BRAZIL Law and Practice Contributed by: Eduardo Castro, Pedro Nasi and Gabriel Libanori, Machado, Meyer, Sendacz e Opice
Machado, Meyer, Sendacz e Opice Rua José Gonçalves de Oliveira, nº 116, 5th floor
Itaim Bibi São Paulo Brazil Tel: +55 11 3150 7000 Email: bd@machadomeyer.com.br Web: www.machadomeyer.com.br/en/
1. Fintech Market 1.1 Evolution of the Fintech Market
• a new regulatory landscape regulating banking as a service (BaaS) relationships through the issuance of CMN BCB Joint Resolution No 16/2025; • the enactment of new rules regulating foreign exchange brokers ( corretoras de câmbio ), which has allowed such institutions to act as e-currency issuers and virtual asset intermediaries in Brazil, in accordance with Resolution No 542/25; • the creation of new rules for centralised risk man - agement in payment schemes that are part of the Brazilian payment system ( Sistema de Pagamentos Brasileiro SPB) as a result of Public Consultation Notice Nos 104 and 204; and • the creation of new regulatory and technical requirements for information technology service providers ( provedor de serviços de tecnologia da informação PSTI) with access to the Brazilian financial system network ( Rede do Sistema Finan- ceiro Nacional RSFN), through the issuance of BCB Resolution No 498/25. These actions aim to revamp the Brazilian regulatory landscape by bringing certain key business models into the regulatory perimeter with clear accountability, capital expectations and operational controls. As a result of the new rules, the market is expecting to see a significant number of authorisation requests to oper - ate as VASPs in 2026, both from new market entrants and from institutions who were already operating in Brazil.
The Brazilian fintech market continues to evolve swift - ly, supported by a pro-innovation stance led by the Central Bank of Brazil ( Banco Central do Brasil BCB) and the National Monetary Council ( Conselho Mon- etário Nacional CMN). Over the past 12 months, the BCB has discussed sev - eral matters focusing on security and financial stabil - ity, including: • a new calculation method for minimum and perma - nent capital, and net equity, for institutions author - ised to operate by the BCB, through the enactment of CMN/BCB Joint Resolution No 14/25 and BCB Resolution No 517/25, which has substantially changed the entrance scenario for new institutions in the country, as well as the capital requirements for institutions subject to the transitional regime set forth by such rules; • the launch of a new regulatory framework for virtual asset service providers (VASPs), encompassing rules relating to corporate governance, operational standards, the integration of virtual asset transac - tions into the foreign exchange market framework and the authorisation process before the BCB, with core regulatory provisions taking effect on 2 February 2026 by means of BCB Resolution Nos 519–521;
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