BRAZIL Trends and Developments Contributed by: Vanêssa Fialdini, Mariana de Azevedo Mendonça and Jorge Augusto de Holanda Souza, Fialdini Advogados
Conclusion and future expectations for the market Brazil’s crypto-asset market is entering a period of regulatory consolidation. The publication of BCB Res- olutions No 519, 520 and 521 on 25 November 2025, followed by the eFX-related changes introduced by BCB Resolution No 561 on 30 April 2026, shows that the Brazilian authorities are moving from observation and consultation to implementation and supervision. The immediate priority for market participants will be regulatory transition. Existing VASPs will need to evaluate whether they fall within the scope of the new framework, prepare authorisation applications, adapt governance structures, implement risk and compliance policies, review custody and segregation arrangements, and ensure that their products can be offered under the new Brazilian rules. Foreign plat- forms will face the additional challenge of localising operations or migrating Brazilian customers to locally authorised entities by the applicable transition dead- lines. Stablecoins will remain a central theme. While their importance in the Brazilian market is unlikely to disap- pear, the Central Bank’s regulatory efforts suggests that the authority will scrutinize and limit stablecoin- based cross-border structures. Tax developments should also be expected. If Brazil proceeds with proposals to tax certain cross-border crypto transactions through IOF or another mecha- nism, the cost and design of stablecoin-based pay- ment structures may change significantly. Increased reporting obligations and international alignment with crypto-asset transparency standards may also reduce the space for offshore structures that historically oper- ated outside the view of Brazilian authorities. Looking ahead, some issues remain open. The market will need further clarity on the treatment of decentral- ised finance, self-custody, staking, lending, tokenised securities, stablecoin reserves, proof of reserves, cross-border liquidity arrangements and the interac- tion between Central Bank regulation and CVM juris- diction. The CVM will continue to play a relevant role where tokens qualify as securities, collective invest- ment schemes or investment products. The Central Bank will remain central where virtual asset services
subject to IOF, the Brazilian financial operations tax. However, there are active discussions in the Federal government regarding the extension of IOF to cross- border transactions involving cryptocurrencies, which would directly impact stablecoin transactions. A relevant development to the rules applicable to sta- blecoins came on 30 April 2026, with the publication by the Central Bank of BCB Resolution No 561. The resolution further updates the foreign exchange regu- lation specifically as related to eFX services – inter- national payment and transfer services intermediated by an eFX service provider. Among the changes to the service, including restricting the activity to licensed institutions, the rule explicitly prohibits the use of vir- tual assets for payment or receipt between an eFX provider and its counterparty abroad, effectively ban- ning the use of stablecoin arrangements by eFX pro- viders as a way to enable cross-border operations. Entering into force on 1 October 2026, the rule requires settlement between the eFX provider and the foreign counterparty to occur through fiat-based foreign exchange transactions or through movements in non-resident accounts held in Brazilian Reais. It is important to note that BCB Resolution No 561 is not a general ban on stablecoins in Brazil. Stable- coins are explicitly recognized and permitted within the crypto-asset framework, and licensed VASPs will still be able to provide custody and intermediation of stablecoins transactions in general, but their use as a settlement layer for mass cross-border payment structures is being restricted where the regulator con- siders that such use undermines transparency, super- vision or the integrity of the foreign exchange system. For market participants, the implications are practical. Payment companies and fintechs that used stable- coins operationally to settle cross-border flows may need to redesign treasury and settlement models. Crypto exchanges offering stablecoin-based remit- tance products may need to assess whether the prod- uct falls under the applicable restrictions to the eFX regime. Banks and authorised institutions may benefit from the return of certain flows to regulated FX rails. Users may see changes in fees, settlement times and product availability.
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