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

Licensing in Hawaii

No state license for crypto. When the Digital Currency Innovation Lab ended on 2024-06-30, DFI said digital currency companies no longer need a Hawaii money transmitter license (HRS ch. 489D) and may operate as unregulated businesses, subject to federal rules (such as FinCEN registration). Since 2026-10-01, Act 224 of 2026 bans kiosks that take US cash in exchange for crypto.

Regulator: Hawaii DCCA Division of Financial Institutions (no crypto license); the ban is enforced under HRS ch. 481B (unfair and deceptive practices) · License: None (crypto not licensed)

Sources: DFI release: DCIL concludes; VC companies no longer need an MTL · DFI DCIL FAQ for consumers · CSBS MTMA update August 2026 (Hawaii partial 2022 and 2023) (secondary)

Hawaii's kiosk law

Act 224 (2026), HRS ch. 481B · effective 2026-10-01

• From 2026-10-01 it is an unlawful practice to own, operate or manage in Hawaii a digital financial asset transaction kiosk (crypto ATM) that accepts US currency in exchange for a digital financial asset.
• The Act expressly still allows kiosks that accept a digital financial asset from a customer in exchange for another digital asset or for US currency. Sell-side (crypto-to-cash) kiosks remain legal.
• Violations fall under Hawaii's fair trade (UDAP) law, HRS ch. 481B.

Sources: Hawaii Legislature 2026 Acts report (Act 224, HB1642 CD1, effective 10/1/2026) · LRB: Bills passed 2026 (HB1642 description, sell-side carve-out, HRS 481B)

Bills and changes to watch

• SB 2387 (2026, Elefante) proposed regulating kiosks instead: $2,000 a day and $10,000 per 30 days per customer, blockchain analytics, and blocking offshore-exchange wallets. It passed third reading in the Senate (crossover list of 2026-03-12). It was not among the acts we found, and the HB1642 ban was enacted instead.

Practical hurdles

• Cash-in (buy) kiosks have been illegal since 2026-10-01. Only sell-side or crypto-to-crypto machines are allowed.
• There is no state crypto license to get, but federal FinCEN MSB obligations still apply.

What we couldn't confirm

• Act 224 penalty amounts. Violations go through HRS 481B, but we didn't read the enacted text.
• Whether Act 224 was signed or became law without signature. The Acts report says 'Act 224, on 07/09/2026'.
• SB 2387's final disposition.
• No enforcement actions or county ordinances were found.