With the regulation of virtual assets in Brazil, a new category of institution authorized to provide services related to these assets was introduced: the Virtual Asset Service Provider (VASP).
Simply put, a VASP is a company authorized by the Central Bank of Brazil (BCB) to provide certain services involving virtual assets, such as buying, selling, exchanging, brokering, and custody.
To operate, these institutions must comply with rules related to security, risk management, internal controls, and compliance. The goal is to establish standards for companies providing these services and increase the security of operations in the Brazilian market.
What can a VASP do?
A VASP can provide different services related to virtual assets. The activities it is allowed to perform depend on the institution's category and the authorization granted by the Central Bank.
These activities include:
buying and selling virtual assets;
exchanging virtual assets;
brokering transactions;
custody and management of assets;
distribution;
trading.
Therefore, not all VASPs offer the same services. The category under which the institution operates determines which activities it can perform.
What are the types of VASPs?
The regulation establishes three categories of Virtual Asset Service Providers: intermediary, custodian, and broker.
The main difference lies in the role each one plays in transactions and its responsibility for holding clients' assets.
Intermediary VASP
An intermediary VASP connects buyers and sellers of virtual assets and facilitates transactions. It can participate in trading and distribution but is not necessarily responsible for holding clients' funds.
Custodian VASP
A custodian VASP is responsible for holding and managing clients' virtual assets. These institutions keep assets in custody and must adopt security and control measures to protect funds and monitor their movement.
Broker VASP
A broker VASP combines the two functions described above: intermediation and custody. Its operation is therefore similar to the model commonly associated with virtual asset exchanges. However, under the new regulatory framework, these institutions must comply with specific requirements for security, governance, risk management, and compliance.
Requirements to become a VASP
To operate as a VASP, a company must meet a series of requirements established by the regulation.
These include:
adequate corporate and organizational structure;
minimum capital and net equity requirements;
governance rules;
internal controls;
risk management;
anti-money laundering policies;
customer identification and monitoring;
segregation of client assets;
security controls;
business continuity measures.
These rules help establish standards for companies providing virtual asset services and increase the security of their operations.
In addition to VASPs, banks, broker-dealers, securities distributors, and payment institutions that are already authorized by the Central Bank may also provide certain services related to virtual assets, as long as they comply with the rules applicable to each activity.
Why are VASPs important to the virtual asset market?
The regulation of VASPs, established by BCB Resolutions No. 519, 520, and 521, introduces new rules for companies providing virtual asset services in Brazil.
For companies already operating in this market, one of the main changes is the need to adapt their operations to the new regulatory requirements.
Institutions that were already providing services covered by the regulation before the new rules came into effect have until October 30, 2026, to file an authorization application with the Central Bank, in accordance with the transition rules established by BCB Resolution No. 520.
This means these companies need to assess, within this period, how their operations fit into the new framework and what measures are necessary to continue operating in compliance with the applicable rules.
For companies planning to enter this market, the regulation also changes how new operations need to be planned. Before offering virtual asset services, it is necessary to understand which activities will be performed, which requirements apply, and whether the company will need its own authorization.
What does this mean for companies looking to incorporate virtual assets?
Not every company that uses virtual assets necessarily needs to build its own infrastructure to provide these services.
A fintech that wants to add virtual assets to its product, a payment platform planning to work with cryptocurrencies, or a company looking to offer digital asset trading, for example, can evaluate different operating models.
One option is to obtain its own authorization and build the necessary teams and processes internally to meet regulatory requirements.
Another is to use the infrastructure and services of an already authorized institution, when the business model and intended activities allow for it.
This decision involves evaluating factors such as:
which activities the company intends to offer;
which responsibilities will remain with each party;
which authorizations are required;
compliance and risk management structure;
technology and operational infrastructure;
the time and investment required to launch the operation.
For this reason, regulation should not be viewed only as a requirement for obtaining authorization. It also becomes part of the decision-making process for structuring virtual asset products and operations.
Why is it important to understand VASPs?
VASPs create a clearer framework for companies providing virtual asset services in Brazil.
For companies already operating in this market, understanding the new rules is important to identify what needs to be adapted and which deadlines must be met.
For companies planning to enter the market, understanding the regulatory framework helps determine from the outset which operating model makes sense, which services will be offered, and how the financial and regulatory infrastructure will be structured.
In this context, companies can choose between building their own infrastructure or working with authorized institutions, depending on the characteristics of their operations.
Is your company looking to incorporate virtual assets into financial products, payments, or other digital operations? Talk to our sales team and discover how Transfero's financial infrastructure can support your virtual asset operation.
