With the new regulatory framework for virtual asset service providers now in effect, exchanges operating or planning to operate in Brazil face a strategic decision: obtain their own license from the Central Bank of Brazil or operate through an already authorized partner.

Each model involves different costs, responsibilities, and timelines. While obtaining your own license offers greater autonomy, operating on the infrastructure of an authorized Virtual Asset Service Provider (PSAV) can accelerate market entry and reduce regulatory complexity.

In this article, we explain how each model works and which factors exchanges should consider before making this decision.

Two Ways to Operate in Brazil

Establish your own PSAV

The exchange takes direct responsibility for obtaining authorization from the Central Bank, with a Brazilian corporate entity, local management, minimum capital requirements, and the full compliance, governance, and reporting structure required of a regulated institution.

Operate through an authorized partner

The exchange keeps its brand and relationship with the end customer while running the regulated operation — including custody, liquidity, FX, and compliance — on the license and infrastructure of a partner that already meets the Central Bank’s requirements.

What Is Involved in Obtaining Your Own License?

Setting up a PSAV from scratch involves more than filling out an authorization application. These are financial and operational commitments that remain throughout the entire operation, not just during the initial setup.

High minimum capital requirement

The minimum share capital and net equity requirements vary depending on the activities performed — intermediation, custody, or both — and range from BRL 10.8 million to BRL 37.2 million. This amount must be maintained, not simply demonstrated once during the authorization process.

In addition to the initial investment, this capital must remain in place throughout the operation, making it a permanent commitment rather than merely a requirement for obtaining authorization.

Physical presence and local management

The regulations require an exclusively used headquarters in Brazil — coworking spaces and shared offices are not permitted — as well as managers who reside in the country. For an international exchange, this means building a local operation from scratch, not simply establishing a Brazilian corporate entity.

For international groups, for example, this means setting up a complete local operation with a team, local management, and dedicated headquarters, significantly increasing the investment required to operate in the country.

Increasing prudential requirements

On July 1, 2026, the Central Bank published BCB Resolution No. 580, which classifies PSAVs as Type 3 institutions, under the same regime applied to securities brokers and dealers. Starting January 1, 2027, capital, risk management, and disclosure requirements equivalent to those applicable to these institutions will come into effect. By June 30, 2028, PSAVs must also be classified under Segment 4 (S4), regardless of their size.

In practice, the cost of maintaining an independently licensed operation in compliance with the regulatory framework is likely to increase over the coming years rather than stabilize.

Time required before operating as an authorized institution

From establishing the corporate structure and raising the minimum capital to implementing the required governance framework and waiting for the Central Bank’s review, the authorization process for a PSAV typically takes months, not weeks. BCB Instruction No. 704 establishes the documents and criteria required for the application, but it does not eliminate the review period.

For an exchange that already has customers in Brazil, every month of delay means another month of regulatory exposure.

Operating Through Already Licensed Infrastructure

For many exchanges, operating through the infrastructure of an authorized PSAV is the fastest way to serve the Brazilian market without taking on the full regulatory complexity directly.

A regulated infrastructure partner already has the authorization, capital, and controls required by the Central Bank. The exchange connects its operations through an API and maintains its relationship with the end customer without having to replicate every layer of compliance internally.

This may include segregated custody of customer assets, liquidity for order execution, conversion between fiat currencies and crypto assets, international payments within applicable FX limits, and the ongoing reporting required by the regulator.

In practice, the flow works as follows: the end customer continues to interact only with the exchange’s brand. Behind the interface, each buy, sell, or withdrawal order is processed through the partner’s infrastructure, which is already responsible to the Central Bank for the regulated portion of the operation.

The exchange does not need to report directly to the regulator or maintain its own segregated custody infrastructure — these capabilities are already built into the integration.

This model also reduces time to market. While obtaining a PSAV license can take months, an API integration with an already licensed partner can typically take weeks, since the regulatory layer is already in place.

What Are the Advantages of Using an Infrastructure Partner?

Building a local financial operation internally can require multiple integrations and a complex operational structure. For exchanges that already have a global platform, working with a specialized partner can simplify the process.

Fewer integrations

Instead of establishing separate connections with different institutions and providers, the exchange can access multiple services through a single integration.

This reduces the effort required to develop and maintain multiple technical connections.

Access to local infrastructure

A specialized partner can connect the exchange to the financial rails used in the Brazilian market, such as Pix, payments, and settlement in Brazilian reais.

Faster integration

APIs allow financial services to be incorporated into the exchange’s existing infrastructure without requiring the platform to be rebuilt.

Greater scalability

As the number of users and transactions increases, the infrastructure needs to scale accordingly. Access to liquidity, payments, and different financial rails can make it easier to expand the operation.

Product focus

By using specialized infrastructure, the exchange can focus its resources on developing its own product, improving the user experience, and expanding into new markets.

Stablecoins

In addition to integration with the traditional financial system, stablecoins can make settlement between different markets more efficient.

While assets such as USDT and USDC are widely used in international operations, a Brazilian real-pegged stablecoin such as BRZ can represent BRL on blockchain and facilitate the movement of funds between Brazil’s financial system and the digital asset ecosystem.

This model reduces conversion steps and can improve efficiency in certain flows, particularly in operations involving more than one currency.

What to Look for in an Infrastructure Partner

• Active license and PSAV classification — confirm that the authorization already covers the required activities, whether intermediation, custody, or both.

• Proven asset segregation — customer funds and assets must be kept separate from the platform’s own funds.

• FX coverage — ability to operate within the limits established by Resolution 521 for international transfers.

• Compliance and reporting — AML and KYC controls already aligned with Central Bank and Federal Revenue Service requirements.

• Operational track record — length of regulated operations in Brazil, rather than simply having a recently granted authorization.

Transfero Infrastructure for Exchanges

The regulation of the digital asset market is changing how exchanges structure their operations in Brazil. The choice between obtaining your own license and using already authorized infrastructure depends on each company’s strategy, the time available to enter the market, and the resources it is prepared to dedicate to regulatory compliance.

For organizations looking to accelerate this process, operating through an authorized PSAV can reduce operational complexity without compromising the compliance requirements established by the Central Bank.

Does your company want to incorporate digital assets into financial products, payments, or other digital operations? Talk to our sales team to learn how Transfero’s financial infrastructure can support your digital asset operations.