Banks, Financial Services, Fintechs and Digital Assets Newsletter – October 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 Normative Instruction No. 675, dated October 14, 2025

BCB Normative Instruction (“IN”) No. 675, dated October 14, 2025, publicizes the procedures governed by Resolution No. 188, dated February 23, 2022, of the Central Bank of Brazil (“BC”). The resolution defines and consolidates the reserve requirement rules applied to savings deposit funds.

BCB IN No. 675 entered into force on the date of its publication.

Read BCB IN No. 675 in full.

BCB IN No. 677, dated October 29, 2025

BCB Normative Instruction No. 677, dated October 29, 2025, provides clarifications and defines procedures regarding BCB Resolution No. 188, dated February 23, 2022, which defines and consolidates reserve requirement rules applied to savings deposit funds.

BCB IN No. 677 entered into force on the date of its publication.

Read BCB IN No. 677 in full.

BCB IN No. 679, dated October 30, 2025

BCB Normative Instruction No. 679, dated October 30, 2025, amends BCB Normative Instruction No. 511, dated August 30, 2024, which sets maximum limits for Pix transactions. BCB Normative Instruction No. 679 updates provisions relating to the Special Refund Mechanism, to post-registration pending issues, and to the signing of documents associated with the Pix adhesion procedure.

BCB IN No. 679 entered into force on the date of its publication.

Read BCB IN No. 679 in full.

BCB Resolution No. 512, dated October 10, 2025

BCB Resolution No. 512, dated October 10, 2025, amends BCB Resolution No. 188/2022, which provides for reserve requirements on savings deposit funds. Primarily, the update enables financial institutions to deduct the nominal value of real estate credit transactions contracted for the purpose of calculating the reserve requirement levied on demand savings deposits.

1. Authorized deduction:

• Financial institutions may deduct the nominal value of real estate credit transactions from the reserve requirement amount.
• This deduction is limited to 5% of the calculation basis throughout the calculation period between December 28, 2026, and December 31, 2026.
• Starting in January 2027, the limit will be increased by 1.5 percentage points per year, with annual increments.

2. Conditions for deduction:

• Only real estate credit transactions contracted on or after October 13, 2025, will be considered.
• These transactions must comply with the parameters established in CMN Resolution No. 5,255/2025.
• The transactions cannot have been used to comply with the mandatory allocation of savings funds, in accordance with Resolution No. 4,676/2018.

BCB Resolution No. 512 entered into force on the date of its publication.

Read BCB Resolution No. 512 in full.

BCB Resolution No. 513, dated October 21, 2025

BCB Resolution No. 513, dated October 21, 2025, provides for the accounting concepts and criteria applicable to the measurement, recognition, write-off, and disclosure of sustainability assets and liabilities. The resolution applies to consortium administrators, payment institutions, brokerage firms, securities distributors, and foreign exchange brokerage firms authorized to operate by the BC. The regulation also establishes disclosure procedures through explanatory notes and additional information related to sustainability assets and liabilities. Financial institutions and other institutions authorized to operate by the BC must comply with these procedures.

BCB Resolution No. 513 will enter into force on January 01, 2027.

Read BCB Resolution No. 513 in full.

BCB Resolution No. 514, dated October 21, 2025

BCB Resolution No. 514, dated October 21, 2025, amends BCB Resolution No. 264, dated November 25, 2022, which provides for the registration of receivables from transactions within the scope of payment schemes based on post-paid accounts and demand deposit arrangements that are part of the Brazilian Payments System. The regulation introduces new procedures related to the cancellation of pre-contracted advance transactions; to the requirement to use, for reconciliation purposes, the information made available to registration systems by centralized settlement systems; and adjustments to provisions that address tariffs and the review of the merits of the agreement.

BCB Resolution No. 514 will enter into force:

I – On May 11, 2026 (amendment to Article 11, Paragraph 3, of BCB Resolution No. 264, dated November 25, 2022); and

II – On January 5, 2026 (amendment to the remaining provisions).

Read BCB Resolution No. 514 in full.

BCB Resolution No. 515, dated October 21, 2025

BCB Resolution No. 515, dated October 21, 2025, amends BCB Resolution No. 443, dated December 12, 2024, which provides for the use of boletos (bank-issued invoices), their issuance and means of presentation. Furthermore, the resolution governs the settlement of associated fund transfers.

BCB Resolution No. 515 entered into force on the date of its publication.

Read BCB Resolution No. 515 in full.

National Monetary Council

CMN Resolution No. 5,255, dated October 10, 2025

On December 19, 2025, the National Monetary Council (“CMN”) published Resolution No. 5,255, amending Resolution No. 4,676, dated July 31, 2018, which provides for members of the Brazilian Savings and Loan System (“SBPE”), the Housing Finance System (“SFH”), and the Real Estate Financing System (“SFI”). In addition, the resolution provides for the general conditions and criteria for the contracting of real estate credit transactions by financial institutions and other institutions authorized to operate by the BC. The resolution also regulates the allocation of funds raised in savings deposits.

