A crypto exchange based in Singapore serves 40,000 users in Brazil, who deposit and withdraw reais through Pix via a local payment partner. Brazil’s VASP authorization deadline passed on October 30, 2026, and the partner’s compliance team is now asking the exchange a direct question: are you authorized, and if not, how do your Brazilian users keep moving reais? What changed for foreign crypto exchanges in Brazil after the deadline?
Firms already operating in Brazil had to request Central Bank authorization by October 30, 2026: those that filed may keep operating while the request is analyzed, and those that did not must stop within 30 days. From November 6, 2026, financial and payment institutions in Brazil may no longer carry out or enable virtual asset operations with providers that are not authorized.
What did the October 30 deadline require?
The deadline comes from BCB Resolution No. 520, of November 10, 2025, which took effect on February 2, 2026. Article 88 gave providers already operating 270 days from that date to request authorization, a window that closed on October 30, 2026.
For foreign firms, a second rule mattered just as much. Article 1 of Resolution 520 defines operating in Brazil as being incorporated in the country, with headquarters and management located there. Article 23 gave a foreign entity that served the Brazilian market the same 270 days to transfer its operations and clients to an authorized institution or to a Brazilian PSAV, the Brazilian term for a VASP.
The rest of the rulebook, from governance to capital, is covered in what foreign exchanges need to know about Brazil’s VASP license.
Where does a foreign crypto exchange stand now?
The answer depends on what the exchange did before October 30. There are three situations.
1. It filed or moved its clients before the deadline
A Brazilian entity that filed on time may keep providing its services until the authorization process ends, under article 88, paragraph 6, without adding a new service type in the meantime. A foreign group that transferred its Brazilian clients to an authorized institution or a local PSAV serves them through that successor, which takes full responsibility for the clients under article 23.
2. It did not file and did not move its clients
Article 88, paragraph 7, requires a provider that did not file on time to stop its virtual asset services within 30 days after the deadline. In practical terms, the period after October 30 is a wind-down window, not a grace period.
3. It never served Brazilian users
An exchange planning to enter Brazil now is outside the transition rules. It needs a Brazilian entity and Central Bank authorization before it starts, or it can reach Brazilian users through an institution that is already authorized.
What changes on November 6?
BCB Resolution No. 589, of September 23, 2026, rewrote article 91 of Resolution 520, effective October 1, 2026. From November 6, 2026, financial institutions, payment institutions and other institutions authorized by the Central Bank may not carry out or enable virtual asset market operations with providers that are not authorized to operate in Brazil.
The previous wording also allowed providers “in the process of authorization.” That phrase is gone. The ban reaches trading, intermediation and custody of virtual assets, FX operations, payment accounts and payment transactions when they are used to enable those operations.
For a foreign exchange, this is where the deadline becomes operational. The bank or payment institution behind its BRL deposits and withdrawals has its own rule to follow, regardless of what the exchange decided. What the deadline means for firms that filed and those that did not walks through the same dates from the provider’s side.
Can a foreign exchange still serve Brazilian users?
There are two paths, and they lead to different operating models.
Its own authorization: a Brazilian entity, with headquarters and management in Brazil, authorized by the Central Bank. Full control of product and client relationship, and the full cost of capital, governance and compliance.
An authorized institution: the regulated activity sits with an institution authorized in Brazil, and the exchange serves users on top of that infrastructure, under a contract that defines who owns the client relationship and the KYC data.
Which path fits depends on volume in reais, appetite for a local structure and how much of the product the exchange needs to control. The trade-offs are compared in detail in own license or authorized partner for exchanges in Brazil. Each case still needs its own legal analysis.
What has changed in the official texts since the deadline?
When this article was checked against the official text of Resolution 520 on November 3, 2026, the dates were the ones described above: October 30, 2026 for authorization requests, 30 days to stop for those that did not file, and November 6, 2026 for the counterparty ban in article 91. No extension had been published in the resolution.
What does a bank check from November 6? An example
Take an exchange that settles BRL 20 million a month in Pix deposits and withdrawals through a Brazilian payment institution. The values are illustrative.
Before November 6, the payment institution may have accepted a provider that was preparing its application.
From November 6, the payment institution has to confirm that the provider it serves is authorized by the Central Bank, because article 91 bars it from enabling virtual asset operations for unauthorized providers.
If the exchange itself is not authorized, the BRL 20 million monthly flow needs another structure, such as serving users through an institution that is authorized.
The same check applies to the accounts and Pix transactions that move users’ reais, not only to the trading itself.
Serving Brazilian users after November 6? See how BRL rails work through licensed infrastructure.
How does Transfero work with exchanges in Brazil?
Transfero is a financial infrastructure company that connects banking rails, blockchain networks and liquidity. Its Crypto as a Service offering gives exchanges, wallets and fintechs ramps, swaps, payments and custody through APIs, within a regulated framework with built-in KYC and AML.
BRL on-ramps and off-ramps through Pix, in the same integration as swaps and payments
Custody powered by Fireblocks
KYC and AML built into the flow
A top-5 global exchange used this setup to run BRL on and off-ramps, BRZ and KYC in one integration; according to the published case, its trading volume grew 200%.
Transfero Instituição de Pagamento Ltda. is authorized by the Central Bank of Brazil to operate as a payment institution. For digital asset services in Brazil, the group also operates Transfero SPSAV, which has submitted its application for authorization to the Central Bank of Brazil and operates under the applicable transitional framework. Onboarding and contractual requirements depend on the services and operating model.
Questions to ask now
Did your exchange serve users in Brazil on February 2, 2026?
Did it file for authorization or transfer its Brazilian clients by October 30, 2026?
Which banks and payment institutions settle your BRL flows, and what will they ask you from November 6?
If you did not file, what is your plan for users within the 30-day window?
If you work with an authorized institution, who owns the client relationship and the KYC data?
Talk to Transfero’s team about BRL on-ramps and off-ramps for your exchange: get in touch.
Frequently asked questions
Can an exchange still apply for authorization after October 30?
Not under the transition rule for firms already operating. Article 88 of Resolution 520 set October 30, 2026 as the limit, and a provider that did not file must stop within 30 days. A new Brazilian entity can still request authorization under the regular process, but it cannot operate before it is authorized.
What happens to users’ assets if an exchange stops serving Brazil?
Resolution 520 requires a provider that did not file to cease its services within 30 days. When a foreign entity transfers its Brazilian clients to another institution, article 23 requires continuity, security, transparency and informed consent, and the successor takes full responsibility for those clients.
Does Resolution 589 affect stablecoin transfers?
The ban in article 91 covers FX operations, payment accounts and payment transactions used to enable virtual asset operations with unauthorized providers. Under BCB Resolution No. 521, buying and selling stablecoins and international payments with virtual assets are FX operations, so stablecoin flows sit inside the same rules.
Does a foreign exchange need a Brazilian entity?
To operate in Brazil on its own, yes. Resolution 520 defines operating in the country as being incorporated in Brazil, with headquarters and management located there. The alternative is to serve Brazilian users through an institution that is already authorized.
