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

Licensing in Kansas

Kiosk operators are deemed to be engaged in money transmission and need a Kansas money transmitter license under the Kansas Money Transmission Act (Kansas's MTMA, HB 2560 of 2024, effective 2025-01-01). Operators not licensed on 2026-07-01 had to apply within 60 days after that date; those who applied on time may keep operating while a complete application is reviewed, and must stop if it is denied. OSBC has a money transmitter VC-kiosk supplemental checklist.

Regulator: Office of the State Bank Commissioner (OSBC) · License: Money transmitter license

Sources: OSBC: copy of the Virtual Currency Kiosk Consumer Protection Act (HB 2591, Secs. 6-11) · OSBC news post on the VCKCPA, effective 2026-07-01 · OSBC MT virtual currency kiosk supplemental checklist · CSBS MTMA legislative update, August 2026 (Kansas HB 2560, full MTMA, effective 2025-01-01) (secondary)

Kansas's kiosk law

Virtual Currency Kiosk Consumer Protection Act (HB 2591, 2026) · effective 2026-07-01

• A first-time (initial) transaction is capped at $1,000.
• Within 14 days of the initial transaction: up to $1,000 per day, only one transaction in the first 72 hours, and $10,000 total over the 14 days.
• More than 14 days after the initial transaction: up to $10,500 per day.
• Transactions within 14 days of the initial transaction are held for 72 hours.
• Total direct and indirect charges are capped at the greater of $5 or 18% of the transaction; any spread over market price counts as a charge, and market-price records must be kept.
• A new customer can get a full refund for any reason during the 72-hour hold.
• A fraud victim who reports within 30 calendar days of the last fraudulent transmission and files a police report or sworn declaration gets a full refund (amount plus fees) for initial/first-14-day transactions; existing customers get back fees and charges only.
• Refunds are paid by cash, ACH or paper check within 10 business days; an operator may delay for cause if it reports suspected fraud to the commissioner, the AG or police.
• Ten risk disclosures and terms and conditions are required before the first transaction, plus an on-screen fraud warning before every transaction (at least 12-point font, tap to acknowledge, also emailed; Spanish version for Spanish-language transactions).
• Receipts must show operator contact and complaint phone number, transaction type, value, date and precise time, fee, exchange rate, any spread fee, refund policy and full wallet address; kiosks placed in service on or after 2026-07-01 must print paper receipts.
• Live, trained customer service must be available during kiosk operating hours, with a toll-free number on the kiosk or screen.
• Operators must employ a full-time consumer protection officer who owns no more than 20% of the company and has a dedicated phone line and email for police and regulators.
• Blockchain analytics software is mandatory to block sends to wallets known to be linked to fraud.
• Quarterly kiosk location reports are due to the commissioner within 45 days after each quarter (names, addresses, in-service dates, hours, start/end dates).
• A written anti-fraud policy and a board-approved enhanced due diligence policy (flagging people at risk by age or mental capacity) are required.
• Operators must verify ID and collect name, date of birth, phone, address and email before accepting payment, and are strictly liable if someone transacts under another person's name.

Sources: OSBC: VCKCPA text (HB 2591 Secs. 6-11) · Kansas Legislature: HB 2591 bill page (Signed by Governor) · Orrick InfoBytes, 2026-05-01: Kansas enacts kiosk protections (HB 2591) (secondary) · FS Vector: Kansas Enacts Licensing for Virtual Currency Kiosks (secondary)

Bills and changes to watch

• HB 2515 (2026), a stand-alone kiosk bill with a $2,000 initial-transaction cap, is shown on the Legislature's bill page as vetoed by the Governor (veto date not shown). Similar kiosk provisions, but with a $1,000 initial cap, were enacted in omnibus HB 2591.

Enforcement and lawsuits

• 2026-10 (headline dated 2026-10-08 on OSBC site): Kansas joined a $2.5 million multistate settlement with kiosk operator Coinme Inc.; 34 state financial regulators took part per ICBA.

Practical hurdles

• Operators that were unlicensed on 2026-07-01 had a 60-day window to file a money transmitter application; a denial means shutting kiosks down.
• Kiosks put into service on or after 2026-07-01 must print paper receipts, so older hardware moved to new sites may need printers.
• A full-time consumer protection officer (max 20% owner) is a fixed staffing cost even for small operators.

What we couldn't confirm

• Exact governor signature date of HB 2591 (bill page says Signed by Governor; Orrick says enacted April 9 without saying signed); exact HB 2515 veto date.
• K.S.A. section numbers assigned to the new kiosk sections (not yet shown in the OSBC copy).
• Kansas money transmitter surety bond and net worth amounts (not checked).
• That the Coinme settlement headline on the OSBC site refers to the same 34-state Coinme settlement reported by ICBA (OSBC headline only; body not read).