BRAZIL Law and Practice Contributed by: Eduardo Castro, Pedro Nasi and Gabriel Libanori, Machado, Meyer, Sendacz e Opice
2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models
Brazil, including global fintechs. The main recent trend in this area is the emergence of the “global account” model, a product through which Brazilian users are able to open accounts in other jurisdictions and hold funds in multiple currencies using the same app. Also, the BCB has recently allowed foreign exchange bro - kers to offer prepaid payment accounts as an ancillary activity, which should enhance the sector. The regulation concerning the provision of internation - al payment and transfer services was recently sub - ject to public consultation through the BCB’s Public Consultation Notice No 124/2025, proposing that all institutions providing international payment services (so-called eFX services) obtain authorisation from the BCB to operate as a payment institution, while also introducing other changes to strengthen oversight of international payments. The market expects the regu - lation resulting from the consultation to be enacted during 2026. Payment Services Payments remain a core engine of fintech growth. The SPB encompasses many of the latest and most effi - cient payment solutions and innovations. For instance, Pix (instant payment system) processed transactions worth a total of BRL3 trillion monthly in 2025. Payment services in Brazil are provided both by incumbent banks and payment service providers ( instituições de pagamento ). With the introduction of the Pix instant payments scheme by the BCB, sev - eral payment service providers currently offer (either in accordance with regulatory obligations or voluntarily) instant payments through direct or indirect participa - tion in the Brazilian instant payments system ( sistema de pagamentos instantâneos SPI). Crypto Market With the recent introduction of a regulatory framework for VASPs, alongside the ongoing wave of authorisa - tion requests and compliance initiatives, this sector is expected to grow substantially – particularly given the global increase in operations involving stablecoins. Unlicensed Business Models As further detailed in 2.2 Regulatory Regime , there are unlicensed fintechs that implement their business
Fintech business models in Brazil are very diverse. Products and services can be offered by legacy play - ers (traditional banks in the Brazilian financial sys - tem), licensed fintechs that hold specific licences and unlicensed fintechs (as detailed in 2.2 Regulatory Regime ). The business models that predominate in Brazil are as follows. Credit Market Products and services in the credit market can be offered by traditional banks, credit fintechs and unli - censed fintechs – in the last case necessarily through partnerships with licensed financial institutions via BaaS or banking correspondent structures (as detailed in 2.2 Regulatory Regime ). Credit fintechs usually target businesses with small- ticket operations and/or borrowers with lower credit scores. Investment Market The investment market in Brazil has more tradition - al players than fintechs. Traditional players include investment banks, universal banks with investment portfolios, securities broker-dealers ( corretoras de títulos e valores mobiliários CTVMs) and securities dis - tribution companies ( distribuidoras de títulos e valores mobiliários DTVMs), which are regulated by the Secu - rities and Exchange Commission of Brazil ( Comissão de Valores Mobiliários CVM) and BCB. The fintech market involving investment products has been growing. Cross-border structures involving the “introducing broker” business model, based on the CVM’s opinion notes, have increased in number in the last few years, with the aim of enabling Brazil- based institutions to introduce their clients to prod - ucts offered by licensed institutions abroad. These products are known in Brazil as “investment global accounts”. Foreign Exchange Market The foreign exchange market has experienced regula - tory changes that have incentivised new entrants into
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