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Banking, Financial Services, Fintechs, and Digital Assets Newsletter – January 2026
January 19th, 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!
Central Bank of Brazil
BCB Resolution No. 547, dated January 30, 2026
Amends BCB Resolution No. 498, of September 05, 2025, which regulates, within the scope of the National Financial System and the Brazilian Payment System, the requirements, procedures, and conditions for the accreditation of Information Technology Service Providers (“PSTI”).
BCB Resolution No. 547 entered into force on the date of its publication.
Read BCB Resolution No. 547 in full.
BCB Normative Instruction (“IN”) No. 703, dated January 28, 2026
Amends BCB Instruction No. 511, of August 30, 2024, which establishes the procedures required for adherence to the Pix system, to incorporate provisions regarding evidence of share capital and net worth, and to amend provisions relating to the value‑recovery testing.
BCB IN No. 703 entered into force on the date of its publication.
BCB IN No. 705, dated January 29, 2026
Amends BCB IN No. 103, of April 30, 2021, and BCB IN No. 299, of August 30, 2022, which provides for:
- (i) Changes to the procedures for submitting authorization requests for payment institutions to operate in the foreign exchange market (BCB IN No. 103) and for the institutions governed by CMN Resolution No. 4,970, of November 25, 2021 (BCB IN No. 299); and
- (ii) The removal of references to foreign exchange brokerages, securities brokerage firms (“CTVMs”), and securities distribution firms (“DTVMs”), as provided for in BCB IN No. 299, of 2022.
BCB IN No. 705 entered into force on February 02, 2026.
BCB IN No. 707, dated January 29, 2026
Provides for the conditions to be observed in the contracting of real estate credit transactions that share the same real estate as collateral.
To comply with the rules governing the credit quota limits applicable to the real estate credit transactions listed in Article 6 of Resolution No. 4,676, of 2018, financial institutions and other entities authorized to operate by the Central Bank of Brazil (“BC”) must:
- Comply with Article 6, paragraph 2, of Resolution No. 4,676, of 2018, in view of the extension of the fiduciary lien or mortgage, the fiduciary lien over subsequently acquired real estate, and the establishment of subordinated‑priority mortgages, when related to transactions entered into by individuals secured by residential real estate;
- Use the value of the real estate pledged as collateral as determined on the date of contracting each credit transaction, based on an appraisal or reappraisal conducted in compliance with applicable regulations; and
- Consider the credit quota limit established in Art. 6, main section, item II, of Resolution No. 4,676, of 2018, in force on the date of contracting the new credit transaction, in the event of transactions that share the same real estate as collateral.
In addition, to comply with Article 22-B of Resolution 4,676 of 2018, financial institutions and other entities authorized to operate by the BC must:
- Consider the remaining term of the original credit transaction – as verified on the date of contracting the new transaction – as the maximum term for contracting new credit transactions;
- Consider that the sum of the nominal value of the new transaction and the outstanding balances of the transactions already secured must be less than or equal to the nominal value of the original credit transaction on the date it was contracted. The credit quota limit established in Art. 6, main section, item II, of Resolution No. 4,676, of 2018, must also be observed.
BCB IN No. 707 entered into force on the date of its publication.
Brazilian National Monetary Council
CMN Resolution No. 5,279, dated January 22, 2026
Amends Annexes I and II of Resolution No. 4,222, of May 23, 2013, which address, respectively, the Bylaws and Regulations of the Credit Guarantee Fund (“FGC”), to improve the governance of the FGC and the protection of depositors.
CMN Resolution No. 5,279 entered into force on the date of its publication.
Read CMN Resolution No. 5,279 in full.
Credit portability can be conducted through Open Finance
Increasingly used by Brazilian society, Open Finance continues its steady process of evolution. Recently, the BC and the National Monetary Council (“CMN”) issued Joint Resolution No. 15 and CMN Resolution No. 5,265/2025, which address the portability of credit transactions within this ecosystem.
The regulations maintain the current credit portability process, conducted through an electronic system for the exchange of information, governed by CMN Resolution No. 5,057, of 2022. The new development is that users of the financial system will now have an additional alternative for transferring their credit transactions: Open Finance.
Credit portability through Open Finance will provide greater efficiency in accessing and exchanging information, which may be shared digitally in a secure, fast, and standardized manner, thereby eliminating information asymmetries and operational barriers and enabling a more automated and optimized process. At the same time, this modality will offer an improved customer experience, as the customer journey becomes fully digital, initiated by clients on their smartphones, without the need to gather documents or visit branches and service points. The process also becomes more transparent, as clients will be able to track the progress of their requests through their institution’s app.
BC publishes information report on virtual asset services in the foreign exchange market
On December 19, 2025, the BC published IN No. 693, which establishes the procedures for submitting information on the provision of virtual asset services in the foreign exchange market to the BC, as referred to in BCB Resolution No. 521, of November 10, 2025.
