Vermont — Bitcoin and virtual-currency law

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Legislation

2026-10-09

Document text

Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

Vermont — Bitcoin and virtual-currency law

  • Jurisdiction: State of Vermont (US)
  • Date checked: 2026-10-09 (all statuses below were checked on this date unless another date is given)
  • Regulator: Department of Financial Regulation (DFR), Banking Division
  • Legislature: 2025–2026 biennium; 2026 session adjourned; new biennium January 2027.
  • Saved primary sources: sources/states/vt/ (see sources/states/vt/INDEX.md)

At a glance

Topic Vermont position Key cite Status (checked 2026-10-09)
Money-transmitter licence for virtual currency Yes. Vermont's money-services law has a dedicated virtual-currency subchapter (Subchapter 10, §§ 2571 et seq.) — one of the few states to adopt the MTMA's virtual-currency title 8 V.S.A. ch. 79 (Money Services), as rewritten by 2023 Act No. 110 (H 659, Adj. Sess. 2024) Effective 2024-07-01 [S1][S3][S4]
Model law Full MTMA, "Money Services Act," Vt. Stat. tit. 8 §§ 2500 et seq.; CSBS: "Yes (virtual currency incorporated)" CSBS [S3][S4]
Crypto ATMs / kiosks Strict. Kiosks must be registered; $2,000/day new, $5,000/day existing customers; fees capped at the greater of $5 or 15%; photo of the customer at each transaction and ID with strict liability; mandatory live phone screening for new customers over 60 and anyone exceeding $5,000 in 10 days; full refund (new customers) or fee refund (existing) for fraud reported within 90 days; moratorium on new kiosks until 2026-07-01 (kiosks licensed and operating by 2024-06-30 exempt) 8 V.S.A. §§ 2507, 2577 (2023 Act 110; amended 2025 Act No. 23 / H 137) In force; moratorium expired 2026-07-01 [S1][S5]
Blockchain business entities Blockchain-based LLC (BBLLC) 11 V.S.A. §§ 4171–4176 (2018 Act 205) In force [S2]
Blockchain evidence Blockchain records admissible (12 V.S.A. § 1913) 2016 law (year from general knowledge) In force [S1][S2]
Tax No Vermont crypto tax guidance found (gap) — —

1. Money-transmitter licensing of virtual currency

8 V.S.A. chapter 79 — Money Services (full chapter saved). Rewritten as the Money Transmission Modernization Act by 2023 Act No. 110 (Adj. Sess.) — H 659 — effective 2024-07-01. [S1][S4]

  • "Virtual currency" (§ 2503 / § 2571): a digital representation of value that is used as a medium of exchange, unit of account or store of value and "is not money, whether or not denominated in money"; excludes merchant rewards and similar closed-loop units. [S1]
  • Subchapter 10 "Virtual Currency" (from § 2571): defines blockchain (by reference to 12 V.S.A. § 1913), blockchain analytics, digital wallet, "exchange," "virtual-currency kiosk operator," "virtual-currency storage" (holding custody for others, incl. as a control-services vendor), etc.; licensed "virtual-currency business activity" includes exchanging, transferring and storing virtual currency for others. [S1]
  • CSBS: full MTMA, effective 2024-07-01, "Yes (virtual currency incorporated)." [S3][S4]

2. Virtual-currency-specific statutes

Law What it does Status Source
12 V.S.A. § 1913 Blockchain records — evidence/authentication; definition of "blockchain technology" In force (enacted 2016 — year unverified) [S1][S2]
2018 Act No. 205 (Adj. Sess.) (S 269) Blockchain-based limited liability companies: an LLC that uses blockchain for a material part of its business may elect BBLLC status and govern itself through blockchain (11 V.S.A. §§ 4171–4176) In force [S2]
2023 Act No. 110 (Adj. Sess.) (H 659) MTMA with virtual-currency subchapter; kiosk rules Effective 2024-07-01 [S1][S4]
2025 Act No. 23 (H 137) Insurance/DFR omnibus incl. virtual-currency kiosk amendments to § 2577 Governor approved 2025-05-19; § 2577 amendment effective 2025-07-01 [S1][S6]
2026 Act No. 142 (H 648) Banking, insurance and securities omnibus Governor approved 2026-06-16; crypto content not checked (gap) [S7]

3. Crypto ATM / kiosk law

8 V.S.A. § 2507 (kiosk registration) and § 2577 "Virtual-currency kiosk operators" (added by 2023 Act 110; amended by 2025 Act 23, effective 2025-07-01). [S1]

