A crypto exchange headquartered in Singapore serves 50,000 users in Brazil, who deposit BRL 30 million a month through Pix via a local payment partner. Its compliance team has read about Brazil’s new rules and needs a clear answer: does the exchange need a VASP license in Brazil to keep those users?
Yes. Under BCB Resolution 520, a virtual asset service provider must be incorporated in Brazil, with headquarters and management in the country, and foreign providers already serving Brazilians had 270 days to move those clients to an authorized institution. The alternatives are to set up and authorize a Brazilian entity or to serve the market through a provider that is already authorized.
Does a foreign exchange need authorization to serve users in Brazil?
It needs a Brazilian entity with authorization from the Central Bank of Brazil (BCB). Law No. 14,478, of December 21, 2022, gave the BCB the mandate to regulate virtual asset service providers, known locally as PSAVs, the Brazilian term for VASPs.
The BCB issued three rules on November 10, 2025, published in the Official Gazette the next day and in force since February 2, 2026. BCB Resolution No. 519 sets the authorization process, and BCB Resolution No. 521 brings virtual assets into the FX rules.
BCB Resolution No. 520 is the core rule for exchanges. Article 1, sole paragraph, requires the provider to be incorporated in Brazil, with headquarters and management in the country.
For a foreign exchange, this means the license cannot sit with the offshore entity. Article 23 gave foreign providers already serving Brazilians 270 days to transfer those operations and clients to an authorized institution, or to wind them down.
Transfero’s guides on what a VASP is and on VASP regulation in Brazil cover the wider framework.
What are the PSAV categories?
Article 4, paragraph 1, of Resolution 520 sets three types of provider. The category defines which services the Brazilian entity can offer.
Intermediary
An intermediary executes buy, sell and swap orders in virtual assets on behalf of clients. It fits platforms that route orders without keeping client assets.
Custodian
A custodian holds and safeguards virtual assets for clients, including control of the private keys.
Broker
A broker combines intermediation and custody in one entity. Most full-service exchanges, with an order book and client wallets, fall into this category.
What does authorization require?
Three building blocks come before the application. Each takes time, which matters for an exchange starting from outside Brazil.
A Brazilian entity
The provider must be a company incorporated in Brazil, with headquarters and management in the country. A branch or a local representative of the offshore exchange does not meet this requirement.
Minimum capital
Capital follows Joint Resolution No. 14, of November 3, 2025, which raises the minimum in stages through December 31, 2027. Exchanges should model their capital plan against each stage of that rule.
Governance and compliance
The Brazilian entity needs its own management, internal controls, risk management and anti-money laundering procedures in line with Resolution 520.
What changes after October 30, 2026?
October 30, 2026, is the end of the 270-day window counted from February 2, 2026. Under article 88, providers already operating in Brazil that file by then keep operating until the BCB decides; those that do not file have 30 days to wind down.
The second date is November 6, 2026. BCB Resolution No. 589, of September 23, 2026, in force since October 1, rewrote article 91 of Resolution 520.
From that date, financial and payment institutions are barred from operating with virtual asset providers that are not authorized. The previous text also accepted providers “in the process of authorization,” and that phrase was removed.
For a foreign exchange, the practical effect lands on the BRL rails. The Pix partner that receives the BRL 30 million a month from the example cannot keep serving an unauthorized provider after November 6.
Weighing your own authorization against using licensed infrastructure? Talk to our team.
License or authorized partner: which path fits a foreign exchange?
Back to the exchange with 50,000 Brazilian users and BRL 30 million a month in Pix deposits. It has two compliant paths, compared below.
Criterion | Own Brazilian entity and license | Clients moved to an authorized provider
|
|---|---|---|
Legal structure | New company in Brazil, local management | Contract with an authorized provider |
Capital | Joint Resolution 14, rising through December 31, 2027 | Held by the provider |
Time to operate | Setup, application and BCB review | Integration and client migration |
BRL rails from November 6 | Only once authorized | Through the provider |
Control of product and users | Full | Shared under contract |
The license path suits exchanges for which Brazil is a core market, with volume that justifies a local team and capital. The partner path suits exchanges that want to keep Brazilian users without building a regulated entity, or that need a bridge while their own application is prepared.
Transfero’s analysis of whether exchanges should get a license or use a partner goes deeper into the trade-off. Its guide on how an exchange operates in reais explains the BRL side.
How does Transfero support foreign exchanges in Brazil?
Transfero’s Crypto as a Service (CaaS) gives exchanges, fintechs, neobanks and wallets ramps, swaps, payments and custody through an API, as licensed infrastructure within a regulated framework with built-in KYC and AML.
BRL on-ramps and off-ramps through Pix, via Transfero’s crypto infrastructure
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%. The platform processed more than 9.8 million transactions in 2025.
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 answer before October 30
How many Brazilian users and how much BRL volume does your exchange serve today?
Which PSAV category matches each service you offer to Brazilians?
Do you have, or can you set up, a Brazilian entity with local management?
Is your capital plan aligned with the stages of Joint Resolution 14?
Which banks and payment institutions move your BRL, and what happens to them on November 6?
If you use a provider, is it authorized, and how will users be migrated?
Offer crypto services in Brazil on Transfero’s licensed infrastructure. Talk to us.
Frequently asked questions
Can a foreign exchange file without a Brazilian entity?
No. Article 1, sole paragraph, of Resolution 520 requires the provider to be incorporated in Brazil, with headquarters and management in the country. A foreign exchange first needs a Brazilian company that meets those conditions, and that company is the one that applies for authorization.
How long does authorization take?
Resolution 520 does not set a deadline for the BCB’s review, so there is no fixed timeline. The preparation itself, with a Brazilian entity, capital, governance and the application, also takes time. Exchanges should plan their BRL operations without assuming a decision date.
What happens to existing Brazilian users after the deadline?
Article 23 gave foreign providers 270 days to transfer Brazilian operations and clients to an authorized institution, or to wind them down. From November 6, 2026, banks and payment institutions can no longer serve unauthorized providers, so users of an exchange that did neither lose the BRL rails.
Can a partner handle BRL deposits and withdrawals?
Yes. A provider with the right structure in Brazil can run BRL deposits and withdrawals through Pix for the exchange’s users, within the FX and virtual asset rules. The exchange should confirm the provider’s regulatory status and how the integration, KYC and client relationship are split.
