Banking and finance newsletter: Brazil Q1 2026 updates

Brazililian Central Bank and National Monetary Council strengthen credit guarantee rules

The Brazilian National Monetary Council (CMN) and Central Bank (BCB) recently issued CMN Resolution No. 5,279 (January 22, 2026) and BCB Resolution No. 551 (March 3, 2026), introducing significant changes to the regime governing the Credit Guarantee Fund (FGC – broadly comparable to the FDIC in the United States). The new rules bolster the fund’s governance and directly affect how member institutions calculate their contributions and monitor risk.

CMN Resolution No. 5,279/2026 amends CMN Resolution No. 4,222/2013, which sets out the FGC’s bylaws and operational regulations. Principal changes include giving the FGC power to review member institutions’ systems and controls for calculating and remitting ordinary, special, and additional contributions, as well as for determining the amounts and issuance limits of financial instruments covered by the fund’s guarantee.  The resolution also clarifies that institutions placed under intervention or extrajudicial liquidation (administrative wind-down procedures overseen by the BCB) are exempt from paying contributions while retaining their member status within the FGC.

BCB Resolution No. 551/2026, in turn, introduces rules allowing member institutions to offset accelerated FGC contributions against compulsory reserve deposits they already hold at the BCB. Covering both demand and time deposits, this measure lets institutions use those reserves as credit toward any contributions the FGC’s board of directors decides to collect ahead of schedule.

New rules for virtual asset services

The BCB has continued building out Brazil’s regulatory framework for virtual assets by issuing a series of normative instructions that spell out procedures, technical requirements, and reporting obligations for Virtual Asset Service Providers (VASPs) – entities such as crypto exchanges, custodians, and other businesses dealing in virtual assets.

• Notifying interest and technical certification

BCB Normative Instruction No. 701 (January 22, 2026) sets the rules for notifying the BCB of an intention to provide virtual asset services. The following requirements must be met for notification to be valid:

• Up-to-date registration in Unicad (the BCB’s centralized registry of supervised entities);
• Submission (on a dedicated BCB system) of certification prepared by an independent, qualified firm attesting to the applicant’s technical capacity and independence; and
• A technical opinion meeting prescribed minimum-content requirements, individually assessing governance, internal controls, risk management, cybersecurity, and asset segregation.

• Authorization applications and corporate documents

BCB Normative Instruction No. 704 (January 29, 2026) details the procedures and documentation required to obtain an operating license, as well as corporate documents involving VASPs and other regulated entities.  Applicants that have yet to commence operations must submit a comprehensive dossier covering corporate structure, financial capacity, governance, and a business plan. Those already operating fall under a two-phase transitional regime: an initial filing of structural information and proof of prior activity, followed by supplementary documentation after the BCB’s preliminary review.

• Reporting and sending information

BCB Normative Instruction No. 713 (February 27, 2026) establishes rules on the form, content, and frequency of information VASPs must submit to the BCB. Obligations include monthly reporting of proof-of-reserves and staking transactions and daily reporting of custody data, effective from the date the authorization application is filed.

BCB changes authorization process for operating in forex markets

BCB Normative Instruction No. 705 (January 29, 2026) updates the procedures for entities seeking authorization to operate in the foreign-exchange market. Notable changes include a requirement to provide a reasoned justification demonstrating the project’s economic and financial viability, along with evidence that the applicant’s IT infrastructure and governance framework are adequate for the complexity and risks of the intended operations.

BCB discloses accreditation process for IT Service Providers (PSTI)

BCB Resolution No. 547 (January 30, 2026) revises the accreditation regime for Information Technology Service Providers (PSTI) seeking access to the National Financial System Network (RSFN). The resolution amends BCB Resolution No. 498/2025 and tightens qualification criteria and supervisory oversight.

Requirements include proof of technical and operational capacity, information-security certification under international standards, and a minimum paid-in capital of BRL 15 million. The BCB may impose additional requirements proportional to a provider’s size, transaction volume, and risk profile. Notably, entities that serve only institutions within the same corporate group are exempt from accreditation, provided they maintain adequate operational segregation and comply with the regulator’s technical and security standards.

