Dollar credit is no longer for exporters only

Since 2002, foreign-currency deposits in the Argentine financial system could only be lent to borrowers with income linked to foreign trade: that was the rule that kept any company billing in pesos out of dollar credit. DNU 736/2026 replaces article 23 of Decreto 905/2002 and adds, verbatim, «as well as the granting of financing to other legal entities, in accordance with the regulations issued to that effect by the CENTRAL BANK OF THE ARGENTINE REPUBLIC». The requirement that falls away is having export income; what comes in is being a legal entity and complying with the Central Bank's regulation. And here is what most coverage skips: the decree sets NO parameters. The 15% cap on foreign-currency deposits per institution, the 125% minimum-capital requirement and the 1.25× weighting in concentration limits that circulate in the press are NOT in its text — the recitals expressly delegate to the BCRA the «eligibility criteria for borrowers, segmentation of limits, liquidity requirements and differentiated provisions». That fine print came out on Aug 18, 2026 in Communication «A» 8467: a cap of 15% of each bank's dollar deposits, special attention to the borrower's currency risk and 25% more capital required. verif · Aug 14, 2026 ↗

August 14, 2026: the decree itself provides that it takes effect «from the day of its publication in the OFFICIAL GAZETTE». The operating instrument came out four days later: the Central Bank's Communication «A» 8467, of Aug 18, 2026, adds to the credit policy the purpose «financing to other legal entities that do not fall under the preceding points», with a cap of 15% of each bank's foreign-currency deposits. It asks for special attention to the borrower's cash flow, «bearing in mind that its income may not follow the evolution of the exchange rate», and multiplies by 1.25 the capital requirement for that financing, a factor that also counts toward the large-exposures limit. The communication does not name DNU 736. verif · Aug 18, 2026 ↗

Directly: the banks, which can now lend a pool of dollar deposits that previously could only go to the export chain, and companies — any legal entity — that were kept out of foreign-currency credit for not billing exports. Within the ecosystem we track, the natural candidate is the supplier to a RIGI project that buys imported equipment and gets paid in pesos: currency mismatch is its structural problem, and a dollar facility flips its sign. With two caveats that must be stated together: (1) the decree does not mention the RIGI, nor Ley 27.742, nor any province or sector — verified by reading the text, so any sectoral landing is our reading and not the act's; (2) dollar credit to someone billing in pesos transfers currency risk to the borrower, and that risk is exactly what the 2002 rule was designed to avoid. prob · Aug 14, 2026 ↗