An exchange in São Paulo settles BRL 20 million a month in Pix deposits through a partner bank, and its board has not yet decided whether to file with the Central Bank of Brazil (BCB). With Brazil’s VASP authorization deadline on October 30, 2026, the question is what happens the day after.
Firms that already operated must file by October 30, 2026: those that file keep operating until the BCB decides, and those that don’t have 30 days to wind down. And under BCB Resolution No. 589, of September 23, 2026, banks and payment institutions may only work with authorized providers from November 6, 2026, which weighs on firms still waiting for a decision.
What is the VASP authorization deadline and where does it come from?
The deadline comes from the framework the BCB built on Law No. 14,478, of December 21, 2022. The law gave the Central Bank the mandate to authorize and supervise virtual asset service providers, known as PSAVs, the Brazilian term for VASPs.
For the full rulebook beyond the deadline, Transfero’s overview of VASP regulation in Brazil covers licensing, governance and compliance requirements.
BCB Resolutions 519, 520 and 521
The BCB issued three rules on November 10, 2025, published in the Official Gazette the next day. BCB Resolution No. 519 sets the authorization process, and BCB Resolution No. 520 governs how providers are incorporated and operate.
BCB Resolution No. 521 brings virtual assets into the foreign exchange and international capital rules. The deadline itself sits in Resolution 520.
Effective February 2, 2026, with a 270-day count
All three resolutions took effect on February 2, 2026. Article 88 of Resolution 520 gave firms already operating 270 days from that date to file, which lands on October 30, 2026.
Capital follows a separate calendar. Joint Resolution No. 14, of November 3, 2025, raises minimum capital in stages through December 31, 2027.
Who needs to file for authorization by October 30, 2026?
Any company that already provided virtual asset services in Brazil when the rules took effect and wants to keep doing so. Resolution 520 groups that activity into three types in article 4, paragraph 1, and one firm may fall into more than one.
Intermediaries
Intermediaries execute buy, sell and swap operations in virtual assets on behalf of clients. Platforms that route orders or offer conversion inside an app usually start here.
Custodians
Custodians hold and safeguard virtual assets for clients, including control of the private keys. Wallet providers and firms that keep client balances fall into this group.
Virtual asset brokers
Brokers combine intermediation and custody in one entity. This is the closest profile to a full-service exchange, and the one most exposed to the November 6 counterparty rule.
What happens from October 31, 2026 to firms that did not file?
A firm that operated without filing enters the 30-day wind-down period set by article 88. It cannot request authorization under the transition rule anymore, and its regulated activity must end within that window.
Restrictions on banks and authorized institutions
BCB Resolution No. 589, in force since October 1, 2026, rewrote article 91 of Resolution 520. From November 6, 2026, financial and payment institutions are barred from operating with virtual asset providers that are not authorized.
The previous wording also accepted providers “in the process of authorization.” That phrase is gone.
Effect on clients and counterparties
For a firm that did not file, the banking side closes before the wind-down ends. Settlement accounts and Pix rails supplied by banks and payment institutions must stop serving it from November 6.
Clients and partners therefore have a short window to withdraw balances and migrate. The 30-day period becomes an exit plan, not a grace period.
Does filing by October 30 guarantee continued access to banks and PSPs?
No. Filing keeps the operation legal until the BCB decides, under article 88, but the counterparty rule in article 91 accepts only authorized providers from November 6. A firm with a pending application can keep operating under Resolution 520 and still lose its banking partners.
Take the exchange from the opening, which receives BRL 20 million a month in Pix deposits. If it files by October 30, it may continue serving clients while the BCB reviews the application.
From November 6, the bank that settles those deposits can only serve it once it is authorized. Until then, the BRL 20 million monthly flow needs another settlement route. Resolution 520 sets no deadline for the review, so the length of that gap cannot be predicted.
Weighing your own authorization against using licensed infrastructure? Talk to our team.
What are the three options for firms that have not decided?
Each path has a different cost, timeline and level of control. The table compares them on the points that matter before October 30.
