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Brazil’s regulatory turn
March 2026
Juan Andres Dudier Mendoza, head of product, digital asset stablecoin at Apex Group, examines how Brazil has built Latin America’s most comprehensive digital-asset regime, setting a new benchmark for operational, custody, and FX oversight in the region
Image: Apex Group
Brazil enters 2026 with what is now the most advanced and fully-implemented digital asset regulatory framework in Latin America. While much of the region is still tied up in long consultation cycles or early‑stage rule drafting, Brazil has pushed ahead with a complete regime that covers licensing, operational requirements and the treatment of stablecoin flows. Between mid‑2024 and mid‑2025, the country moved more than US$318.8 billion in crypto value, and stablecoins represented close to 90 per cent of that activity. These tokens are now deeply embedded in everyday financial behaviour in Brazil, from trading to cross‑border payments, and policymakers have chosen to bring this market into the formal financial system with clear supervision, stronger controls and alignment with the FX rules. The intention is to regulate stablecoins in line with how widely people already use them in the country.
Brazil’s three resolutions define the structure: resolution 519 establishes a licensing perimeter for virtual-asset service providers; resolution 520 sets operational and custody standards aligned with financial-sector expectations; resolution 521 places fiat-referenced token flows inside the FX regime. The rules began taking effect on 2 February 2026, with selected reporting requirements starting 4 May 2026, and a transition period ending 30 October 2026. The phased rollout gives credible operators time to prepare while preventing remote-only platforms from serving Brazilian users without local accountability.
A new licensing perimeter
Resolution 519 requires any entity that intermediates, custodies, or brokers virtual-asset activity for Brazilian users to be authorised as a Specialized Virtual Asset Service Provider (SPSAV), the licensing category created under the rule. Minimum capital requirements range from 10.8 million to 37.2 million Brazilian reais (US$2-7.2 million) depending on activity. Operators must demonstrate anti-money laundering (AML) and Countering the Financial of Terrorism (CFT) controls, segregation of client assets, and governance that functions reliably in production. This naturally concentrates the market around firms able to operate under supervisory expectations and encourages foreign providers to establish local presence or credible partnerships.
Operational standards at financial-sector level
Resolution 520 shifts the focus to daily operations. Identity and access controls must extend to vendors and any onchain functions. Incident-response procedures must be documented and tested.
Continuity frameworks must cover both traditional infrastructure and digital-asset-specific components including key management, MPC providers and oracle dependencies. Smart-contract logic is treated as part of the operational-risk perimeter. If a service depends on code, operators must show evidence of testing, change approval and real-time monitoring. Custody processes must be transparent, segregated and independently assured.
Stablecoins inside FX supervision
Resolution 521 brings fiat‑referenced token transfers into the FX framework. Transfers facilitated by licensed operators are now FX operations. This requires standardised purpose coding, counterparty verification, and monthly submissions to the central bank. Obligations attach to the intermediary, not the issuer. When a counterparty cannot be verified as licensed or FX‑authorised in Brazil, transfers are capped at US$100,000 per transaction. This cap applies only to authorisation within Brazil’s regulatory perimeter, and foreign licensing does not substitute for local approval.
The cap acts as a guardrail, ensuring visibility into cross‑border flows while allowing legitimate commercial activity to continue without shutting down stablecoin‑based corridors entirely.
Implications for market participants
Exchanges and brokers must meet SPSAV requirements and demonstrate segregation, sanctions compliance, market-integrity controls and governance for any smart-contract functions. Custodians must maintain dual-control key management, reconciliations and independent assurance.
Payment companies supporting stablecoin settlement must build verification steps and FX-reporting pipelines. Banks and corporates can incorporate stablecoin flows into existing risk and reconciliation frameworks. Overseas platforms must obtain authorisation or partner with a licensed SPSAV.
The regional context
Across the rest of Latin America, regulatory development remains fragmented and at early or transitional stages. Several jurisdictions — including Mexico, Colombia, Chile, Peru, and Argentina — have partial frameworks, sector‑specific guidance, or ongoing consultations, but none have a fully-implemented regime covering both service providers and stablecoin flows.
As a result, Brazil now stands as the region’s only jurisdiction with a comprehensive and enforceable digital‑asset framework.
A key factor behind Brazil’s regulatory acceleration is the central bank’s longstanding view that digital assets must be supervised through the same operational lens applied to financial market infrastructures.
