Newsletters

Banks, Financial Services, Fintechs and Digital Assets Newsletter – March and April 2026

May 25th, 2026

In this edition of our monthly newsletter, we have compiled the main news and regulatory developments regarding the banking industry, financial services, fintechs, and digital assets. This publication was designed as a reliable source of information for our clients, partners and professionals who work or want to know more about the current landscape in regard to these topics.

Enjoy reading!

Regulations

Central Bank of Brazil

BCB Resolution No. 552, dated March 03, 2026

BCB Resolution No. 552, dated March 03, 2026, amends BCB Resolutions:

28, dated October 23, 2020;
51, dated December 16, 2020;
65, dated January 26, 2021;
85, dated April 08, 2021;
93, dated May 06, 2021;
155, dated October 14, 2021;
260, dated November 22, 2022;
343, dated October 04, 2023; and
432, dated November 13, 2024, to include, in their scope of application, virtual asset service providers authorized to operate by the Central Bank of Brazil (“BC”).

BCB Resolution No. 552 entered into force on the date of its publication.

Read BCB Resolution No. 552 in full on the BC’s website.

BCB Resolution No. 553, dated March 03, 2026

BCB Resolution No. 553, dated March 03, 2026, amends BCB Resolutions:

2, No. 5, No. 6, No. 7, No. 8, and No. 9, dated August 12, 2020;
15, dated September 17, 2020;
33, dated October 29, 2020;
59, dated December 23, 2020;
66, dated January 26, 2021;
92, dated May 06, 2021;
120, dated July 27, 2021;
130, dated August 20, 2021;
146, dated September 28, 2021;
168, dated December 1, 2021;
170, dated December 09, 2021;
178, dated January 19, 2022;
352, dated November 23, 2023; and
513, dated October 21, 2025, to include, in its scope of application, virtual asset service providers authorized to operate by the BC.

BCB Resolution No. 553 entered into force on the date of its publication.

Read BCB Resolution No. 553 in full on the BC’s website.

BCB Resolution No. 554, dated March 24, 2026

BCB Resolution No. 554, dated March 24, 2026, amends the regulation attached to BCB Resolution No. 195, dated March 03, 2022, which governs the operation of the Instant Payments System (“SPI”) and the Instant Payments Account (“Conta PI”) at the BC.

BCB Resolution No. 554 entered into force on March 30, 2026.

Read BCB Resolution No. 554 in full on the BC’s website.

BCB Resolution No. 555, dated March 24, 2026

BCB Resolution No. 555, dated March 24, 2026, amends Circular No. 3,846, dated September 13, 2017, which regulates BCB Resolution No. 478, dated May 30, 2025. The resolution changes the rules on the Internal Capital Adequacy Assessment Process (ICAAP and ICAAP-SIMP). In addition, the resolution provides for the ICAAP-SIMP for cooperative banks and credit cooperatives and updates the guidelines on the Risk Sharing Mechanism and risk stratification.

BCB Resolution No. 555 will enter into force on July 1, 2026.

Read BCB Resolution No. 555 in full on the BC’s website.

BCB Resolution No. 559, dated April 23, 2026

BCB Resolution No. 559, dated April 23, 2026, amends the regulation attached to BCB Resolution No. 1, dated August 12, 2020, which establishes the Pix payment arrangement and approves its regulations, to improve the provisions involving the withdrawal service facilitator and the reimbursement of operating costs within the scope of Pix Saque (“Cash Withdrawal” modality) and Pix Troco (“Cash-back” modality).

The measure aims to: (i) adjust the obligations of payment institutions not authorized to operate by the BC; (ii) introduce a new case leading to loss of participation; (iii) amend the provisions governing the “amount recovery” functionality; (iv) revise the provisions on the notification of non-compliance with the Pix Regulation; (v) introduce the provision for verification of participants’ adherence to the Pix Regulation; and (vi) amend the rules applicable to the Special Return Mechanism.

BCB Resolution No. 559 entered into force on the date of its publication.

Read BCB Resolution No. 559 in full on the BC’s website.

BCB Resolution No. 562, dated April 30, 2026

BCB Resolution No. 562, dated April 30, 2026, amends BCB Resolution No. 264, dated November 25, 2022, which governs the registration of receivables arising from transactions within payment arrangements based on postpaid accounts and demand deposit arrangements that are part of Brazil’s Payment System (“SPB”). The resolution amends the procedures for canceling pre-contracted advance payments.

BCB Resolution No. 562 entered into force on May 11, 2026.

Read BCB Resolution No. 562 in full on the BC’s website.

BCB Normative Instruction No. 714, dated March 04, 2026

BCB Normative Instruction (“IN”) No. 714, dated March 04, 2026, establishes the procedures and templates of documents that are necessary for providing guidance on authorization requests involving payment arrangements that are part of the SPB.

