Pennsylvania — Bitcoin and virtual-currency law

• Jurisdiction: Commonwealth of Pennsylvania (US)
• Date checked: 2026-10-09 (all statuses below were checked on this date unless another date is given)
• Regulator: Pennsylvania Department of Banking and Securities (DoBS); Secretary Wendy Spicher (quoted 2025)
• Governor: Josh Shapiro (signed Act 7 of 2025)
• Legislature: 2025–2026 session (full-time); bills die on 2026-11-30.
• Saved primary sources: sources/states/pa/ (see sources/states/pa/INDEX.md)

At a glance

1. Money-transmitter licensing of virtual currency

• Act 7 of 2025 (Senate Bill 202), signed by Gov. Shapiro 2025-06-27, amends the Money Transmission Business Licensing Law (Act of 1965-09-02, P.L. 490, No. 249), now titled the "Money Transmission and Virtual Currency Transmission Business Licensing Law." New § 2(a)(2): no person shall "Engage in the business of transmitting virtual currency by means of a transmittal instrument for a fee or other consideration with or on behalf of an individual without first having obtained a license from the department." Effective 2025-08-26. [S1][S2][S3]
• DoBS letter (dated 2025-08-12, saved): the earlier Virtual Currency Statement of Policy (VCSOP), published 2024-04-20 and effective 2024-10-15, said "the Department interprets the definition of 'money' to include virtual currency, such as Bitcoin"; anyone transmitting virtual currency had to apply for a licence or stop by 2024-10-15; there is no grace period under Act 7; the VCSOP is rescinded when Act 7 takes effect. DoBS "does not provide licensing determinations." Applications go through NMLS. [S1]
• DoBS press release (2025-06-28): Secretary Wendy Spicher — "Before this law, if a company transmitted money for a fee, they had to be licensed by us — but if they transmitted virtual currency like Bitcoin, they didn't. That gap left consumers unprotected." DoBS called Pennsylvania the 27th state to regulate virtual currency under its money-transmitter act (DoBS's count). [S2]
• Before 2024: a 2019 DoBS guidance that virtual currency was not "money" under the MTA is reported by law-firm commentary (JD Supra headline "PA Department of Banking and Securities: Virtual Currency is not 'Money'") — not read directly (unverified). [N2]
• CSBS: Pennsylvania is not listed as an MTMA state. [S4]

2. Virtual-currency-specific statutes

3. Crypto ATM / kiosk law

• No Pennsylvania kiosk statute. Since 2025-08-26 kiosk operators transmitting virtual currency for a fee need a DoBS licence under Act 7 (by its terms). [S1]
• SB 1015 (2025–26) "providing for regulation and reporting requirements for qualifying virtual currency kiosk operators and for money transmitter license; and imposing duties on the Department of Banking and Securities" (memo subject "Consumer Protections for Virtual Currency Kiosks") — referred to Senate Communications & Technology 2025-09-17; no further action. [S5]
• September 2026 opinion pieces (PennLive, Reading Eagle) call kiosks "a scam pipeline for Pennsylvania seniors" and urge the legislature to act. [N4]

4. Tax treatment

• Pennsylvania's personal income tax taxes eight classes of income, including net gains from the disposition of property; crypto gains would fall there (general knowledge; no DoR crypto publication found — gap). Pennsylvania's sales tax treatment of crypto purchases was not checked (gap).

5. Notable enforcement

• No Pennsylvania DoBS crypto enforcement action was located in this check (gap). Pennsylvania is a participating state (Appendix A); its share of the $2.2M administrative penalty is $10,000.00 (Appendix B) Coinme consent order, App. A–B (completeness check, 2026-10-09).

6. Pending bills (2025–2026 session; die 2026-11-30)

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

• Policy reversal. Pennsylvania went from "virtual currency is not money" (2019, reported) to "it is money" (2024 policy) to an express statute (2025). Industry commentators criticized regulating by policy statement before the statute; DoBS framed it as closing a consumer gap. [S1][S2][N1][N2] Interpretive history.
• "27th state." DoBS's count of states regulating virtual currency under money-transmitter law is a regulator's claim and depends on definitions. [S2]
• Kiosk "scam pipeline." Opinion-page framing; industry disputes that kiosks are mainly used for scams (no industry source read). [N4]

Sources

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

• [S1] PA Department of Banking and Securities, "Pennsylvania Money Transmitter Act Amendments" (Act 7 letter, dated 2025-08-12). https://www.pa.gov/content/dam/copapwp-pagov/en/dobs/documents/non-bank-licensees/forms/non-bank%20licensee%20act%207%20letter%20081225.pdf — retrieved 2026-10-09 — saved pa-dobs-act-7-of-2025-money-transmitter-amendments-letter-2025-08-12.pdf
• [S2] PA DoBS press release, 2025-06-28, "Department of Banking and Securities to Begin Regulating Virtual Currency Transmitters Thanks to New Bipartisan Law." https://www.pa.gov/agencies/dobs/newsroom/dobs-regulating-virtual-currency-transmitters-thanks-to-new-bipa — saved pa-dobs-press-release-2025-06-28-act-7-virtual-currency.html
• [S3] PA General Assembly, law information page, Act 7 of 2025 (SB 202). https://www.palegis.us/statutes/unconsolidated/law-information?sessYr=2025&sessInd=0&actNum=7 — saved pa-act-7-of-2025-sb202-law-information.html
• [S4] 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
• [S5] PA General Assembly bill pages (2025–26): SB 1015, HB 881, HB 883, HB 1210. https://www.palegis.us/legislation/bills/2025/sb1015 (and /hb881, /hb883, /hb1210) — read 2026-10-09
• [S6] NCSL, 2024–2026 cryptocurrency legislation pages. https://www.ncsl.org/financial-services/cryptocurrency-digital-or-virtual-currency-and-digital-assets-2026-legislation — read 2026-10-09
• [N1] Consumer Finance Monitor (Ballard Spahr), "PA Department Of Banking And Securities: virtual currency is 'money'," 2024-05-13 (headline only). https://www.consumerfinancemonitor.com/2024/05/13/pa-department-of-banking-and-securities-virtual-currency-is-money
• [N2] JD Supra, "PA Department of Banking and Securities: Virtual Currency is not 'Money'…" (headline only; 2019 guidance). https://www.jdsupra.com/legalnews/pa-department-of-banking-and-securities-68645
• [N3] CryptoSlate, "Pennsylvania Bitcoin Strategic Reserve Act | HB 2664" (headline only). https://cryptoslate.com/crypto-laws/pennsylvania-bitcoin-strategic-reserve-act ; Cointelegraph, "Pennsylvania lawmaker introduces bill for 'strategic Bitcoin reserve'" (headline only). https://cointelegraph.com/news/pennsylvania-house-bill-strategic-bitcoin-reserve
• [N4] PennLive opinion, "Crypto kiosks have become a scam pipeline for Pennsylvania seniors," September 2026 (headline only). https://www.pennlive.com/opinion/2026/09/crypto-kiosks-have-become-a-scam-pipeline-for-pennsylvania-seniors-opinion.html ; Reading Eagle opinion, 2026-09-17 (headline only)