VASPs included in the scope of rules applicable to financial institutions

• Bank-secrecy rules

CMN Resolution No. 5,280 (February 26, 2026) brings VASPs within the scope of Supplementary Law No. 105/2001, Brazil’s bank secrecy statute. This law governs the confidentiality of financial institution operations and the circumstances under which customer information may be disclosed. VASPs must now observe the same data protection and confidentiality standards as traditional financial institutions.

• Governance, conduct, and risk management

BCB Resolution No. 552 (March 3, 2026) extends a range of requirements previously applicable to conventional financial institutions to VASPs. The requirements include the establishment of an ombudsman, implementation of compliance and cybersecurity policies, creation of an internal audit structure, adoption of internal controls, observance of customer relationship standards, information sharing on fraud indicators, and a formalized management compensation policy.

• Cosif and accounting standardization

BCB Resolution No. 553 (March 3, 2026) subjects VASPs to the Accounting Statement of Financial Institutions (Cosif), Brazil’s standardized accounting framework for supervised financial entities. Among other requirements, compliance entails preparing and disclosing individual and consolidated financial statements, recognizing and measuring assets and liabilities, accounting for provisions and contingencies, and recording shareholders’ equity.

BCB and CMN establish accounting rules for virtual assets

CMN Resolution No. 5,281 and BCB Resolution No. 550 (both February 26, 2026) establish rules for supervised institutions on recognizing, measuring, and disclosing virtual assets. CMN Resolution No. 5,281 applies to financial institutions and certain other BCB-authorized entities, while BCB Resolution No. 550 covers administrators of consortiums (a group-purchasing arrangement commonly used as a financing mechanism in Brazil), payment institutions, brokers, distributors, exchange brokers, and VASPs.

Under both resolutions, virtual assets are initially recognized at cost or, where applicable, at fair value, and must be remeasured at fair value at least monthly, with changes recognized in profit or loss. Specific criteria apply to certain categories, such as assets issued by entities within the same corporate group and non-fungible tokens (NFTs). The rules also address derecognition; the accounting treatment of assets issued by the reporting institution itself; and assets held in custody on behalf of third parties. Institutions must include disclosures in their notes to the financial statements covering accounting policies adopted, associated risks, quantities, movements, and gains or losses. The rules take effect prospectively on January 1, 2027.

Authorization requests and change notifications regarding payment arrangements in the Brazilian Payments System

BCB Normative Instruction No. 714 (March 4, 2026) consolidates the procedures and documents required for authorization requests and change notifications relating to payment arrangements within the Brazilian Payment System (SPB). The instruction introduces mandatory templates – including in regard to application forms, regulatory compliance declarations, and an index for each arrangement’s rules – and prescribes minimum content for the arrangement’s regulations (Annex VII). Arrangement operators must publish updated regulations on their websites and use the BCB’s digital filing system to submit all documentation. Existing operators are required to review their regulations and align future filings with the new templates.

BCB upgrades liquidity management rules for Instant Payment System participants

BCB Resolution No. 554 (March 24, 2026) upgrades liquidity management tools for direct participants in the Instant Payments System (SPI). New features in the Instant Payments Account (PI Account) include real-time balance inquiries, the ability to send operational commands, and access to account statements.

Participants can also configure minimum-balance alerts, parameters for flagging atypical transactions, and a floor for the operating balance. The most significant change is a new automatic blocking mechanism: if a payment order would reduce the PI Account balance below a predefined minimum and the feature is enabled, the BCB temporarily suspends settlement until the participant issues an unblocking command. While the block is in effect, pending payment orders are rejected. This requires participants to maintain more robust internal processes for monitoring and managing liquidity.

BCB publishes public consultation on financial market infrastructure

On March 10, 2026, the BCB opened Public Consultation No. 129, seeking comments on proposed amendments to BCB Resolution No. 304/2023 aimed at strengthening the regulatory framework for Financial Market Infrastructure Operators (IOSMF) and preserving the SPB’s stability. The proposals cover new authorization requirements (potentially including independent auditing), prudential adjustments, a formal IT-governance mandate including an IT Master Plan, stronger business-continuity standards, enhancements for central counterparties, changes to protection fund rules, and interoperability and accounting requirements (including adopting the Cosif framework). Contributions must be submitted by June 8, 2026.

For more information on these topics, please contact Mattos Filho’s Banking & Finance practice area.