Brazil's Crypto Deadlines Cover Different Obligations

Brazil's crypto licensing timetable contains two different obligations. Existing providers faced a deadline for application documents on 30th October 2026. A separate restriction starts on 6th November, governing operations that banks, payment institutions and other regulated institutions conduct or enable with unauthorised crypto providers.

The earlier date appears explicitly in Article 9 of the Banco Central do Brasil's Instruction 704. It requires the first phase of an authorisation application to be supported by the specified documents by 30th October. The listed material includes a declaration that the institution was operating when the relevant resolutions entered into force. That is a requirement within the route for existing businesses seeking permission to operate.

Resolution 520's Article 88 gives qualifying existing providers 270 days from the resolution's commencement to request authorisation. Its first paragraph connects the end of their adjustment period to the central bank's decision on the application's first phase. The procedure therefore distinguishes submitting a request from the regulator deciding it.

Article 88 also distinguishes timely applicants from businesses that miss the deadline. Paragraph 6 permits timely applicants to maintain services until their authorisation process concludes, while barring them from assuming another service category during that period. Paragraph 7 requires those that fail to apply on time to cease services within 30 days after the application period ends. Those provisions address the provider's own services, rather than deciding every question about its banking access.

Our global crypto-regulation guide explains why an application, registration and authorisation can describe different statuses.

A restriction on regulated counterparties

The later date comes from Resolution 589, dated 23rd September 2026. It amended Article 91 of Resolution 520, moving the restriction's starting date from 30th October to 6th November. The amendment itself took effect on 1st October. Neither date represents a new rule enacted on 30th October.

Article 91's addressees are financial institutions, payment institutions and other institutions authorised by the central bank. It bars them from carrying out or enabling virtual asset operations with provider counterparties that lack authorisation, except through arrangements expressly permitted in the resolution. That exception remains part of the amended text.

The restriction reaches beyond a bank executing a crypto trade. Article 91's following paragraph includes custody, meaning safekeeping of assets, foreign exchange, payment accounts and payment transactions when those services enable the covered operations. Its mechanism can therefore concern access to financial services used by a provider, rather than only the provider's own trading activity.

The amendment also removed the earlier wording referring to providers in the authorisation process. The retained exceptions mean that change alone cannot establish that every pending applicant must lose banking access.

For international monitoring of national crypto standards, see our report on FATF’s targeted review.

Resolution 589 separates these restrictions from its reporting amendments, which take effect on 1st January 2027. Those amendments concern information including client balances, assets held in custody, reserves and assets committed to transaction validation through staking. Resolution 520 defines staking as allowing a provider to lock assets for participation in transaction validation, with the possibility of a reward.