Banks, Financial Services, Fintechs and Digital Assets Newsletter – April 2025

In this edition of our monthly newsletter, we have compiled the main news and regulatory develop-ments regarding the banking industry, financial services, fintechs and digital assets. This publica-tion was designed as a reliable source of infor-mation 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 IN No. 596, of March 24, 2025

BCB Normative Instruction (“IN”) No. 596, of March 24, 2024, amends IN No. 374, of April 26, 2023, which provides for the procedures, deadlines, documents, and information necessary to instruct authorization requests relating to the operation of the Financial Market Systems (“SMFs”) within the scope of the Brazilian Payment System (“SPB”). This IN also provides for the types of changes in SMFs and the regulations posing a significant risk to their safety, efficiency, or integrity, as well as to the regular functioning of the SPB or the National Financial System (“SFN”).

BCB IN No. 596 entered into force on the date of its publication.

Read BCB Resolution No. 596 in full.

BCB IN No. 597, of March 26, 2025

BCB IN No. 597, of March 26, 2025, regulates the cycles of approval tests to be observed by authorized institutions or institutions undergoing the authorization process, by the Central Bank of Brazil (“BC”), for exercising bookkeeping, registrations, and centralized deposits of book-entry duplicates.

BCB IN No. 597 entered into force on the date of its publication.

Read BCB Resolution No. 597 in full.

BCB IN No. 606, of April 03, 2025

BCB IN No. 606, of April 03, 2025, establishes guidelines regarding the process of drafting and submitting the convention governing credit events to be used by the institutions authorized to operate by the BC in credit derivative operations contracted in Brazil or upon issuing structured transaction certificates (“COE”) in the credit risk modality, as provided for in the specific regulation of these products.

The convention must be drafted by an entity representing the credit derivatives market at the national level and must have as signatories those institutions authorized to operate by the BC that are counterparties in credit derivatives operations in Brazil or issuers of COEs in the credit risk modality.

BCB IN No. 606 entered into force on the date of its publication.

Read BCB Resolution No. 606 in full.

BCB IN No. 611, of April 22, 2025

BCB IN No. 611, of April 22, 2025, provides for the types of financial assets that can be connected to dynamic payment slips.

These are financial assets that can be connected to dynamic payment slips: (i) bills of exchange issued in book-entry form, as addressed by Law No. 13,775, of December 20, 2018; and (ii) real-estate receivables originating from purchase and sale agreements or promissory purchase and sale agreements, with or without the issuance of a Real Estate Credit Note (“CCI”), entered into between a developer or land subdivider and a purchaser or promissory purchaser of an autonomous real-estate unit or lot.

The IN also highlights the need for a timetable for implementing the dynamic payment slip for each type of financial asset, which must be agreed upon between the institution operating the settlement system in charge of the centralized base of payment slips and the institutions responsible for the asset’s bookkeeping, registration, or centralized deposit systems. The schedule must also include: (i) the list and description of the working groups in charge, including their participants; and (ii) the stages for carrying out each step.

It is worth highlighting that the timetable referred to must be submitted to the BC in compliance with the form and deadline, to be informed through an act published by the agency.

BCB IN No. 611 entered into force on April 30, 2025.

Read BCB Resolution No. 611 in full.

BCB Resolution No. 463, of April 22, 2025

BCB Resolution No. 463, of April 22, 2025, establishes the general regulations governing production tests within the scope of the Open Finance. The regulation determines that these tests must be carried out: (i) by institutions integrating the Open Finance prior to the launch of new products or services and relevant versions of application programming interfaces (“APIs”) relating to existing products or services; (ii) by institutions integrating the Open Finance that either did not join or were unsuccessful in the tests provided for in the previous item; and (iii) by new institutions integrating the Open Finance, in one or more participation modalities, in relation to the main products, services, and APIs already implemented.

The production tests apply to all participating institutions, regardless of whether participation in the Open Finance is mandatory or optional, depending on the type of participation. The BC will publish the versions that must be considered as relevant and the main products, services, and APIs that have already been implemented. If products or services cannot be contracted in a production environment, the BC can choose to determine alternative methods for carrying out production tests.

Production tests must: (i) be carried out using the validation tool developed by the Open Finance Governance Structure and among the participating institutions that already offer or will offer products and services; (ii) be restricted to a client database defined by the institutions that will participate in the tests, including the lists of clients provided by the Open Finance Governance Structure and the BC; and (iii) address the functionalities of the products or services, the client experience journeys, and the integration with the tools of the Open Finance Governance Structure, in compliance with its current regulations and documentation.

It is also worth noting that participating institutions must demonstrate to the BC that their client experience journeys comply with the current regulations and Open Finance Structure documents. These companies can submit the compliance verifications implemented by the Governance Structure. In addition, institutions must provide the Open Finance Governance Structure with instructions and access to their production testing environment.

BCB Resolution No. 463 entered into force on the date of its publication.

Read BCB Resolution No. 463 in full.

BCB Resolution No. 467, of April 30, 2025

BCB Resolution No. 467, of April 30, 2025, amends BCB Resolution No. 443, of December 12, 2024, which regulates payment arrangements involving payment slips, types of slips, issuance, display methods, and settlement methods for transfer funds.

BCB Resolution No. 467 entered into force on the date of its publication.

Read BCB Resolution No. 467 in full.

BCB Resolution No. 468, of April 30, 2025

BCB Resolution No. 468, of April 30, 2025, provides for the calculation and remittance of interest and charges accumulated in revolving credit card and invoice installment operations involving credit cards and other post-paid payment instruments.

BCB Resolution No. 468 will enter into force on July 01, 2025.

