After nearly three years of anticipation, Brazil's cryptocurrency market finally has a clearer regulatory framework. The new rules come at a time of strong industry growth. In 2025, Brazil recorded R$505.5 billion in crypto asset transactions, an all-time high and a 21.5% increase from the previous year, according to data from the Brazilian Federal Revenue Service.
To keep pace with this growth, Brazil's Central Bank published BCB Resolutions No. 519, 520, and 521 on November 10, 2025. The resolutions establish rules for providing virtual asset services in Brazil and introduce requirements for exchanges, custodians, and other institutions. Implementation is taking place gradually, with the first rules coming into effect in February 2026 and the transition period ending in October 2026.
In this article, we'll explain the main changes introduced by the new regulations, who will be affected, the compliance deadlines, and what companies need to consider to operate in accordance with the Central Bank's requirements.
Where Does Brazil's Digital Asset Regulation Come From?
The new regulatory framework aims to bring the virtual asset market closer to the standards already applied to financial institutions. Its goals include strengthening anti-money laundering measures, improving customer protection, increasing legal certainty for businesses and consumers, and reinforcing oversight by the Central Bank of Brazil.
The publication of BCB Resolutions No. 519, 520, and 521 is the result of a regulatory process that began several years earlier. The first major step was Law No. 14,478/2022, known as Brazil's Crypto Asset Legal Framework. The law designated the Central Bank as the regulator and supervisor of the virtual asset market in Brazil. It established the general guidelines while leaving the operational rules to be defined through additional regulations.
Between 2023 and 2024, the Central Bank conducted a series of public consultations (Public Consultation Notices No. 97, 109, 110, and 111) to discuss the rules with market participants. The feedback received contributed to the three resolutions published in November 2025, which now establish how virtual asset service providers must operate in Brazil.
How Does Brazil's New Regulatory Framework Work?
The three resolutions published by the Central Bank are complementary. Together, they regulate the authorization and operation of virtual asset service providers, as well as transactions subject to foreign exchange regulations.
BCB Resolution No. 519 — SPSAV Authorization
This resolution establishes the requirements for authorizing Virtual Asset Service Provider Companies (Sociedades Prestadoras de Serviços de Ativos Virtuais, or SPSAVs).
It sets requirements related to the company's structure, management, and other conditions that must be met to obtain authorization from the Central Bank.
BCB Resolution No. 520 — Operating Requirements
This resolution establishes the main operating requirements for SPSAVs, including rules covering corporate governance, internal controls, risk management, compliance, anti-money laundering, and asset segregation.
It is the primary regulation within the new regulatory framework.
BCB Resolution No. 521 — Foreign Exchange Transactions
This resolution updates Brazil's foreign exchange regulations to cover certain transactions involving virtual assets. It establishes which transactions are subject to foreign exchange rules and the limits applicable to each type of institution.
Who Needs to Comply?
The new rules apply to institutions that provide services involving virtual assets, including trading platforms, custodians, companies responsible for transferring virtual assets, fintechs that incorporate crypto into their products, and financial infrastructure providers.
The regulations also apply to foreign institutions that serve customers in Brazil. In other words, the determining factor is not where the organization is headquartered, but rather the market in which its services are offered.
Any organization providing virtual asset services to customers in Brazil should therefore assess whether its activities fall under the Central Bank's requirements.
Foreign Companies Will Need a Local Presence
To operate as a Virtual Asset Service Provider Company (SPSAV), foreign companies will need to maintain a substantive presence in Brazil. This includes establishing a legal entity in the country, having local management, and maintaining an organizational structure appropriate to the activities performed.
The requirement is intended to ensure that institutions operating in the Brazilian market are subject to Central Bank supervision and follow regulatory standards similar to those applicable to domestic financial institutions.
What Is an SPSAV?
The new regulatory framework establishes a new category of institution: the Virtual Asset Service Provider Company (SPSAV).
An SPSAV is an institution authorized by the Central Bank to provide virtual asset services on behalf of customers, such as buying, selling, exchanging, custody, and intermediation.
SPSAVs are classified into three categories:
Intermediary: facilitates the purchase, sale, and distribution of crypto assets;
Custodian: holds and manages customers' virtual assets;
Broker: combines intermediation and custody services.
In addition to SPSAVs, institutions already authorized by the Central Bank, such as banks, broker-dealers, and payment institutions, may also offer virtual asset services, provided they comply with the requirements established by the new regulations.
Key Changes Under Brazil's New Digital Asset Regulations
In addition to creating a new category of institution and establishing authorization requirements, the Central Bank's resolutions introduce new requirements related to governance, compliance, risk management, minimum capital, customer asset protection, and international transactions.
As a result, the virtual asset market is moving closer to the regulatory standards applied to traditional financial institutions.
Below are the main changes and what they mean for companies operating in this market.
Governance and Compliance
The new framework expands requirements related to corporate governance, internal controls, risk management, anti-money laundering (AML), customer identification (KYC), and ongoing transaction monitoring.
These requirements bring Brazil's regulatory framework closer to practices adopted in other markets and reinforce the professionalization of the industry. As a result, SPSAVs will be expected to operate with governance and compliance standards closer to those required of financial institutions than those typically found in technology companies.
Asset Segregation
Another important change is the requirement to separate customers' funds and virtual assets from the institution's own assets.
Funds held in Brazilian reais must remain in individual accounts in each customer's name, while virtual assets must be held in segregated wallets.
The measure is designed to reduce one of the key risks historically associated with the virtual asset market: the commingling of company and customer assets. Similar issues contributed to the insolvency of major international exchanges, including FTX.
With asset segregation, customer assets receive an additional layer of protection if a service provider experiences financial difficulties.
