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

Licensing in California

Kiosk operators need a Digital Financial Assets Law (DFAL) license from DFPI; under AB 1934 operators had to be licensed or have applied by July 1, 2026 to keep operating. DFPI opinion letters (2020-2021) had held Bitcoin ATMs were not subject to the Money Transmission Act.

Regulator: California Department of Financial Protection and Innovation (DFPI) · License: DFAL license

Sources: DFPI: Digital Financial Assets (kiosk operators) · DFPI: DFAL information for kiosk operators · DFPI: Opinion letters by subject (Bitcoin ATMs not subject to MTA)

California's kiosk law

Digital Financial Assets Law, Cal. Fin. Code Div. 1.25, Ch. 9 · effective 2024-01-01. $1,000 a day per customer, a charge cap, pre-transaction disclosures, receipts and a DFAL license.

• No more than $1,000 a day accepted from or dispensed to a customer, with policies to identify the same customer across phone numbers or transactions.
• Charges, direct or indirect, may not exceed the greater of $5 or 15% of the U.S. dollar value of the digital assets in the transaction (since January 1, 2025).
• A written disclosure before each transaction (amounts, fees in dollars, your price and the exchange price), and a warning that all transactions are final if you offer no refund method.
• A receipt for every transaction, including the spread against a licensed exchange's price.
• DFAL licensing: operators who want to keep doing business in California had to apply to DFPI by July 1, 2026.

Sources: California DFPI: Digital Financial Assets Law · California DFPI: kiosk operators · Cal. Fin. Code, Div. 1.25, Ch. 9 (kiosks)

Bills and changes to watch

• AB 236 (2025-26): would cap the nonrefundable DFAL license application fee at $5,000. Status not confirmed.
• No 2026 kiosk-specific California bill found in a search of leginfo.

Local rules

• San Diego: an ordinance requiring operators and host businesses to post a City-created crypto ATM scam warning sign was on the Council Rules Committee agenda for 2026-09-16; adoption not confirmed.

Enforcement and lawsuits

• Coinme: consent order (2025-06-25), $300,000 penalty including $51,700 restitution, for exceeding the $1,000 daily limit and missing receipt disclosures; DFPI later ordered a further $175,000 in refunds for overcharges.
• Coinhub: ordered to pay $675,000 in penalties including $105,000 restitution; DFPI also issued desist-and-refrain orders against several other kiosk operators for DFAL violations, including insufficient customer ID.
• Hermes Bitcoin (Anh Management, LLC): settlement requires it to stop operating its 42 Southern California kiosks by 2026-05-20 and bars it from digital asset business in California.
• DFPI lists an enforcement action against Athena Bitcoin, Inc. (details not read).

Practical hurdles

• DFPI is actively examining kiosk operators; a series of 2025-2026 orders show it enforces the $1,000 daily limit, receipt spread disclosures, fee cap and ID collection.
• Receipts must show the spread against a 'licensed digital financial asset exchange' that does not operate kiosks; DFPI said that until DFAL licenses issue, only New York BitLicensed exchanges qualify.
• Location list: report all kiosk locations to DFPI and file changes within 30 days via DFPI's template and upload site; DFPI publishes the list.
• A challenge to the $1,000 daily limit was dismissed by Los Angeles Superior Court on 2024-08-30.
• Scam pressure context: FBI IC3 counted 978 crypto-kiosk complaints from this state in 2025 with $24,017,535 in adjusted losses (FBI notes losses may include non-kiosk transactions).

What we couldn't confirm

• Whether DFAL license applications are filed through NMLS (not confirmed from a DFPI page we read).
• Dates of the Coinme $175,000 and Coinhub orders.
• Adoption of the San Diego sign ordinance.