Kansas Bitcoin ATM Regulations

Review and sources

Summary reviewed: 2026-09-10. Official source. This is a dated summary; later amendments may change these requirements.

Licensing requirements

Kansas HB 2591 (2025-26 session) enacted the Virtual Currency Kiosk Consumer Protection Act as new sections 6 through 11 of the bill, supplemental to the Kansas Money Transmission Act (K.S.A. 2025 Supp. 9-555 through 9-596). The conference committee report was adopted March 26, 2026, and the Governor approved the bill April 9, 2026. Each kiosk section states that it takes effect on and after July 1, 2026.

Section 9(g) deems any person who owns, operates, solicits, markets, advertises, or facilitates virtual currency kiosks in Kansas to be engaged in money transmission and requires licensure under K.S.A. 2025 Supp. 9-564. Unlicensed operators had to apply for a money transmitter license within 60 days after July 1, 2026. Operators that applied in time may keep operating while the commissioner reviews a complete application; an operator whose application is denied must cease operations until licensed.

Section 7 defines a virtual currency kiosk as an electronic terminal owned, rented, or leased by an operator that facilitates exchanging money for virtual currency, or virtual currency for money or other virtual currency, with a person in Kansas, whether by connecting to a separate exchange or by drawing on the operator's own virtual currency. A virtual currency kiosk operator is a person who owns, rents, or leases a kiosk and transacts at a physical location in the state. An initial virtual currency transaction is the first transaction the operator facilitates with a person in Kansas.

Section 9(f) requires operators to report every kiosk location to the commissioner within 45 days after the end of each calendar quarter, including legal and trade names, physical address, date first placed in service, operating hours, and start and end dates at each location.

Transaction limits

Section 11(c) sets transaction and daily limits for each person in Kansas:

• Initial transaction: up to $1,000.
• Within 14 days of the initial transaction: up to $1,000 per day, only one transaction within 72 hours of the initial transaction, and no more than $10,000 in total transactions during the first 14 days.
• More than 14 days after the initial transaction: up to $10,500 per day.

Holding period. Under section 11(a), the operator must retain, hold, and safekeep any money or virtual currency from a transaction with a person in Kansas for 72 hours if the transaction occurs within 14 days of that person's initial transaction. Section 11(b) requires the transaction to be completed at the rates agreed when the customer initiated it, unless the operator is legally required or judicially ordered to safekeep the funds because of criminal activity, or receives a refund request under the act.

Fees

Section 10(a) prohibits an operator from collecting direct or indirect charges on a virtual currency transaction with a person in Kansas that exceed the greater of $5 or 18% of the full money transmission amount.

Section 10(b) treats any spread between the market price and the price offered to the customer as an indirect charge, so the spread counts toward the cap. Section 10(c) requires the operator to retain documentation of the relevant market price at the time of each transaction.

Refunds

Section 11(d) through (f) creates three refund paths.

• Initial transaction, any reason: any person in Kansas may request a full refund of the initial transaction within the 72-hour holding period. The operator must issue it unless safekeeping the funds is required by law or court order because of criminal activity (section 11(d)(1)).
• Fraud within the first 14 days: for the initial transaction or any transaction within 14 days of it, the operator must refund the full money transmission amount plus all fees, including any spread fee, when requested by the customer, the commissioner, the attorney general, or any law enforcement agency. The customer must have reported the fraudulent transmission to the commissioner, the attorney general, or law enforcement within 30 calendar days after the last fraudulent transmission and must give the operator a police report or sworn declaration describing the fraud (section 11(e)).
• Existing customers: a customer past the 14-day window who meets the same 30-day reporting and police-report or sworn-declaration conditions may recover only the direct and indirect charges, including spread and transaction fees (section 11(d)(2)).

Section 11(f) requires any refund to be paid by cash payout, automated clearing house transfer, or mailed paper check within 10 business days after the request. An operator with reasonable suspicion that someone acting for the customer is committing fraud may delay the refund for cause, but only if it immediately reports the suspicion to the commissioner, attorney general, or law enforcement and waits for that agency to conclude its investigation.

Section 8(h) states that the required scam warnings and disclosures do not affect a fraud victim's eligibility for a refund.

Disclosures

Section 8 layers several disclosure duties on kiosk operators:

• Material risk disclosures before the initial transaction, in clear, conspicuous, legible English, covering at least ten enumerated risks, including that virtual currency is not legal tender or government-insured, that transactions may be irreversible, and that any bond or trust account may not cover all customer losses (section 8(a)).
• Terms and conditions when opening an account, including the customer's liability for unauthorized transactions, when information will be shared with third parties, and the right to receipts, statements, and notice of policy changes (section 8(b)).
• Scam warning on every transaction, displayed on screen in at least 12-point or the largest available font, acknowledged by tapping the screen, and also sent by email. The statutory text lists eight common scam patterns, including impersonation of family members, financial institutions, and law enforcement, and ends with an instruction to contact local law enforcement (section 8(c)). If the operator agrees to conduct the transaction in Spanish, all disclosures and the warning must also be provided in Spanish (section 8(f)).
• Receipt after every transaction showing the operator's name and complaint telephone number, transaction type, value, date and precise local time, the fee, the exchange rate, any decrease from market rate expressed in dollars and labeled a "spread fee," the operator's liability for non-delivery, its refund policy, and the complete destination wallet address (section 8(d)). Kiosks first placed in service in Kansas on or after July 1, 2026 must issue paper receipts; kiosks in service before that date may issue paper or digital receipts, and digital receipts require a clicked acknowledgment that the customer supplied an email address (section 8(e)).

