Md. Register Vol. 52, Issue 26, p. 1306) · OFR: Notice of Proposed Regulation (topics covered) · Legal500/Mondaq: Maryland finalizes rules governing virtual currency kiosks (secondary) · Orrick InfoBytes, 2026-05-22: Governor signs SB 741 (signed 2026-05-12, effective 2026-10-01) (secondary)

Bills and changes to watch

• SB 741 (2026): signed 2026-05-12, in force 2026-10-01; widens 'operator' to anyone who installs or operates kiosk software and separates kiosks from ATMs (now enacted, listed for context).

Enforcement and lawsuits

• Victims have sued Athena Bitcoin alleging elder abuse (private suit, per Cointelegraph, 2025-08-15; case details not checked).

Practical hurdles

• Two layers of registration (operator plus every kiosk) through NMLS, with $2,000 + $200 per kiosk every year.
• Registration does not replace a money transmitter license if the kiosk can do money transmission; operators must either license or disable those features and file a declaration.
• Moving a fixed kiosk to a new address needs the registration updated; mobile kiosks are limited to a registered geographic area.

What we couldn't confirm

• COMAR chapter number, final effective date and numeric details of the OFR kiosk regulations (refund timelines, disclosure display time, annual report dates); the final-action notice could not be opened.
• Whether the regulations' blockchain analytics and chief compliance officer duties are exactly as summarized (secondary source only).
• Any Maryland AG or OFR enforcement action against a kiosk operator (none found in a quick search).
• Any Maryland county or city kiosk ordinances (none found).