Understand the BCB resolutions, their impact on VASPs, and the new rules for stablecoins and foreign exchange operations in Brazil.
With the growing use of digital assets and the emergence of new applications for them, authorities around the world have been mobilizing to create regulatory frameworks governing the operation of this market. In Brazil, this movement intensified at the end of 2025, when the Central Bank of Brazil (BCB) issued rules regulating virtual assets.
On November 10, 2025, three resolutions were published to regulate the Virtual Assets Law (Law No. 14,478, of December 21, 2022) and establish guidelines for the organization and supervision of the sector in Brazil. The new measures came into effect on February 2, 2026, with a transition period for compliance and licensing.
In this article, we explore the scope of these new resolutions, their impact on Virtual Asset Service Providers (VASPs), and how this new regulatory framework is expected to influence operations, compliance, and the growth of the sector in Brazil.
For years, Brazil’s cryptocurrency market operated with limited standardization and without clear rules. This scenario began to change definitively with the implementation of Virtual Assets Law No. 14,478 of 2022, which establishes parameters for operations involving digital assets.
The law defines what constitutes a virtual asset and establishes that service providers may only operate in the country with prior authorization and through a legal entity incorporated in Brazil.
However, several aspects were not fully addressed in the law and were left to be detailed by the designated regulator, the Central Bank of Brazil.
In this context, the Central Bank issued three new resolutions (Resolutions 519, 520, and 521) with the main objective of bringing digital asset transactions into a regulated system, mitigating risks associated with decentralized systems, and ensuring greater security for users without hindering innovation.
Entities classified as Virtual Asset Service Providers (VASPs) will be directly impacted by the new rules. These are legal entities that, on behalf of third parties, provide services such as exchange between virtual assets and fiat currency, transfers, custody, or administration of virtual assets.
The regulatory framework organizes these entities into three categories:
These service providers will now be subject to supervisory, governance, and compliance rules similar to those applied to traditional financial institutions. Institutions already authorized by the BCB, such as banks and brokerage firms, may also provide these services, provided they obtain specific authorization.
BCB Resolution No. 519 establishes guidelines for the authorization and licensing of Virtual Asset Service Providers and became effective on February 2, 2026.
To obtain operational authorization from the Central Bank, VASPs must meet several essential requirements, including proof of economic and financial capacity of the institution and its controllers, business model viability, corporate governance, and technological infrastructure. As provided in the 2022 law, the regulation reinforces the requirement of a legal entity incorporated in Brazil with its own physical address.
Business model viability is a key element for licensing and must contemplate at least a five-year operational horizon. Market, operational, financial, and governance data must be detailed and certified.
Companies must submit authorization requests to the Central Bank by October 30, 2026, which corresponds to 270 days after the regulation came into effect. Capital and reputation requirements will be analyzed initially, and once validated, the evaluation of other regulatory aspects will begin.
During this period, VASPs operating in Brazil that submit their applications within the deadline may continue operating until the process is concluded.
The Central Bank may deny licensing requests if it identifies inconsistencies in the submitted information or noncompliance with the established requirements. VASPs may also withdraw their application at any time.
BCB Resolution No. 520 details how VASPs must be structured and operate in the Brazilian market. Like the previous resolution, it became effective on February 2, 2026.
It clearly establishes the responsibilities and duties that companies must follow when operating under the different service modalities: Intermediaries, Custodians, and Brokers. VASPs are prohibited from engaging in activities not provided for in the regulation or inconsistent with their authorized modality.
Among the requirements applicable to VASPs, the following stand out:
Compliance and Security Requirements: Institutions must implement formal governance policies, internal controls, and risk management frameworks. They must also adopt robust cybersecurity standards, customer risk profiling tools, AML and CFT procedures, and data protection measures.
Governance: VASPs must adopt a minimum governance structure with at least three directors or officers accountable to the BCB. Additionally, they must include the expression “Virtual Asset Service Provider Company” in their corporate name.
Audit Processes: Companies must undergo independent audits every two years and implement proof-of-reserves mechanisms to demonstrate the existence of assets.
Asset Segregation: A strict segregation between the institution’s and clients’ virtual assets and financial resources is mandatory, with funds maintained in segregated accounts.
Minimum Capital: The BCB has not yet provided a definitive breakdown of share capital and net equity requirements. However, during a press conference, it indicated that minimum capital requirements will depend on the range of activities performed by the VASP, potentially varying from BRL 10,800,000 to BRL 37,200,000, pursuant to Joint Resolution No. 14 and BCB Resolution No. 517, both dated November 3, 2025.
The resolution prohibits VASPs from offering credit to clients and from raising funds from the public, except through the issuance of shares. It also prohibits the use of clients’ virtual assets for proprietary operations, except for staking activities and transactions involving qualified or professional investors.
As of October 30, 2026, institutions authorized by the BCB are also prohibited from operating in Brazil with counterparties that are not authorized or are in the licensing process, except for expressly provided exceptions.
The resolution further defines important concepts that previously lacked clear definitions in Brazilian regulation, such as foreign currency-referenced virtual assets (stablecoins), smart contracts, airdrops, staking, cold, warm, and hot wallets, liquidity providers, among other terms.
BCB Resolution No. 521 specifically addresses international transactions involving virtual assets, which are now formally regulated and integrated into Brazil’s foreign exchange market.
As of May 4, 2026, institutions will be required to provide the BCB with minimum monthly information regarding foreign exchange operations involving virtual assets, following the same model applied to international transactions conducted within traditional systems.
The following operations are now regulated:
VASPs must comply with a limit of USD 100,000 per foreign exchange transaction involving virtual assets when the counterparty is not an institution authorized by the BCB to operate in the foreign exchange market. In addition, any operation involving physical currency, whether domestic or foreign, through service points is prohibited.
The new regulatory framework for virtual assets represents a significant development for Brazil’s cryptoasset market. The resolutions issued by the Central Bank establish, for the first time, clear and comprehensive rules that bring the sector within the scope of traditional financial regulation.
Although the path to regulatory compliance presents challenges and requires adjustments by VASPs, the existence of a clear legal framework may, in the long term, benefit the Brazilian cryptoasset market by increasing operational security and attracting more users and institutional investors to the sector.
Conduit already operates in accordance with robust compliance standards and will continue to fully adhere to the guidelines established by the new regulation applicable to VASPs. In doing so, the company reinforces its commitment to offering international stablecoin transactions that are secure, accessible, and fast, aligned with regulatory requirements and industry best practices.
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