Operators must retain evidence of these disclosures for three years in addition to the record-retention rules in K.S.A. 2025 Supp. 9-578 (section 8(g)).

Customer identification

Section 9(h) requires the operator or its authorized delegate to verify each user's identity before accepting payment. The operator must obtain a copy of a government-issued identification card and collect the user's name, date of birth, telephone number, address, and email address. No user may transact under any name, account, or identity other than their own. The statute makes operators strictly liable for violations of section 9.

Fraud Prevention

Section 9 sets operational anti-fraud requirements:

• Blockchain analytics must be used to help prevent sending purchased virtual currency to wallets known to be affiliated with fraud. The commissioner may request evidence of current and historical use. An operator is held harmless for refusing a transaction based on knowledge or credible suspicion that the destination wallet is tied to fraud (section 9(a)).
• Live customer service during kiosk operating hours through a toll-free number displayed on the kiosk or its screens and staffed by trained people who assist callers in real time (section 9(b)).
• Written anti-fraud policy identifying fraud risk areas, controls, responsibility for monitoring, and periodic review (section 9(c)).
• Enhanced due diligence policy, approved by the board or equivalent body, that at a minimum identifies individuals at risk of fraud because of age or mental capacity (section 9(d)).
• Consumer protection officer employed full time, not an owner of more than 20% of the operator, with a direct telephone number outside any call routing system and an email address for law enforcement and regulator contact (section 9(e)).

Enforcement

Section 12 authorizes the attorney general's office and any law enforcement agency to investigate fraudulent money transmissions reported by a person in Kansas, and requires money transmitters to cooperate to the extent state and federal law permit. Those agencies must periodically report fraud and violations of the act to the state bank commissioner, who may consider that history when deciding whether to revoke or refuse to renew a license, and who must share reported fraud with the attorney general and relevant law enforcement.

First reported use. On September 9, 2026, the Sedgwick County District Attorney's Office announced that its Consumer Protection Division had used HB 2591 to recover money for a Wichita-area resident who paid a kiosk after an outstanding-warrant scam call. According to the release, the operator initially offered a refund only in cryptocurrency, which was of little use to the victim. After the Consumer Protection Division sent the operator a copy of the complaint under the new law, the operator agreed to refund by check. The release did not name the operator or the amount. Read the district attorney's release.

Federal requirements

Federal rules apply alongside the Kansas kiosk act.

• Register with FinCEN as a money services business when required by federal law.
• Maintain a written anti-money-laundering program, designate a compliance officer, and train kiosk support staff.
• Use customer identification, sanctions screening, and scam-escalation procedures sized to transaction risk.
• File Suspicious Activity Reports and Currency Transaction Reports when thresholds or facts require them.

Consumer protection

The Kansas Office of the State Bank Commissioner licenses kiosk operators and receives quarterly location reports and fraud referrals under the act. Consumers can start with Kansas Office of the State Bank Commissioner or call (785) 380-3939.

• Report a suspected scam to local police, the attorney general, or the commissioner within 30 calendar days of the last transaction; the refund provisions in section 11 depend on that report.
• Ask the operator for a refund in writing and provide the police report or a sworn declaration. Refunds must be paid in cash, by ACH, or by mailed check within 10 business days, not in cryptocurrency.
• Keep the receipt. It must show the fee, any spread fee, the operator's complaint telephone number, and the full destination wallet address.
• Legitimate government agencies, courts, and law enforcement do not collect fines, bail, or warrant payments through a cryptocurrency ATM.
• Confirm the operator holds a Kansas money transmitter license through NMLS Consumer Access before transacting.

Sources and legislation

Primary state framework: Virtual Currency Kiosk Consumer Protection Act, enacted as new sections 6 through 11 of HB 2591 (2025-26 session), with investigative authority in section 12. The act is part of and supplemental to the Kansas Money Transmission Act (K.S.A. 2025 Supp. 9-555 et seq.).

Primary regulator: Kansas Office of the State Bank Commissioner.

Timeline: conference committee report adopted March 26, 2026; approved by the Governor April 9, 2026; kiosk sections effective on and after July 1, 2026. The bill as a whole took effect on publication in the Kansas Register (section 23).

Sources: HB 2591 bill record and enrolled bill (PDF). Section numbers above refer to the enrolled bill; statutory section numbers will be assigned when the act is codified in K.S.A.

This summary covers selected kiosk provisions. Licensing, disclosures, identification, and refund conditions must be read in the full law.