Central Bank of Brazil launches public consultation to enhance eFX regulation

On September 19, 2025, the Central Bank of Brazil (“BC”) published Public Consultation Notice No. 124/2025, aiming to gather public comments, insights, and contributions regarding the proposed regulatory framework for international payment and transfer services, known as eFX.

Key Highlights Include:

1.  Mandatory Authorization: The provision of eFX services will be restricted to institutions duly authorized to operate by the BC. Currently, unauthorized providers will be granted a specific deadline to apply for authorization as a payment institution – under the categories of electronic money issuer, post-paid payment instrument issuer, or acquirer – and continue operating in compliance with regulatory requirements.
2. Information Reporting: Authorized institutions must submit advance notification to the BC declaring their intention to provide eFX services. Additionally, all entities involved in the eFX operation – including the eFX provider, the institution authorized to operate in the foreign exchange market, and the institution holding the deposit account exclusively designated for the eFX service – must submit monthly reports to the regulator detailing transactions and account movements in Brazilian reais. This proposal seeks to enhance oversight and promote greater transparency in the electronic foreign exchange market.
3. Exclusive Deposit Account: To strengthen control and traceability of operations, amounts in Brazilian reais used in eFX transactions must be received and delivered to the user through a deposit account held by the eFX provider, which must be exclusively designated for the provision of eFX services.
4. Scope Expansion: eFX services may be used to facilitate transfers related to investments in the financial and securities markets, whether domestic or international, limited to the equivalent of USD 10 thousand per transaction. This measure aims to increase the efficiency of cross-border transactions within this scope.
5. Introduction of New Foreign Exchange Codes: The proposed regulation provides for the creation of new codes applicable to foreign exchange transactions carried out to fulfill obligations assumed by eFX providers on behalf of their clients. This measure aims to enable the identification of transfers related to the purchase of goods, provision of services, and investments.
6. Client Transparency: For eFX transactions involving unilateral transfers, disclosure of the Total Effective Value (“VET”) to the client will be mandatory. The VET represents the total cost of the foreign exchange transaction in Brazilian reais per unit of foreign currency. This measure is intended to ensure greater transparency for clients, enabling comparability between different service offerings.
7. Possibility of Provision via BaaS: The BC is also seeking input on the feasibility of eFX services through Banking-as-a-Service (“BaaS”) models.

Contributions to Public Consultation No. 124/2025 may be submitted until November 02, 2025, exclusively through the channels indicated both on the BC’s website and the Participa + Brasil portal.

Public Consultation Notice No. 124/2025 is available on the BC’s website.

Demarest’s Banking and Finance team remains available to assist clients and partners with any necessary clarifications on the topic.