CMN Resolution No. 5,255 will enter into force:

I – On the date of its publication, in relation to Article 2, in the part that amends Article 13 of Resolution No. 4,676, of July 31, 2018);

II – On January 1, 2026, in relation to (a) Article 2, in the part that amends the following provisions of Resolution No. 4,676, dated July 31, 2018: Article 5; Article 6; articles 25-C to 25-F; and Article 26-A, and (b) Article 3, head paragraph, item I); and

III – On January 01, 2027, in relation to the remaining provisions.

Read CMN Resolution No. 5,255 in full.

CMN Resolution No. 5,256, dated October 10, 2025

CMN Resolution No. 5,256, dated October 10, 2025, provides for financing supported by the National Social Infrastructure Investment Fund (“FIIS”).

It regulates Article 7 of Decree No. 12,157, dated August 29, 2024, regarding the conditions applicable to financing with repayable funds from FIIS – which must comply with the purposes of application provided for in Law No. 14,947, dated August 2, 2024 – as well as the guidelines and priorities defined by the FIIS Management Committee, in accordance with the provisions of Article 2 of Decree No. 12,157, dated August 29, 2024.

Read CMN Resolution No. 5,256 in full.

CMN Resolution No. 5,259, dated October 23, 2025

CMN Resolution No. 5,259, dated October 23, 2025, consolidates the general criteria for developing the Cooperative System Balance Sheet and the Combined Statements of the Cooperative System, the submission of the Combined Balance Sheet of the Cooperative System, and the disclosure of the Combined Statements of the Cooperative System.

The Cooperative System Balance Sheet and the Combined Statements of the Cooperative System must be based on financial information from member institutions of the cooperative system to which they refer, as if that system represented a single economic entity, and they must include:

(i) Cooperative banks, credit confederations, service confederations service confederations consisting of central credit unions, central credit unions, and individual credit unions participating in the same cooperative system;

(ii) Entities authorized by the BC that are directly or indirectly linked to the institutions mentioned in item I through shareholding, effective operational control (common administration or management), or collective and coordinated action in the market;

(iii) Investment funds in which institutions belonging to the cooperative system substantially assume or retain risks and benefits in any form;

(iv) Payment institutions not authorized by the BC that are directly or indirectly linked to the institutions mentioned in item I through shareholding, effective operational control (common administration or management), or collective and coordinated action in the market;

(v) Voluntary cooperative guarantee funds exclusive to the cooperative system itself;

(vi) Entities that contract credit transactions, including real estate, or credit rights, such as trade development companies, securitization companies, and special purpose entities; and

(vii) Other legal entities whose sole corporate purpose is to hold equity interests in the entities mentioned in items (i) to (vi).

CMN Resolution No. 5,259 will enter into force on January 01, 2026.

Read CMN Resolution No. 5,259 in full.

NEWS

CVM opens public consultation to improve electronic crowdfunding platform regulations

The Brazilian Securities and Exchange Commission (“CVM”) opened Public Consultation SDM No. 05/2025 to discuss the reform of CVM Resolution No. 88, of April 27, 2022, which regulates the public offering of securities through crowdfunding platforms. The proposal aims to widen the scope of eligible issuers, update funding and investment limits, and align informational and operational requirements with the current market, including the securitization and agribusiness sectors.

Interested parties can submit contributions by December 23, 2025, to the Market Development Superintendence (SDM) at conpublicasdm0525@cvm.gov.br.

Public Consultation Notice SDM No. 05/2025 is available on the CVM website.

Read our client alert on this topic.

Public consultation proposes new eFX rules

The BC opened Public Consultation No. 124/2025 to gather contributions from society aimed at improving regulations on the international payment and transfer service known as eFX. The initiative is part of BC’s agenda to modernize the Brazilian financial system and seeks to align regulation with international best practices.

The proposal limits the provision of eFX services to institutions authorized to operate by the BC. Providers currently operating without authorization will have a set period to apply for accreditation as a payment institution. In addition, institutions interested in acting as eFX providers must notify the BC in advance.

Public Consultation No. 124/2025 was open for contributions until November 2, 2025, exclusively through the channels indicated on the BC website and the Participa + Brasil website. Public participation is deemed essential for improving the proposal and securing a more inclusive and innovative regulatory environment.

Read the BC article in full.

Read our client alert on this topic.

BC opens public consultation on settlement cycle deadlines

On October 1, 2025, the Central Bank opened a public consultation through Social Participation Notice (EPS) No. 125/2025 to obtain contributions regarding the cost and benefit assessment of a potential decrease in settlement cycle terms for transactions related to financial instruments within the SPB.