Minimum Capital Requirements
One of the most significant changes introduced by the new regulatory framework is the establishment of minimum share capital and net worth requirements for SPSAVs.
According to the Central Bank, the required amount varies according to the activities performed by the institution—intermediation, custody, or both—and ranges from R$10.8 million to R$37.2 million.
These requirements bring the prudential framework for virtual asset service providers closer to the standards applied to traditional financial institutions. For many companies, meeting these requirements may represent a significant investment to operate independently.
As a result, already licensed infrastructure providers are likely to become increasingly relevant. By centralizing regulatory requirements, they can allow other businesses to offer virtual asset services without having to build and operate an entire regulated infrastructure internally.
Transactions Subject to Foreign Exchange Rules
BCB Resolution No. 521 brings the crypto asset market closer to Brazil's foreign exchange framework by classifying certain transactions as foreign exchange transactions.
These transactions are therefore subject to controls similar to those applied to traditional foreign exchange operations. They include:
International payments made using virtual assets;
Settlement of expenses abroad, such as credit card bills, using crypto assets;
Transfers between self-hosted wallets, provided the service provider can identify the wallet owner and verify the source and destination of the funds;
The purchase, sale, or exchange of stablecoins pegged to fiat currencies.
The resolution also establishes transaction limits based on the type of institution.
Authorized banks can conduct these transactions without a value limit. For broker-dealers and securities distributors, the limit is US$500,000 per transaction. SPSAVs, meanwhile, are subject to a US$100,000 limit when the counterparty is not an institution authorized to operate in the foreign exchange market.
Brazil's Federal Revenue Service Expands Monitoring Through DeCripto
In addition to the changes introduced by the Central Bank, Brazil's Federal Revenue Service has also established new reporting requirements through the Crypto Asset Declaration (DeCripto) under Normative Instruction RFB No. 2,291/2025.
The framework follows the Crypto-Asset Reporting Framework (CARF), a standard developed by the OECD and already adopted by more than 60 jurisdictions.
The new rules took effect in January 2026. The requirement to submit information monthly, both by service providers and by users subject to the reporting rules, began in July 2026.
DeCripto does not change the current tax rules, including the exemption for monthly sales of up to R$35,000. The main change is the expansion of the information reported to the Federal Revenue Service, which now includes transactions between crypto assets, transfers between wallets, and transactions conducted through foreign exchanges serving customers in Brazil.
While the Central Bank determines who can provide virtual asset services and the requirements these institutions must meet, the Federal Revenue Service is increasing the transparency and traceability of transactions in this market.
When Do the New Rules Take Effect?
The three resolutions are being implemented in stages throughout 2026.
February 2, 2026: BCB Resolutions No. 519 and 520, along with most of Resolution No. 521, take effect.
May 4, 2026: The provisions of Resolution No. 521 covering special transactions, foreign capital, and monthly reporting to the Central Bank on foreign exchange and capital transactions involving virtual assets take effect.
October 30, 2026: Institutions authorized by the Central Bank will no longer be allowed to do business with companies providing virtual asset services in Brazil without authorization or a pending authorization application.
This final deadline marks the end of the transition period established by the regulator. From that date onward, companies that want to continue providing virtual asset services must either be properly authorized or operate through an already regulated structure.
Because the authorization process, corporate structuring, and implementation of the required controls can take months, waiting until the final deadline to begin the compliance process could put business continuity at risk.
To support this process, the Central Bank published BCB Normative Instruction No. 70 in February 2026, detailing the procedures, documentation, and deadlines for SPSAV authorization applications.
How Can Companies Prepare?
With the new rules now taking effect, companies operating with virtual assets need to review their processes and assess whether their operations are aligned with regulatory requirements.
Key areas to consider include:
Determine whether the company's activities require authorization from the Central Bank;
Decide whether the operation will be conducted through an in-house SPSAV or an already authorized partner;
Review the corporate structure, including the need for a local presence and management in Brazil;
Update compliance policies and processes, including anti-money laundering (AML) and customer identification (KYC) controls;
Strengthen corporate governance, internal controls, and risk management;
Assess whether the technology infrastructure meets asset segregation and regulatory reporting requirements;
Review partnerships with financial institutions and infrastructure providers to ensure compliance with the new requirements.
Starting this assessment early can reduce risks, simplify the compliance process, and prevent the company from having to implement critical changes as the transition period comes to an end.
What Happens to Companies That Don't Comply?
After the transition period, companies that fail to meet the Central Bank's requirements may be prohibited from providing certain virtual asset services in Brazil.
Starting October 30, 2026, authorized institutions will also be prohibited from maintaining relationships with companies that are not authorized—or do not have an authorization application in progress—to provide virtual asset services.
This could make it more difficult to access banking partners, payment providers, and other companies within the financial system, significantly limiting the company's ability to operate.
Regulated Infrastructure Becomes a Competitive Advantage
The new rules significantly raise the bar for companies looking to offer virtual asset services in Brazil.
Beyond regulatory compliance, operations now require infrastructure capable of integrating liquidity, segregated custody, fiat-to-virtual asset conversion, cross-border payments, stablecoin support, and transaction monitoring and reporting.
For many companies, building this infrastructure internally can require significant investments in time, capital, and specialized expertise. In this environment, regulated financial infrastructure providers can help companies enter the market faster, simplify compliance with the new requirements, and focus their resources on developing their own products.
At Transfero, our Crypto as a Service solution brings this infrastructure together on a single platform. Through APIs, businesses can access services such as on/off-ramps, liquidity, custody, conversion, and payments without having to build a regulated operation from the ground up.
If your company is evaluating how to comply with Brazil's new regulatory framework or expand its virtual asset offering, contact our sales team to learn how Transfero can support your business.
