Central Bank of Brazil regulates interoperability standardization events between registrars and sets fee caps

On May 08, 2025, the Central Bank of Brazil (“BC”) published Resolution BCB No. 472, which provides for the standardization of interoperability events between registrars of payment arrangement receivables, as well as fee caps and collection methods applicable to these services. The regulation integrates the regulatory framework governing interoperability activities within the scope of receivables registration, as provided for in Resolution BCB No. 264, of November 25, 2022, and aims to align the operational relations between registrars.

Interoperability activities carried out between registrars allow contracts and receivables schedules to be shared between different entities within the sector, thus ensuring service continuity regardless of the institution with which the receivables were initially registered. BCB Resolution No. 472 structures this dynamic by identifying specific events that trigger fee collection between registrars. 

These events are listed as follows:

1. Agenda consultation, comprising the application for information on receivables units (“URs”) already constituted or to be constituted, including an individual collection per agenda, both batch and online;
2. Contract effect, relating to the inclusion and permanent contractual effects on active URs, including collection per UR every effective month; and
3. Contract update, regarding the amendment of contractual information or the affected URs, including collection for each updated UR. URs due in previous months are not subject to the effective contract fee.

The regulation also establishes a set of technical definitions that are essential for applying its provisions, including: the concept of “receivables unit” as a financial asset consisting of receivables from payment arrangements; “receivables agenda”, characterized by URs with standardized information; and the difference between an active UR (whose amount has been or is to be constituted, subject to future settlement) and an overdue UR (whose settlement has already expired).

Regarding the collection of interoperability fees, BCB Resolution No. 472 sets specific maximum amounts for each type of event, effective as of July 01, 2025. These amounts, expressed in reais and listed in a document attached to the regulation, will be gradually deducted on an annual basis until July 01, 2029. Annual cap readjustments will be limited to the accumulated variation of the Extended National Consumer Price Index (“IPCA”) from May 1st of the previous year and April 30th of the year in force. The regulation prohibits an increase in the fees charged in 2024, and only allows them to be updated in compliance with the IPCA. Entities choosing to charge lower amounts than the regulatory caps must do so in a non-discriminatory way in relation to other registrars.

BCB Resolution No. 472 also imposes transparency obligations and further requires registrars to publish the fees actually charged for each standardized event on their websites. Participants and the BC must be notified of any changes in these amounts at least 30 days in advance, always in compliance with the caps specified in the annex. In addition, by June 30, 2029, registrars must forward a joint report including a proposal to revise fee caps or a new pricing structure – to be implemented upon the BC’s approval. Until then, the current maximum amounts will remain in force, including an annual adjustment in compliance with the IPCA.

BCB Resolution No. 472 will enter into force on June 01, 2025. The standardized interoperability fees addressed in the regulation annex will come into force on July 01, 2025.

Demarest’s Banks, Financial Services, Fintechs, and Digital Assets team is monitoring the developments of this topic and remains available to assist as may be necessary.