  • Registration: a licensee may not place, or allow a third party to place, a money-transmission kiosk in Vermont unless it is registered (§ 2507).
  • Daily limits (§ 2577(a)): no more than $2,000 of cash per day with a single new customer and $5,000 per day with an existing customer, across the operator's kiosks.
  • Fee cap (§ 2577(b)): all fees plus spread may not exceed the greater of $5.00 or 15% of the dollar value; a series of related transactions counts as one.
  • Operator accountability (§ 2577(e)): an operator that lets another firm use its kiosks must ensure that firm is licensed and within the fee cap.
  • Moratorium (§ 2577(f)): "virtual-currency kiosks shall not be permitted to operate in Vermont prior to July 1, 2026," except kiosks licensed and operating on or before 2024-06-30. (This date has now passed.)
  • Customer identification (§ 2577(g)): government ID, name, date of birth, phone, address and email before accepting payment; a photograph of the customer at the kiosk for each transaction; operator strictly liable for violations.
  • Customer support (§ 2577(h)) — live toll-free support while kiosks operate.
  • Mandatory live screening (§ 2577(i)): the operator must speak by phone with (A) any new customer over 60 before the first transaction, and (B) any customer trying to do more than $5,000 in 10 days; approval depends on that conversation; calls are recorded.
  • Blockchain analytics (§ 2577(j)) through an established third-party analytics firm.
  • Refunds (§ 2577(k)–(l)): full refund including fees for a fraudulently induced new customer, and fee refund for an existing customer, if the customer tells the operator and a law-enforcement or government agency within 90 days.
  • Fraud prevention (§ 2577(m)): written anti-fraud policy, including controls preventing more than one customer from using the same wallet. [S1]
  • S 129 (2025–26) (Sen. Ann Cummings), further kiosk regulation — referred to Senate Finance 2025-03-20; no further action. H 370 (Rep. William Greer), "cryptocurrency and protecting the public welfare" — referred to House Commerce 2025-02-26; no further action. Both die with the biennium. [S8]

4. Tax treatment

  • Vermont income tax starts from federal taxable income (general knowledge; unverified); no Vermont Department of Taxes crypto guidance was found (gap).

5. Notable enforcement

  • No Vermont DFR crypto enforcement action was located in this check (gap).

6. Pending and recently failed bills

Bill Subject Status (checked 2026-10-09) Source
S 129 Regulation of virtual-currency kiosk operators In Senate Finance since 2025-03-20 — dies with biennium [S8]
H 370 Cryptocurrency and the public welfare In House Commerce since 2025-02-26 — dies [S8]
H 206 (2025) UCC revisions (hybrid transactions, electronic records) Enacted 2025 (NCSL) [S9]

7. Contested and fringe claims (flagged, not endorsed)

  • Vermont's kiosk rules are among the strictest short of a ban (moratorium, photos, phone screening of seniors). Privacy advocates could object to photographing every customer; industry argues the moratorium and screening make kiosks uneconomic; consumer advocates (AARP) supported such measures (positions as generally reported — no source read for Vermont specifically; unverified).
  • Age-based screening (over-60 phone call) is a deliberate age distinction; whether it raises age-discrimination concerns has not been tested in court (analysis; unverified).

Sources

Saved full copies are in sources/states/vt/.

  • [S1] Vermont General Assembly, 8 V.S.A. chapter 79 (Money Services), full text. https://legislature.vermont.gov/statutes/fullchapter/08/079 — retrieved 2026-10-09 — saved vt-8-vsa-ch-79-money-services.html
  • [S2] Vermont General Assembly, 11 V.S.A. chapter 25 (Limited Liability Companies), incl. Subchapter 12, Blockchain-Based LLCs (§§ 4171–4176). https://legislature.vermont.gov/statutes/fullchapter/11/025 — saved vt-11-vsa-ch-25-llc-incl-blockchain-based-llc.html
  • [S3] CSBS, MTMA State Enactments (PDF dated 2026-10-08). https://www.csbs.org/sites/default/files/external-link-files/10.8.26%20MTMA%20State%20Enactments.pdf
  • [S4] CSBS, MTMA legislative update (August 2026) — "Vermont (H.B. 659) Full MTMA introduction. (Effective July 1, 2024)." https://www.csbs.org/mtma-legislative-update-august-2026
  • [S5] § 2577 history note in [S1]: "Added 2023, No. 110 (Adj. Sess.), § 48, eff. July 1, 2024; amended 2025, No. 23, § 24, eff. July 1, 2025."
  • [S6] Vermont General Assembly, H.137 (2025) bill status — "Governor approved bill on May 19, 2025." https://legislature.vermont.gov/bill/status/2026/H.137 — read 2026-10-09
  • [S7] Vermont General Assembly, H.648 (Act 142) bill status — "Governor approved bill on June 16, 2026." https://legislature.vermont.gov/bill/status/2026/H.648 — read 2026-10-09
  • [S8] Vermont General Assembly, S.129 and H.370 bill status pages. https://legislature.vermont.gov/bill/status/2026/S.129 ; https://legislature.vermont.gov/bill/status/2026/H.370 — read 2026-10-09
  • [S9] NCSL, 2025 cryptocurrency legislation page. https://www.ncsl.org/financial-services/cryptocurrency-digital-or-virtual-currency-and-digital-assets-2025-legislation