Unlike many jurisdictions in the region, where crypto regulation is still approached primarily as a consumer protection or taxation issue, Brazil has treated digital‑asset activity as a structural component of payments, FX, and financial stability. This mindset was shaped by the country’s experience with PIX, open finance and its modernised instant‑payments infrastructure, which demonstrated the value of regulating emerging technologies through a combination of operational standards and market‑wide interoperability.
The new digital‑asset regime extends that philosophy: rather than imposing prescriptive rules on innovators, the central bank emphasises verifiable controls, responsible intermediation, traceable flows, and alignment with existing supervisory frameworks.
This approach explains why Brazil has moved faster than its regional peers and why its model is increasingly viewed as a template for other emerging markets facing rapid retail adoption of stablecoins.
Brazil in the global context
When comparing Brazil to other major jurisdictions, a clear pattern emerges. Europe’s Markets in Crypto‑Assets Regulation (MiCA) governs both issuers and service providers across the EU. It establishes requirements for issuance, custody, trading platforms, and consumer protection, forming the backbone of the region’s digital‑asset framework. The United States, through the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, focuses more narrowly on payment stablecoin issuers and the conditions under which those tokens can be offered. The UAE and Hong Kong follow models that combine supervision of service providers with specific rules for fiat‑referenced stablecoins.
Brazil takes a different path. Rather than centering regulation on how tokens are issued or how reserves are structured, Brazil focuses on the firms that actually serve users. The SPSAV licensing regime and the operational standards that follow place responsibility squarely on intermediaries. These are the entities that custody assets, run infrastructure, process transfers, and manage the operational risks that arise when value moves.
Stablecoins make this distinction most visible. In most major jurisdictions, regulators focus primarily on the token itself: how it is backed, how it is redeemed, and what issuers must disclose. Brazil instead focuses on how the stablecoin moves through the financial system. That includes verifying counterparties, recording flows and reporting cross‑border movement through the FX regime.
Crucially, the US$100,000 cap applies whenever the counterparty is not licensed or FX‑authorised in Brazil. No equivalent per‑transaction limit exists in the leading frameworks in Europe, the United States, the UAE, or Hong Kong.
This makes Brazil’s approach to supervising stablecoin flows fundamentally different in both design and effect.
The practical takeaway for global firms is straightforward. Other jurisdictions place most of their rules on the stablecoin as a product. Brazil places them on the activity around it. Any firm that wants to operate across these markets must be prepared to handle both approaches at the same time.
By focusing supervision on intermediaries and the movement of value, Brazil has created a framework that fits how digital assets are actually used in the country.
It does not replace the issuer‑based models abroad; instead, it sits alongside them as a distinct and increasingly important approach.
As stablecoin use continues to expand internationally, this difference will matter for any global operator.
Brazil’s three resolutions define the structure: resolution 519 establishes a licensing perimeter for virtual-asset service providers; resolution 520 sets operational and custody standards aligned with financial-sector expectations; resolution 521 places fiat-referenced token flows inside the FX regime. The rules began taking effect on 2 February 2026, with selected reporting requirements starting 4 May 2026, and a transition period ending 30 October 2026. The phased rollout gives credible operators time to prepare while preventing remote-only platforms from serving Brazilian users without local accountability.
A new licensing perimeter
Resolution 519 requires any entity that intermediates, custodies, or brokers virtual-asset activity for Brazilian users to be authorised as a Specialized Virtual Asset Service Provider (SPSAV), the licensing category created under the rule. Minimum capital requirements range from 10.8 million to 37.2 million Brazilian reais (US$2-7.2 million) depending on activity. Operators must demonstrate anti-money laundering (AML) and Countering the Financial of Terrorism (CFT) controls, segregation of client assets, and governance that functions reliably in production. This naturally concentrates the market around firms able to operate under supervisory expectations and encourages foreign providers to establish local presence or credible partnerships.
Operational standards at financial-sector level
Resolution 520 shifts the focus to daily operations. Identity and access controls must extend to vendors and any onchain functions. Incident-response procedures must be documented and tested.
Continuity frameworks must cover both traditional infrastructure and digital-asset-specific components including key management, MPC providers and oracle dependencies. Smart-contract logic is treated as part of the operational-risk perimeter. If a service depends on code, operators must show evidence of testing, change approval and real-time monitoring. Custody processes must be transparent, segregated and independently assured.