The BC is seeking the input of participants of the affected markets regarding any points of attention relating to the regulatory framework, in order to ensure a more accurate assessment capable of making the SPB more solid and efficient. The public consultation also seeks to align Brazilian markets with international best practices that are already effective or under consideration by relevant financial jurisdictions.

A reduction in settlement cycles would have the potential to mitigate exposure to credit and liquidity risks, and to ease collateral and margin requirements. These advances could be achieved without compromising the security of clearing and settlement service providers and chambers. However, implementing this change would require improved efficiency in post-trade procedures, which could entail additional operating costs and temporarily increase the risk of settlement failures.

Contributions on Public Consultation No. 125/2025 can be submitted by December 30, 2025, using the form available on BC’s website or on the Participa + Brasil website.

Read our client alert on this topic.

National Treasury publishes ordinance for the 3rd Eco Invest Brazil Auction to attract private equity investment in ecological transformation projects

On October 13, 2025, the National Treasury Secretariat (“STN”) published Ordinance STN/MF No. 2,302/2025, which regulates Eco Invest Brazil Auction No. 3/2025 to attract domestic and foreign investments through equity instruments in strategic sectors such as energy transition, bioeconomy, circular economy, and infrastructure for climate change adaptation. The measure seeks to contribute directly to the achievement of the UN Sustainable Development Goals and decarbonization targets.

The ordinance sets rules and conditions for financial institutions to access the funds from Auction No. 3/2025, as well as the eligibility and prioritization criteria for supported projects.

Proposals must be submitted with pre-allocation reports to the STN by 6 p.m. on November 19, 2025, at leilaoecoinvest@tesouro.gov.br. The results will be ratified and announced within 20 days of the submission deadline.

Read our client alert on this topic.

Read STN/MF Ordinance No. 2,302/ 2,302 in full.

BC includes sustainable securities in international capital reporting requirements

On October 1, 2025, BCB Resolution No. 492, dated August 14, 2025, entered into force, amending BCB Resolution No. 278, dated December 31, 2022, and BCB Resolution No. 279, dated December 31, 2022. The resolution includes the category of sustainable securities in the following events:

• Reporting of foreign capital information in the Foreign Capital Reporting System for External Credit (SCE-Crédito); and
• Declaration of Brazilian capital abroad (DCBE).

According to the BC, information on external credit transactions via sustainable securities is essential for establishing the statistical basis for climate finance. It also contributes to monitoring and managing climate and socio-environmental risks. The initiative marks a step forward in the BC’s environmental, climate, social, and governance agenda, and brings Brazil in line with the G20’s international guidelines on climate finance.

Read our client alert on this topic.

Read BCB Resolution No. 492 in full

Demarest Advogados joins ABcripto and solidifies market presence

Demarest Advogados is the newest member of the Brazilian Crypto economy Association (ABcripto). As a result, the firm has joined the primary representative of the digital assets sector in Brazil at a time of expansion and maturation within the crypto economy.

Demarest’s crypto assets and digital assets practice has been consolidated with the technical monitoring of topics such as tokenization, Drex, Open Finance, and exchange regulation, in addition to legal advice on structured transactions involving virtual assets and blockchain.

According to Marcus Fonseca, partner at Demarest and digital asset regulation specialist:

“Joining ABcripto is a natural step in our journey of legal innovation. It reiterates our commitment to collaborate in building a solid and innovative digital assets regulatory environment in Brazil. Cooperation between key players in the ecosystem is essential to solidify trust, transparency, and sustainable growth in the crypto economy.

Bernardo Srur, CEO of ABcripto, Demarest’s admission strengthens the sector’s representation with regulators and the market: “Demarest becoming a member is a milestone for the ecosystem.”

Read the full article on Migalhas.

BC launches consultation on simplified liquidity indicator and scope expansion of the Short-Term Liquidity indicator

The BC conducted Public Consultation No. 123/2025 to receive contributions on the creation of the Simplified Short-Term Liquidity Ratio (LCRS) indicator and the expansion of the scope of application of the Short-Term Liquidity Ratio (LCR) indicator.

The proposal seeks to strengthen financial institutions’ capacity to maintain liquid asset reserves to overcome liquidity shortage scenarios, ensuring compliance with obligations, continuity of operations, and stability within the national financial system.

Under the proposed framework, the LCRS would apply to groups composed of at least one financial institution under Segments 3 or 4 that raise funds from the public through deposits or securities. In turn, the LCR would also be required for Segment 2 institutions, as is required of Segment 1 institutions.

The public consultation was open until November 1, 2025, for contributions via BC’s website or the Participa + Brasil website. All contributions will be made available to the public.

Read the full article on BC’s website.