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

Pennsylvania has required a license to transmit virtual currency since August 2025 (Act 7), reversing older guidance that exempted kiosks. Kiosk bills are pending.

No kiosk-specific law · Last checked

Not legal advice. This is a research summary as of 2026-10-28, written for operators deciding where to look harder. Laws change, regulators read them differently, and a bill can move in a week. Confirm anything you act on with the regulator and a lawyer licensed in the state. If you spot an error, write to hello@bitcoinscouts.com and we'll fix it.

Licensing in Pennsylvania

Act 7 of 2025 (SB 202, signed 2025-06-27, effective 2025-08-26) amended the Money Transmitter Act (Act 249 of 1965, now the 'Money Transmission and Virtual Currency Transmission Business Licensing Law'). It requires a DoBS license to engage in the business of transmitting virtual currency by means of a transmittal instrument for a fee. There is no grace period, and the 2024 Virtual Currency Statement of Policy (effective 2024-10-15) was rescinded. DoBS requires money transmitter applicants to use NMLS. This replaced DoBS's 2019 guidance, which said kiosk operators were not money transmitters.

Regulator: Pennsylvania Department of Banking and Securities (DoBS) · License: Money transmitter license

Sources: DoBS letter on Act 7 MTA amendments (no grace period; VCSOP rescinded) · DoBS news: regulating virtual currency transmitters under new law · Act 249 of 1965 as amended (Pa. General Assembly) · DoBS Non-Bank Licensees (NMLS required) · 10 Pa. Code ch. 19 (19.1a VC policy added 2024, deleted 2025-08-26) · Hunton (2019): DoBS guidance that kiosks were not money transmitters (historical) (secondary)

Kiosk-specific rules

Pennsylvania has no law written specifically for crypto ATMs as of 2026-10-28. The general money transmission rules above and the federal rules still apply.

Bills and changes to watch

  • HB 2643 (Ciresi), virtual currency kiosk regulation under Title 7, with a public education fund and penalties. Introduced 2026-06-16. Reported from House Commerce 16-10 on 2026-06-22, then re-committed to Rules. Re-reported 2026-09-08 and laid on the table the same day. Not passed by the House.
  • SB 1015 (Pennycuick), qualifying virtual currency kiosk operators, licensing and reporting. Introduced 2025-09-17 and referred to Senate Communications & Technology. No further action. A joint Senate hearing on kiosk consumer protections took place 2026-04-08.

Enforcement and lawsuits

  • The PA Attorney General has issued a public warning about scams using Bitcoin ATMs (attorneygeneral.gov 'Taking Action' listing). The date was not confirmed, and no lawsuit against a kiosk operator was found.

Practical hurdles

  • Since 2025-08-26 there has been no grace period: kiosk operators that transmit VC for a fee need a DoBS license through NMLS before operating.
  • Two kiosk bills (HB 2643, SB 1015) could add kiosk-specific rules. HB 2643 cleared committee on a party-line-looking 16-10 vote but is tabled.

Sources: PA General Assembly HB 2643 (2025-2026) · PA General Assembly SB 1015 (2025-2026) · PA AG 'AG Sunday Warns Pennsylvanians of Rise in Scams Involving Bitcoin ATMs' (seen in search results only; not opened)

What we couldn't confirm

  • The detailed provisions of HB 2643 and SB 1015 (caps, fees, refunds). The bill texts were not opened.
  • Whether DoBS views a one-way cash-to-BTC kiosk sale as 'transmitting virtual currency' under amended section 2(a)(2). The DoBS press release says entities that 'facilitate the transfer of virtual currency for a fee' need a license.
  • PA bond and net worth amounts.
  • No PA local kiosk ordinances were found. The PA AG warning page was seen only in search results, not opened.

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