Stablecoins inside FX supervision
Resolution 521 brings fiat‑referenced token transfers into the FX framework. Transfers facilitated by licensed operators are now FX operations. This requires standardised purpose coding, counterparty verification, and monthly submissions to the central bank. Obligations attach to the intermediary, not the issuer. When a counterparty cannot be verified as licensed or FX‑authorised in Brazil, transfers are capped at US$100,000 per transaction. This cap applies only to authorisation within Brazil’s regulatory perimeter, and foreign licensing does not substitute for local approval.
The cap acts as a guardrail, ensuring visibility into cross‑border flows while allowing legitimate commercial activity to continue without shutting down stablecoin‑based corridors entirely.
Implications for market participants
Exchanges and brokers must meet SPSAV requirements and demonstrate segregation, sanctions compliance, market-integrity controls and governance for any smart-contract functions. Custodians must maintain dual-control key management, reconciliations and independent assurance.
Payment companies supporting stablecoin settlement must build verification steps and FX-reporting pipelines. Banks and corporates can incorporate stablecoin flows into existing risk and reconciliation frameworks. Overseas platforms must obtain authorisation or partner with a licensed SPSAV.
The regional context
Across the rest of Latin America, regulatory development remains fragmented and at early or transitional stages. Several jurisdictions — including Mexico, Colombia, Chile, Peru, and Argentina — have partial frameworks, sector‑specific guidance, or ongoing consultations, but none have a fully-implemented regime covering both service providers and stablecoin flows.
As a result, Brazil now stands as the region’s only jurisdiction with a comprehensive and enforceable digital‑asset framework.
A key factor behind Brazil’s regulatory acceleration is the central bank’s longstanding view that digital assets must be supervised through the same operational lens applied to financial market infrastructures.
Unlike many jurisdictions in the region, where crypto regulation is still approached primarily as a consumer protection or taxation issue, Brazil has treated digital‑asset activity as a structural component of payments, FX, and financial stability. This mindset was shaped by the country’s experience with PIX, open finance and its modernised instant‑payments infrastructure, which demonstrated the value of regulating emerging technologies through a combination of operational standards and market‑wide interoperability.
The new digital‑asset regime extends that philosophy: rather than imposing prescriptive rules on innovators, the central bank emphasises verifiable controls, responsible intermediation, traceable flows, and alignment with existing supervisory frameworks.
This approach explains why Brazil has moved faster than its regional peers and why its model is increasingly viewed as a template for other emerging markets facing rapid retail adoption of stablecoins.
Brazil in the global context
When comparing Brazil to other major jurisdictions, a clear pattern emerges. Europe’s Markets in Crypto‑Assets Regulation (MiCA) governs both issuers and service providers across the EU. It establishes requirements for issuance, custody, trading platforms, and consumer protection, forming the backbone of the region’s digital‑asset framework. The United States, through the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, focuses more narrowly on payment stablecoin issuers and the conditions under which those tokens can be offered. The UAE and Hong Kong follow models that combine supervision of service providers with specific rules for fiat‑referenced stablecoins.
Brazil takes a different path. Rather than centering regulation on how tokens are issued or how reserves are structured, Brazil focuses on the firms that actually serve users. The SPSAV licensing regime and the operational standards that follow place responsibility squarely on intermediaries. These are the entities that custody assets, run infrastructure, process transfers, and manage the operational risks that arise when value moves.
Stablecoins make this distinction most visible. In most major jurisdictions, regulators focus primarily on the token itself: how it is backed, how it is redeemed, and what issuers must disclose. Brazil instead focuses on how the stablecoin moves through the financial system. That includes verifying counterparties, recording flows and reporting cross‑border movement through the FX regime.
Crucially, the US$100,000 cap applies whenever the counterparty is not licensed or FX‑authorised in Brazil. No equivalent per‑transaction limit exists in the leading frameworks in Europe, the United States, the UAE, or Hong Kong.
This makes Brazil’s approach to supervising stablecoin flows fundamentally different in both design and effect.
The practical takeaway for global firms is straightforward. Other jurisdictions place most of their rules on the stablecoin as a product. Brazil places them on the activity around it. Any firm that wants to operate across these markets must be prepared to handle both approaches at the same time.
By focusing supervision on intermediaries and the movement of value, Brazil has created a framework that fits how digital assets are actually used in the country.
It does not replace the issuer‑based models abroad; instead, it sits alongside them as a distinct and increasingly important approach.
As stablecoin use continues to expand internationally, this difference will matter for any global operator.
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