The regulation defines the procedures for submitting data on transactions with virtual assets in the foreign exchange market, including the following activities or transactions:
- International payments or transfers conducted through virtual assets;
- Loading/unloading virtual assets onto cards or electronic payment instruments for international use;
- Transfers of virtual assets to or from a self-custodied wallets, not involving payments or international transfers with virtual assets; and
- Monthly total of purchases, sales, and exchanges of fiat‑referenced virtual assets.
Read our client alert on this topic.
Registration of Five‑Year Periodic Statement with BC – Base date of December 31, 2025
By March 31, 2026, Brazilian companies receiving foreign direct investment in their share capital, in any amount, and that have recorded total assets equal to or exceeding BRL 100,000, must submit their Five‑Year Periodic Statement (“DPQ”) to the BC, referring to the base date of December 31, 2025.
The DPQ replaces the Annual Statement and the Census of Foreign Capital in Brazil. The DPQ serves for statistical purposes and assists the BC in generating data to support economic research and programs. It is worth noting that the BC must treat the data provided as confidential.
This submission is one of the obligations applicable to Brazilian entities that receive foreign direct investments, and any omission or delay to comply with such obligation may trigger the application of penalties by the BC.
Read our client alert on this topic.
BC publishes information required for processing authorization requests of VASPs
On January 29, 2026, the BC issued Normative Instruction No. 704, which establishes the procedures, documents, deadlines, and information required for processing authorization requests for the operation of foreign exchange brokerage firms, CTVMs, DTVMs, and virtual asset service providers (“VASPs”, or “SPSAVs” in the Portuguese acronym).
IN No. 704 addresses the requirements for authorization requests involving:
- The operation of foreign exchange brokerages, CTVMs, DTVMs, and VASPs that are not currently active;
- The operation of VASPs that are currently active;
- The change in the VASP operating modality;
- Authorization for transfer or change of control;
- Authorization for merger, spin‑off, or consolidation;
- Authorization for corporate restructuring;
- Authorization for the appointment and taking office of individuals elected or appointed to management positions;
- Authorization for changes in share capital;
- Authorization for changes in corporate name;
- Authorization for changes in corporate purpose;
- Cancellation of authorization to operate;
- Authorization and cancellation of authorization to operate in the foreign exchange market;
- Authorization to extinguish the audit committee;
- Notification regarding the assumption of the status of qualified shareholder;
- Notification regarding changes in the structure of management positions; and
- Notification regarding capital increases arising from retained earnings, capital reserves, and profits or credits to shareholders.
Read our client alert on this topic.
CMN resolution amends rules on investment of RPPS funds
On December 18, 2025, the CMN published CMN Resolution No. 5,272, which provides for the investment of funds from the Special Social Security Scheme for Public Servants (“RPPS”) established by the Federal Government, the states, the Federal District, and the cities to ensure the payment of social security benefits to public servants.
The new regulation repeals and replaces CMN Resolution No. 4,963 of November 25, 2021, introducing significant changes to the rules governing the investment of RPPS funds.
The regulatory revision aligned the rules applicable to the RPPS with the regulatory framework for investment funds introduced by Brazilian Securities Commission (“CVM”) Resolution No. 175, of December 23, 2022, as amended. Additionally, the measure encourages the strengthening of governance and management practices and further reduces the concentration of RPPS investments in certain segments and assets – including those issued by financial institutions –, with the aim of increasing the protection of beneficiaries and ensuring the sustainability of pension schemes.
Among the main changes, a key highlight is the requirement that the classes of investment funds eligible for investment by RPPS expressly establish, in their bylaws, the limitation of the quota holder’s liability to the amount subscribed.
In addition, CMN Resolution No. 5,272 updates concepts and definitions, including in relation to investment abroad and the corresponding suffixes previously required. The regulation also revised the terminology to align the vocabulary with that adopted by CVM Resolution No. 175.
The regulation also expressly introduces assets provided for in CVM Resolution No. 175, such as Decarbonization Credits (“CBIOs”), expanding the list of eligible instruments and harmonizing the regulatory treatment of these assets within the scope of investments by RPPS.
Read our client alert on this topic.
BC issues new normative instruction on virtual asset service certification
On January 22, 2026, the BC issued Normative Instruction No. 701, which establishes the communication procedures and the minimum requirements to be observed in the preparation – by an independent qualified firm – of the technical certification that must accompany the notification of interest in providing virtual asset services in Brazil, in compliance with BCB Resolution No. 520, of November 10, 2025.
BCB Normative Instruction No. 701 establishes the guidelines for the independent certification required for virtual asset service providers to obtain authorization to operate. The measure seeks to align the authorization process with clear technical standards, contributing to greater transparency and regulatory certainty.
With this initiative, the BC is strengthening the regulatory framework for the virtual asset sector, aligning Brazil’s practices with those adopted in other markets. The aim is to create conditions for the segment to develop in an organized manner and in line with the stability of the financial system.
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