Banco Central do Brasil published Resolutions 519, 520 and 521 on 10 November 2025. Resolution 520 entered into force on 2 February 2026, opening a 270-day window for institutions already providing virtual asset services to bring themselves into the new regime.
Applications close on 29 October. There is no late window.
From 30 October, institutions supervised by the BCB are prohibited from conducting or facilitating virtual asset operations with counterparties that provide VASP services without BCB authorisation, or without being in the authorisation process. The prohibition covers intermediation, custody, foreign exchange involving virtual assets and payment accounts.
Resolution 521 brings virtual asset operations involving currency conversion, international remittance and stablecoin settlement under the same foreign exchange rules that apply to traditional transactions.
For treasury and câmbio teams, the practical work is counterparty mapping. Which participants in your operational chain hold authorisation, which are in process, and which have done neither. That question is better answered in October than in November.