The templates are provided in Annexes I to VII, including:

Application for authorization to establish the payment arrangement (Annex I).
Application for prior authorization to change the documents and information required in the authorization application (Annex II).
Application for cancellation of authorization due to termination of activities (Annex III).
Declaration by the originator of the payment arrangement regarding compliance with the requirements established in the regulations (Annex IV).
Notification of changes to the documents and information required in the authorization application that do not require prior authorization (Annex V).
Cross-reference index indicating the provisions of the regulation that refer to the items of Art. 19 of Annex I to Resolution No. 150, dated October 06, 2021 (Annex VI).
Requirements for the regulation of the payment arrangement (Annex VII).

BCB IN No. 714 entered into force on the date of its publication.

Read BCB IN No. 714 in full on the BC’s website.

BCB Normative Instruction No. 716, dated March 13, 2026

BCB IN No. 716, dated March 13, 2026, discloses the procedures and templates of documents complementary to BCB IN No. 714, of March 04, 2026, necessary specifically for instructing authorization requests to change the regulations of payment arrangements that are part of the SPB and that refer to compliance with BCB Resolution No. 522, dated November 10, 2025.

BCB IN No. 716 entered into force on the date of its publication.

Read BCB IN No. 716 in full on the BC’s website.

BCB Normative Instruction No. 717, dated March 24, 2026

BCB IN No. 717, dated March 24, 2026, establishes the procedures for registering transfers carried out by Brazilian financial institutions intended to credit accounts held by international organizations at the BC.

BCB IN No. 717 entered into force on April 06, 2026.

Read BCB IN No. 717 in full on the BC’s website.

BCB Normative Instruction No. 725, dated April 16, 2026

BCB IN No. 725, of April 16, 2026, establishes the guidelines, conditions, and deadlines for participating institutions to carry out tests in production regarding the sharing of an optimized payment transaction initiation service with data sharing (optimized journey) within the scope of the Open Finance.

BCB IN No. 725 entered into force on the date of its publication.

Read BCB IN No. 725 in full on the BC’s website.

Brazilian National Monetary Council

CMN Resolution No. 5,295, dated April 23, 2026

Brazil’s National Monetary Council (“CMN”) Resolution No. 5,295, dated April 23, 2026, amends Resolution No. 4,222, dated May 23, 2013, which governs: (i) contributions payable by member institutions; (ii) the conditions for access to the special guarantee; (iii) the categories of member institutions; and (iv) the bylaws and regulations of the Credit Guarantee Fund (“FGC”). The regulation establishes new provisions regarding the additional contribution and defines the conditions under which FGC member institutions must maintain amounts allocated in federal government bonds.

CMN Resolution No. 5,295 will enter into force on June 1, 2026.

Read CMN Resolution No. 5,295 in full on the BC’s website.

CMN Resolution No. 5,298, dated April 24, 2026

CMN Resolution No. 5,298, dated April 24, 2026, provides for the organization and operation of the derivatives market in Brazil.

The resolution establishes principles such as investor protection, transparency, market integrity, prevention of harmful speculation, and promotion of innovation. The regulation also prohibits, within Brazil, the offering and trading of derivatives linked to sporting events, online games, and political, social, cultural, or similar events that do not qualify as economic or financial benchmarks, permitting only products based on verifiable assets and indices of an economic or financial nature. These prohibitions also apply to derivatives traded abroad and offered in Brazil, with the Brazilian Securities and Exchange Commission (“CVM”) responsible for issuing complementary regulations.

CMN Resolution No. 5,298 entered into force on May 04, 2026.

Read CMN Resolution No. 5,298 in full on the BC’s website.

News

A Necessary Tightening: The impact of the Central Bank of Brazil’s stricter rules on fintechs

The fintech sector has grown rapidly in recent years in Brazil, driven by lean business models, a focus on technology, and initially more flexible regulations. This environment has expanded access to financial services for low-income populations and led to a 77% increase in the number of fintechs over five years, reaching just over 2,000 companies.

However, the period of rapid expansion is losing momentum. Estimates indicate that, by 2028, the market is expected to undergo significant consolidation, with mergers, acquisitions, and closures, reducing the number of companies to approximately 600.

Despite this outlook, experts assert that stricter regulation should not hinder innovation. For some – such as executives in the financial sector –, technology and compliance can advance together, enhancing both security and efficiency. Others, such as our partner in Demarest’s Banking and Finance practice area, Fabio Braga, argue that stricter rules are necessary to curb financial crimes, especially following scandals involving institutions that caused billions in losses and affected thousands of clients. In this context, tighter regulation is regarded as an essential response.

Read the article in full on the Veja Negócios website.

New regulatory proposal prioritizes security, robust capital, and interoperability in Brazil’s Payment System

The BC has launched a public consultation to improve the rules governing the operations of financial market system operators – entities responsible for settlement, registration, and centralized custody systems within the SPB. According to the BC, the changes reinforce financial stability, raise regulatory standards, and align Brazil with international best practices.

The proposal seeks to increase the security and resilience of market infrastructures, strengthen governance, risk management, and business continuity, raise technology and cybersecurity standards, and align the SPB with international best practices.

Interested parties can submit contributions by June 08, 2026.