Read BCB Resolution No. 468 in full.

BCB Resolution No. 469, of April 30, 2025

BCB Resolution No. 469, of April 30, 2025, amends the regulation attached to BCB Resolution No. 304, of March 20, 2023, aimed at allowing clearing and settlement chambers and service providers to accept collateral abroad from resident investors.

BCB Resolution No. 469 entered into force on the date of its publication.

Read BCB Resolution No. 469 in full.

BCB Resolution No. 470, of April 30, 2025

BCB Resolution No. 470,  of April 30, 2025, establishes the procedures for calculating – through a standardized approach – the daily amount of the portion of risk-weighted assets (“RWA”) relating to the susceptibility of instruments subject to market risk (“RWASENS”), and amends BCB Resolutions No. 200, of March 11, 2022, No. 111, of July 06, 2021, No. 265, of November 25, 2022, and No. 313, of April 26, 2023.

BCB Resolution No. 470 entered into force on the date of its publication.

Read BCB Resolution No. 470 in full.

CMN Resolution No. 5,205, of April 17, 2025

Resolution No. 5,205 of the Brazilian National Monetary Council (“CMN”), of April 17, 2025, amends the provisions of CMN Resolution No. 5,130/2024, which addresses the financing of Eco Invest Brasil Line, within the scope of the Brazilian National Climate Change Fund (“FNMC”).

CMN Resolution No. 5,205 entered into force on the date of its publication.

Read CMN Resolution No. 5,205 in full.

CMN Resolution No. 5,206, of April 28, 2025

CMN Resolution No. 5,206, of April 28, 2025, amends Resolution No. 4,072, of April 26, 2012, which regulates the implementation – in Brazil – of branches of financial and other institutions authorized by the BC. The amendment updates Article 14 of CMN Resolution No. 4,072/2012, to establish the form, deadline, and conditions for providing information to be submitted by financial institutions to the BC regarding the implementation and location of their branches in Brazil.

CMN Resolution No. 5,206 entered into force on May 01, 2025.

Read CMN Resolution No. 5,206 in full.

CMN Resolution No. 5,207, of April 30, 2025

CMN Resolution No. 5,207, of April 30, 2025, amends CMN Resolution No. 4,958, of October 21, 2021, which provides for the calculation of the minimum requirements for Reference Equity (“PR”), Level I and Core Capital, and the Additional Core Capital (“ACP”), as well as Resolution No. 4,557, of February 23, 2017, which provides for the risk management structure, the capital management structure, and the information disclosure policy.

CMN Resolution No. 5,207 will enter into force on January 01, 2027.

Read CMN Resolution No. 5,207 in full.

NEWS

BC calls for contributions on the tokenization of digital payments

On April 04, 2025, the BC published the Social Participation Notice (“EPS”) No. 118/2025, regulating Call for Contribution No. 118/2025. The initiative seeks to gather input on the participation of token storage service providers of debit, credit, and prepaid card user data as providers of modalities addressed in payment arrangement regulations. Thus, the BC intends to collect contributions on the need to regulate these services involving digital wallets by agents such as Apple Pay, Samsung Pay, and Google Pay.

With the advance of the digitalization of payment methods and the popularization of mobile devices with NFC technology, token applicants have assumed a strategic position in the sector. This can have a significant impact on card issuers’ costs and, consequently, on the prices charged to consumers and commercial facilities. This call for contributions is intended to deepen the analysis of these effects, observing aspects such as market structure, safety, and efficiency of tokenization practices, as well as costs and possible regulatory gaps.

Call for Contribution No. 118/2025 is structured as a questionnaire addressing operational, competitive, and regulatory matters relating to tokenization service providers. Contributions can be submitted through the Participa + Brasil platform by June 02, 2025.

Read the BC article in full.

Read our client alert on this topic.

BC proposes accounting standardization for sustainability assets and liabilities through public consultation

On April 09, 2025, the BC published Public Consultation Notice (“ECP”) No. 119/2025, which addresses proposals for CMN and BC resolutions aimed at standardizing the accounting approach to assets and liabilities resulting from sustainability initiative seeking to clarify and align the information in the financial statements prepared by financial and other institutions authorized to operate by the BC.

The draft proposals define concepts and criteria for accounting for these assets and liabilities, considering the intended purpose and the institution’s business model. They also establish that the measurement of sustainability liabilities must be connected to the assets recognized in the institutions’ balance sheets. The accounting criteria adopted are based on the Technical Guidance of the Accounting Committee (“OCPC”) 10, Carbon Credits (“tCO2e”), Emission Allowances, and Decarbonization Credit (“CBIO”), published on December 16, 2024 by the CPC, and are in line with the guidelines of Resolution No. 223 of the Brazilian Securities and Exchange Commission (“CVM”), applicable to publicly traded companies.

Contributions to Public Consultation No. 119/2025 can be submitted by May 31, 2025, using the form available on the BC website or through the platform Participa + Brasil. Alternatively, suggestions can be submitted directly to denor@bcb.gov.br.

Read the BC article in full.

BC lists regulatory priorities for 2025/2026

On April 24, 2025, the BC published its list of regulatory priorities for 2025/2026 through a press conference. The topics that have already been submitted or will be submitted for study, public consultations, and/or regulations – depending on the progress of the discussions – are as follows:

1. 1. PIX;
   2. payment arrangements and financial market infrastructure;
   3. guarantee funds;
   4. Open Finance;
   5. tokenization;
   6. artificial intelligence;
   7. bank fees and fraud prevention;
   8. real estate credit;
   9. rural credit; and
   10. sustainability.

Read the BC article in full.