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

Licensing in New Hampshire

New Hampshire's money transmitter law (RSA 399-G, rewritten by 2024 ch. 368, eff. 2024-10-22) expressly exempts persons who sell or issue payment instruments or stored value solely in convertible virtual currency, or who receive convertible virtual currency for transmission. Such persons are instead subject to the Consumer Protection Act (RSA 358-A). The exemption dates from HB 436 (2017, ch. 70). A crypto-only kiosk operator therefore appears to need no NH money transmitter license, but is covered by the new kiosk chapter RSA 358-U from 2026-12-16.

Regulator: NH Banking Department (money transmitters); Department of Justice Consumer Protection & Antitrust Bureau (enforces RSA 358-A and RSA 358-U) · License: None (crypto exempt)

Sources: RSA 399-G:3 Exemptions (para. VII, convertible virtual currency) · RSA 399-G:2 Definitions (cross-reference to VC exemption) · HB436 (2017) bill status: exempting persons using virtual currency from registering as money transmitters, ch. 0070

New Hampshire's kiosk law

RSA 358-U (SB 482, 2026) · effective 2026-12-16

• Daily cap of $2,000 per customer per calendar day, counted across all kiosks under common control anywhere in the US. The cap applies to all customers, not only new ones.
• A customer's first transaction must be held for at least 48 hours, and no second transaction is allowed until the hold ends. During the hold the customer can cancel and get the full amount back.
• Before taking funds, the kiosk must show prominent scam warnings, including that no government agency, police, court, utility, bank, tech support, employer or retailer will ever demand payment by crypto ATM.
• The kiosk must ask fraud-screening questions, including whether someone is coaching the customer. If the answers show fraud risk, it must block the transaction and display law-enforcement and AG Consumer Protection Bureau contacts.
• Before taking funds, the kiosk must disclose in writing and on screen all fees, the spread against a real-time reference price (as a percentage and in dollars), and the total crypto to be delivered. The statute sets no percentage fee cap.
• Operators must use blockchain analytics to block transfers to or from wallets flagged for scams, theft, sanctions or other illicit activity, and must keep written anti-fraud and consumer-protection policies.
• Every transaction needs a printed and electronic receipt with: operator name, toll-free live customer service number, kiosk location, timestamp, asset name and quantity, reference price, spread, all fees, total paid, wallet address or voucher ID, cancellation codes and refund policy.
• Customers fraudulently induced to transact get a full refund of all transactions, fees included, if they report to the operator and to a law-enforcement or government agency within 14 days of their last transaction.
• Identity must be verified before accepting payment, and no transactions are allowed under false or assumed identities.
• Operators must post a monitored phone line or email for law-enforcement and regulator contact.
• Any violation is an unfair or deceptive practice under RSA 358-A and is enforceable with that act's remedies. Per the NH DOJ, civil penalties run up to $10,000 per violation.

Sources: RSA 358-U:1 Statement of purpose · RSA 358-U:2 Definitions · RSA 358-U:3 Registration and coordination (48-hour hold, ID, LE line) · RSA 358-U:4 Core consumer protections · RSA 358-U:5 Remedies · NH General Court 2026 chaptered list (ch. 187 = SB0482) · NH DOJ data privacy page (RSA 358-A civil penalty up to $10,000 per violation)

Bills and changes to watch

• SB 482 (2026) was enacted as Laws 2026 ch. 187, effective 2026-12-16. A House committee amendment (2026-1526h) appears in the 2026-04-17 House Record. No other pending NH kiosk bills were found.

Practical hurdles

• From 2026-12-16 the $2,000/day cap applies to every customer, existing ones included, and counts nationwide across all of an operator's kiosks. That limits high-volume repeat users.
• The mandatory 48-hour hold on a first transaction, plus refunds for fraud victims who report within 14 days, puts loss exposure on the operator.

What we couldn't confirm

• Whether NH Banking Department licensing or NMLS applies to kiosk operators that handle fiat in other ways. The VC exemption in RSA 399-G:3 VII covers only VC-only activity.
• Whether the 2024 rewrite of RSA 399-G (2024 ch. 368) is an MTMA adoption. It looks MTMA-like (tangible net worth, authorized-delegate structure), but no source confirmed it.
• The governor's signing date for SB 482. The RSA source line gives only the chapter number and the 2026-12-16 effective date.
• No NH AG enforcement actions or local ordinances against kiosk operators were found.