Criterion | Own authorization | Authorized partner | Discontinue
|
|---|---|---|---|
Action by October 30 | File the application | Sign with an authorized provider | Approve a wind-down plan |
Banking access from November 6 | Only after authorization | Through the partner’s status | Not applicable |
Capital | Rising in stages through December 31, 2027 | Held by the partner | None |
Control of the regulated activity | Full | Shared under contract | Ends |
1. File for your own authorization
The firm keeps full control of products, pricing and client relationships. It needs a Brazilian entity, governance and controls in line with Resolution 520, and a capital plan that follows Joint Resolution 14.
Filing by October 30 keeps the operation running. The firm still has to cover its BRL settlement between November 6 and the BCB decision.
2. Operate through an authorized partner
An authorized institution carries the regulated activity, and the firm offers services to its clients on top of that infrastructure. Banking counterparties deal with the authorized provider, so the November 6 rule does not cut the flow.
Due diligence centers on three points: the partner’s authorization status, ownership of the client relationship and how KYC and AML data are shared. Transfero’s analysis of whether exchanges should get a license or use a partner goes deeper into that trade-off.
3. Discontinue the regulated activity
Some firms will conclude that the Brazilian market does not justify the cost of compliance. In that case, the 30 days after October 30 are for client communication and the return of assets.
Ending the activity in an orderly way protects the brand and the relationships the firm may want to reuse later.
How do you decide in four weeks?
Start with dependency on BRL rails. If Pix deposits and withdrawals carry most of the revenue, any gap after November 6 hits the business directly.
Then check readiness. A firm without a Brazilian entity, a capital plan and a near-final application has little chance of filing a solid request by October 30.
Finally, test the scenarios with legal counsel. Some structures combine paths, such as filing an own application while serving clients through an authorized provider during the review.
How does Transfero support firms that choose licensed infrastructure?
Transfero’s Crypto as a Service (CaaS) gives fintechs, neobanks, exchanges and wallets ramps, swaps, payments and custody through an API, within a regulated framework with built-in KYC and AML. The platform processed more than 9.8 million transactions in 2025.
BRL on-ramps and off-ramps through Pix, via the crypto infrastructure API
Custody powered by Fireblocks
Swaps and payments in the same integration
KYC and AML built into the flow
A global top-five exchange used this setup to run BRL on/off-ramp, BRZ and KYC in one integration. According to the published case, its trading volume grew 200%.
Transfero’s licenses page lists, among others, Transfero Instituição de Pagamento Ltda., authorized by the Central Bank of Brazil to operate as a payment institution, and Transfero Swiss AG, a VASP registered with VQF since 2021.
Questions to ask before October 30
Did your firm already provide virtual asset services in Brazil on February 2, 2026?
Which type, intermediary, custodian or broker, describes each service you offer?
Is your application ready to file by October 30, including the Brazilian entity and capital plan?
Which banks and payment institutions settle your BRL flows, and what happens to them on November 6?
If you choose a partner, is it authorized, and who owns the client relationship and KYC data?
If you wind down, can you return client assets within 30 days?
Offer crypto services in Brazil on Transfero’s licensed infrastructure. Talk to us.
Frequently asked questions
Can a firm file for authorization after October 30, 2026?
Not under the transition rule. Resolution 520 provides no filing window after October 30, 2026 for companies that were already operating. A company that misses the date has 30 days to wind down its regulated activity, which makes the remaining weeks the only chance to file and keep operating during the review.
Does a foreign company serving clients in Brazil need to file?
Yes, through a Brazilian entity. Article 1, sole paragraph, of Resolution 520 requires providers to be incorporated in Brazil. Article 23 gave foreign firms 270 days to transfer Brazilian clients to an authorized institution or a local SPSAV, so the choice is to incorporate and file or to move those clients.
Can the deadline be extended?
The filing deadline remains October 30, 2026. What changed with Resolution 589 is the counterparty date: from November 6, 2026, banks and payment institutions may only operate with authorized virtual asset providers. Firms should plan around both dates rather than expect a new calendar.
How long does the BCB take to review an application?
Resolution 520 does not set a deadline for the analysis. Firms that filed on time keep operating until the decision, but from November 6, 2026 their banking counterparties can only serve authorized providers. Plan settlement and payment routes without assuming a review date.
