Central Bank publishes information necessary for processing VASP authorization requests

On January 29, 2026, the Central Bank of Brazil (“BC”) published Normative Instruction No. 704, which discloses procedures, documents, deadlines, and information required for processing authorization requests related to the operation of foreign exchange brokerage firms, securities brokerage firms, securities distribution companies, and virtual asset service providers (“VASPs”).

About the rule:

Normative Instruction No. 704 provides for requirements applied to authorization requests involving:

• The operation of foreign exchange brokerage firms, securities brokerage firms, securities distribution companies, and VASPs not currently in operation;
• The operation of active VASPs;
• Update of the type of VASPs;
• Authorization for transfer or change of control;
• Authorization for mergers, spin-offs, or consolidations;
• Authorization for corporate transformation;
• Authorization for the appointment and exercise of elected or appointed management positions;
• Authorization for changes to share capital;
• Authorization for change of corporate name;
• Authorization for change of corporate purpose;
• Cancellation of authorization to operate;
• Authorization and cancellation of authorization to operate in the foreign exchange market;
• Authorization to dissolve the audit committee;
• Notice of acquiring qualified shareholding status;
• Notice of changes to the structure of management positions; and
• Notice of capital increase arising from retained earnings, capital and profit reserves, or receivables from shareholders.

Key points – authorization to operate:

1. Supporting materials required for operation authorization requests involving foreign exchange brokers, securities brokerage firms, securities distribution companies and VASPs not currently active:

• Application, in accordance with the Sisorf 08.23.010.001 model;
• Proof of the economic and financial capacity of the controllers, compatible with the capital required for the structuring and operation of the institution;
• Declaration of the origin of the funds used by the controllers and qualified shareholders in the payment of share capital;
• Proof of assets of controllers abroad;
• Executive summary of the business plan;
• Statement that controlling shareholders and qualified shareholders have an unblemished reputation and meet legal requirements;
• Statement, executed by controllers and qualified shareholders, except for individuals, regarding compliance with the conditions established by current legislation and regulations;
• Authorizations to access tax, registry, and personal data (controllers and qualified shareholders);
• Requirements and authorizations for elected or appointed managers;
• Company statements regarding verification and qualification of managers;
• Statement from management regarding knowledge of the business, market, and risks;
• Control structure and agreements between shareholders.

2. Phase 1 requirements for VASP authorization applications:

• Formal authorization request, in accordance with model Sisorf 08.23.010.002;
• Statement that the institution was in operation on the date of entry into force of BCB Resolutions No. 519/2025 and No. 520/2025;
• Statements of unblemished reputation and compliance with legal and regulatory requirements by controllers and qualified shareholders;
• Statements of compliance with legal and regulatory requirements by controllers and qualified shareholders, except for those that are institutions authorized by the Central Bank;
• Authorizations for access to tax, registry, and judicial information and for the processing of personal data of controllers and qualified shareholders;
• Statements regarding the definition of control and the existence of corporate agreements or instruments;
• Statements on the filing, reporting, and provision of corporate agreements;
• Audited financial statements for the last three fiscal years.

3. Phase 2 requirements for VASP authorization applications:

• Formal authorization request, in accordance with the Sisorf 08.23.010.003 model.
• Statement, signed by the controllers, regarding compliance with the economic and financial capacity requirement – compatible with the capital necessary for the structuring and operation of the institution – as well as contingencies arising from market dynamics , except in the case of a company controlled by an institution authorized by the Central Bank, or a controller who is a natural person residing or domiciled abroad or a legal entity based abroad.
• Information and supporting documentation proving compliance with the economic and financial capacity requirement – compatible with the capital necessary for the structuring and operation of the institution – as well as with the contingencies arising from market dynamics. Based on this information, the Central Bank will verify the asset evolution over the last three fiscal years of any controlling shareholder who is an individual resident or domiciled abroad, or a legal entity headquartered abroad.
• Statement of the lawful origin of funds to pay in the share capital, except where a controlling shareholder or qualified shareholder is an institution authorized by the Central Bank.
• Executive summary of the business plan.
• Statements of unblemished reputation and technical qualifications of the managers.
• Authorizations from managers for access to information and processing of personal data by the Central Bank.
• Company statements regarding the verification, qualification, and monitoring of managers.
• Statement of management’s knowledge of the business, the market, and the associated risks.

Business Plan

The business plan referenced as a requirement for certain authorizations must provide for at least five years of activity and include:

• a marketing plan;
• an operational plan; and
• a financial plan.

Executive Summary of the Business Plan

The executive summary of the business plan must include, among other specifications, a description of the business, strategic targets, market opportunities, an assessment of the market segment, and the key products and services to be offered. It must also include, among other items, background information, the organizational chart, the economic group, physical location, relevant services contracted in Brazil and abroad for the provision of virtual asset services, and the corporate governance framework and standards.

BCB Normative Resolution No. 704 came into force on February 2, 2026.

See Normative Resolution No. 704 in full

Demarest’s Banking and Finance team is available to provide further clarifications.