BC and CMN regulate nomenclature and public presentation of institutions authorized to operate by the Central Bank of Brazil

On November 28, 2025, the Central Bank of Brazil (“BC”) and the Brazilian National Monetary Council (“CMN”) issued Joint Resolution No. 17, which governs the nomenclature and the manner in which institutions authorized to operate by the BC present themselves to the public.

Key points of Joint Resolution No. 17

Purpose and scope of application

The new regulation establishes the following definitions:

• “Nomenclature”: the corporate name, trade name, brand, and Internet domain.
• “Term”: any word, word fragment, expression, or phrase, in any language, used in the nomenclature of institutions authorized to operate by the BC.
• “Presentation to the Public”: the content displayed across all communication and customer service channels of the institution authorized to operate by the BC.

Nomenclature

Institutions authorized to operate by the BC must include, in their corporate name, terms that clearly reference the scope of the authorization granted by the BC.

The use of terms suggesting activities or types of institutions for which the entity does not hold specific authorization is prohibited.

Institutions that are part of prudential conglomerates may use the conglomerate’s name in their nomenclature, provided that:

• It is clear to the client which type of institution within the conglomerate they are interacting with; and
• The conglomerate’s name does not include terms identifying or characterizing types of institutions subject to the BC’s authorization that are not part of the conglomerate.

Presentation to the Public

Institutions authorized to operate by the BC must use, in their public presentation, terms that clearly inform clients and users of the type of institution covered by the authorization granted by the BC.

Such institutions may not use terms suggesting activities or types of institutions for which they do not hold specific authorization.

However, in their public presentation:

• Institutions that are part of a prudential conglomerate can use terms that suggest the activity, the type of authorized institution, or the nomenclature of one of the institutions authorized to operate by the BC within the conglomerate;
• Prudential conglomerates can use terms or nomenclature of one of the institutions authorized to operate by the BC within the conglomerate.

In addition, the public presentation of institutions authorized to operate by the BC must clarify (including when the public presentation is made available through agreements with banking correspondents or partnerships):

• The specific activities authorized by the BC;
• The financial, virtual asset, consortium, or payment services authorized; and
• The prudential conglomerate or cooperative system to which they belong, if applicable.

Agreements and partnerships

Institutions authorized to operate by the BC cannot enter into correspondent agreements in Brazil or establish partnerships for activities related to the offering of financial and payment products and services with entities not subject to authorization by the BC that use:

• In their nomenclature, terms that identify or characterize types of institutions subject to authorization by the BC; and
• In their public presentation, terms that do not clearly indicate to clients and users their status as a contracted entity or partner of the institution authorized to operate by the BC.

Institutions authorized to operate by the BC must adopt measures to adjust correspondent agreements or partnerships entered into before November 28, 2025, based on the above requirements within one year from November 28, 2025.

Exceptions to the prohibition:

• Agreements or partnerships entered into with entities promoting microcredit under the legislation governing the National Program for Productive Microcredit (“PNMPO”) and initiatives related to solidarity economy and the National Solidarity Economy Policy; and
• Agreements related to ancillary or operational services that enable the offering of financial and payment products and services, such as information technology, infrastructure, logistics, and outsourced ATM network services.

Compliance plan

Institutions authorized to operate by the BC must assess compliance with Joint Resolution No. 17 and prepare a compliance plan for those that are not compliant. This compliance plan must:

• Include, at least, the procedures and steps to be adopted, as well as a maximum period of one year for the institution to comply with Joint Resolution No. 17, based on the complexity of the adjustments; and
• Be prepared and submitted to the BC within 120 days from the date the resolution takes effect.

The compliance plan is not required and does not apply:

• If the adjustment involves only the change of the corporate name; and
• To the adjustment of correspondent agreements in Brazil or partnerships.

Institutions that are already in compliance with Joint Resolution No. 17 or whose adjustment involves only the change of the corporate name must notify the BC of this condition within 90 days from the date the resolution takes effect, in compliance with specific regulations.

If changing the corporate name is the only adjustment required for compliance with Joint Resolution No. 17, it must:

• Be carried out within one year from November 28, 2025; and
• Be communicated to the BC within 90 days after its implementation.

Finally, amendments to the bylaws or articles of incorporation are authorized if they entail exclusively the change of the institution’s corporate name for complying with Joint Resolution No. 17.

Final provisions

• Except for the provisions described above regarding the compliance plan, all other rules also apply to authorization requests already filed with the BC. The BC may issue regulations and adopt measures necessary to implement the provisions of Joint Resolution No. 17.
• Article 8 of CMN Resolution No. 4,935, dated July 29, 2021, is hereby repealed.
• Joint Resolution No. 17 came into force on the date of its publication.

Demarest’s Banking and Finance team is monitoring this topic and remains available to assist clients and partners as necessary.