Read the article in full on the BC’s website

Crises require a new legal framework for resolution

On March 31, 2026, Fabio Braga, a partner in Demarest’s Banking and Finance practice, published an article in his column on Bill No. 281/2019, which seeks to modernize Brazil’s resolution regime for distressed institutions. Bill No. 281/2019 replaces the outdated framework (based on Law No. 6,024/1974 and the Temporary Special Administration Regime – “RAET”) that currently produces extreme responses, such as abrupt liquidations or taxpayer-funded government interventions.

The bill incorporates international standards established by the Financial Stability Board in the aftermath of the 2008 financial crisis, introducing mechanisms such as the so-called “bail-in” (that is, internal loss absorption without the immediate use of public funds), as well as operational continuity tools, bridge banks, and the segregation of performing and non-performing assets. As a result, Bill No. 281/2019 aligns Brazil with G‑20 best practices in systemic crisis management.

A key advancement is the expansion of the scope of entities subject to the resolution regime to include payment institutions, direct credit companies (“SCDs”), peer-to-peer lending companies (“SEPs”), virtual asset service providers, entities supervised by the CVM, and entities regulated by the Superintendence of Private Insurance (“SUSEP”). The measure reflects the growing interconnectivity of the market, in which risks extend beyond the traditional banking system.

The bill does not provide for the so-called “bail-out” (that is, financial rescue funded by public resources). The use of such funds is permitted only in exceptional circumstances, subject to the prior exhaustion of shareholder capital, subordinated debt, and private resolution funds, as well as a demonstrated material systemic risk. Eliminating this valve altogether would undermine the regime’s credibility, as evidenced by international experience.

Accordingly, Bill No. 281/2019 represents a decisive step toward establishing a comprehensive, technically robust resolution framework aligned with global standards, equipping Brazil to address future crises with appropriate tools rather than the improvised solutions of the past.

Read the article in full on Valor Econômico website.

Central Bank of Brazil and Securities and Exchange Commission enter into cooperation agreement to expand and improve credit information in Brazil

The BC and the CVM have entered into a technical cooperation agreement to expand and improve the exchange of information on credit transactions, thereby strengthening credit monitoring within the National Financial System (“SFN”).

Aligned with CMN Resolution No. 5,037/2022, the initiative enables the inclusion, in the Credit Information System, of data from entities regulated by the CVM, expanding its scope beyond Credit Rights Investment Funds (“FIDCs”) to encompass securitization companies and other vehicles investing in credit rights. With more complete and standardized data, authorities improve micro- and macroprudential supervision, reduce information gaps, and promote better risk pricing, with potential positive effects on credit costs and the stability of the financial system.

Read the article in full on the BC’s website

Central Bank of Brazil introduces changes to the rules governing international payment and transfer services (eFX)

On April 30, 2026, the Central Bank of Brazil (“BC”) published BCB Resolution No. 561, amending BCB Resolution No. 277, dated December 31, 2022, which regulates Law No. 14,286, dated December 29, 2021, to improve the provisions relating to the international payment and transfer services (“eFX”).

Main points:

Scope and definition of eFX:
BCB Resolution No. 561/2026 refines the framework for eFX, including an expansion to cover transfers related to investments in the financial and capital markets, in Brazil and abroad, limited to USD 10,000.
Authorized providers and operational kick-off:
Only institutions authorized by the BC may provide eFX services in the specified categories. Unauthorized eFX providers may only continue to provide eFX services if they submit a request to the BC by May 31, 2027. The regulation requires prior registration of the service type with Unicad. Service provision may only begin five business days after such registration, without prejudice to compliance with other applicable regulatory requirements.
International settlement and operational restrictions:
Payments and receipts between the eFX provider and the foreign counterparty must occur exclusively through a foreign exchange transaction or a transaction in a Brazilian reais account held by a non-resident – the use of virtual assets and the netting of amounts paid and received are prohibited. Settlement may be made on an individual or consolidated basis. It is worth clarifying that the restriction does not prohibit the use of stablecoins in the foreign exchange market – it only restricts their use within the scope of eFX.
Contractual relationships with users and counterparties, and Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF):
The resolution regulates the roles of the sending user, receiving user, and foreign counterparty, requiring that the sending user be a client of the eFX provider, that a contractual relationship exist with the foreign counterparty, and that Know Your Customer (KYC) and Know Your Partner (KYP) procedures be followed, in compliance with Circular No. 3,978/2020. The regulation also requires monitoring by foreign exchange institutions and by the entities maintaining the accounts used.
Delivery and receipt of Brazilian reais within the country:
The regulation details the permitted methods for inflows and outflows of Brazilian reais, prioritizing transaction traceability. Additionally, it establishes specific rules for cases where the provider does not have a reserve or settlement account at the BC, requiring the use of a segregated account exclusively for eFX, and prohibiting any offsetting between amounts received and amounts delivered to users.
Information obligations, recordkeeping, and reporting:
Providers within the scope of eFX are now subject to more detailed rules regarding the provision of information to the BC through the Foreign Exchange System, with responsibilities distributed according to each institution’s role in the transaction. The resolution also updates the foreign exchange purpose codes applicable to eFX.