How to Get a VASP License in Brazil: SPSAV Authorisation at the Central Bank

A practical guide to obtaining virtual-asset service authorisation in Brazil: who the regulator is, what an SPSAV is, the filing routes (Phase 1/Phase 2, art. 22 notification and art. 23 transfer), capital under the official methodology, the 30 Oct and 6 Nov 2026 deadlines, and how the regime compares with MiCA and Argentina's CNV PSAV register. At the latest BCB open-data reference date (30/09/2026), the dataset listed 7 open SPSAV processes (+1 with no segment stated) and no SPSAV was listed as authorised.

For information only. Not legal advice and not an official BCB, ESMA or CNV publication. Always read the original resolutions and instructions, and take advice for your own facts.

Who Regulates Virtual-Asset Services in Brazil

Law 14,478/2022 created the legal framework for virtual-asset service providers. Decree 11,563/2023 assigned regulation and supervision of those providers to the Central Bank of Brazil (Banco Central do Brasil — BCB). In November 2025 BCB published the core of the regime: BCB Resolution 519/2025 (authorisation processes), BCB Resolution 520/2025 (SPSAV constitution and functioning) and BCB Resolution 521/2025 (virtual assets in FX and capital markets). Anyone filing now also needs BCB Normative Instruction 704 (procedures, Sisorf models and document lists) and BCB Resolution 589/2026 (which rewrote, among other points, art. 91 of Res. 520).

Authorisation files are received by Deorf. Filings are protocolled at BCB; supporting data go into Unicad; document models live in the Sisorf manual (IN 704, arts. 2–4). Once authorised, an institution can be looked up in Encontre uma instituição.

What an SPSAV Is

An SPSAV — Sociedade Prestadora de Serviços de Ativos Virtuais — is the dedicated institutional type authorised by BCB to provide virtual-asset services for third parties (Res. 520; BCB's November 2025 market presentation). It must be a Brazilian limitada or sociedade anônima, use the words “Sociedade Prestadora de Serviços de Ativos Virtuais” in its corporate name, and have administrators accountable to BCB.

There are three modalities (Res. 520, art. 4): intermediation, custody and broker (intermediation + custody). Intermediation and custody may not be stacked outside the broker modality. The resolution also bars, among other things, extending credit to clients and raising funds from the public other than equity issuance (art. 12).

The market often says PSAV. In the resolution that broader label also covers already-authorised institutions (certain banks, CTVMs, DTVMs, FX brokers) when they provide the same services — they do not open an SPSAV process in the open-data feed; they use the arts. 20–22 notification path.

Who Must File, Who Notifies, and Who Must Transfer

• New entrants (not providing the covered services on 2 Feb 2026): need BCB authorisation before starting (Res. 520, art. 19) and follow the single package in IN 704, art. 5.
• Incumbents (already active on 2 Feb 2026): must apply within 270 days (art. 88, I); Phase 1 must be filed by 30 Oct 2026 (IN 704, art. 9).
• Already-authorised institutions listed in art. 20: file a formal notification with independent technical certification (arts. 21–22; certification detail in IN BCB 701). Those notifications do not appear in the open SPSAV-process table.
• Foreign operators that were already serving Brazil: must transfer operations and clients to a local SPSAV or authorised institution within the same 270-day window (art. 23). There is no foreign “passport” into Brazil the way MiCA passporting works inside the EEA.

Application Steps: Phase 1, Phase 2 and New Entrants

For firms already active on 2 Feb 2026, BCB Resolution 519, art. 26 — explained in BCB Vote 18/2026 — splits authorisation into two phases. IN 704 turns that into a document checklist.

Phase 1 — File by 30 October 2026 (IN 704, Art. 9)

Protocol the request to Deorf, enter required data in Unicad, and attach at least: the request form (Sisorf model 08.23.010.002); an activity declaration that the firm was operating when Res. 519/520 entered into force (08.23.020.010); fit-and-proper declarations from controllers and qualifying holders; authorisations for Receita Federal tax returns and for BCB access to cadastres; control / shareholder-agreement declarations; and audited financial statements for the last three financial years (CVM-registered independent auditor). Phase 1 analysis covers proof of activity on 2 Feb 2026, controllers and qualifying holders, and minimum capital / net-worth requirements in force (Vote 18/2026; Res. 519).

Phase 2 — Within 60 Days of a Favourable Phase 1 Decision (IN 704, Art. 10)

The 60-day clock (extendable by another 60 on a justified request) includes, among other items: the Phase 2 request (08.23.010.003); controllers' economic-financial capacity; a declaration of the lawful origin of funds used to pay in capital; an executive summary of the business plan (Annex II; BCB may demand the full five-year plan in Annex I); administrators' packages; and a reasonable-assurance AML/CFT report from a CVM-registered independent auditor (Annex IV, added by IN BCB 739/2026). Phase 2 looks at the remaining Res. 519 requirements: controllers' capacity, origin of funds, economic viability, IT infrastructure and governance fit for the risk of the business.

Capital Methodology and Filing Fees

Res. 520 itself does not publish a single flat “SPSAV minimum capital” figure. Res. 519 requires compliance with the minimum paid-in capital and net-worth requirements in the rules in force. Those rules are in CMN/BCB Joint Resolution 14/2025: a cost parcel (BRL 2 million × number of operational activity categories communicated to BCB, plus a technology add-on of BRL 5 million, capped at BRL 10 million) is added to an activities parcel (category amounts for services / custody / intermediation / lending, plus the investment category, then multiplied by a funding-source factor). Institutions that use “banco” in their name add a further BRL 30 million. Because the result depends on the modalities and funding profile you communicate, this guide does not invent a one-number SPSAV floor.

On an SPSAV-specific BCB application fee (emolumento): in the official instruments reviewed for this article (Res. 519/520, IN 704, Joint Resolution 14) we did not find a publicly stated amount. Do not assume there is none — check the current BCB fee table / Sisorf guidance when you file — but we are not publishing a figure we cannot cite.

Deadlines: 30 October, 6 November and Wind-Down

Firms that file Phase 1 on time may keep providing services “until the conclusion of their authorisation process”, without taking on another modality (Res. 520, art. 88, §6). Firms that miss the deadline must cease those services within 30 days after it (§7) — by VASP Tracker's count, 29 Nov 2026; the rule does not state that date. For the calendar and the wording of art. 91, see what changes on 30 October 2026.

Separately, from 6 Nov 2026, BCB Resolution 589 rewrote art. 91 of Res. 520: financial institutions, payment institutions and other BCB-authorised institutions may not carry out or enable virtual-asset market operations with counterparties that provide those services without authorisation to operate in Brazil, except in the forms the Resolution itself expressly allows. The new text dropped the carve-out for firms “in the authorisation process”. Read literally, that is a banking-access risk (for example Pix rails), not only a licence-status risk.

What the Official Data Shows

BCB publishes the authorisation-process dataset (Olinda OData). At reference date 30/09/2026: 7 open SPSAV processes (+1 with no segment stated); 0 authorised SPSAV(s) on our reading of the data; 0 of 22 major tracked platforms appear in that cut. Being “in process” is not a licence. Track the living table on the Brazil hub and the files under VASP Tracker open data; the brand-by-brand scorecard is in who has applied and who is leaving.

What Happens Without a Licence

• New activity without authorisation is prohibited (Res. 520, art. 19).
• An incumbent that does not file by 30 Oct 2026 must stop within 30 days (art. 88, §7).
• Denial: a society whose constitutive act was already filed at the commercial registry must dissolve or change its object within 15 days (IN 704, art. 6). There is a public denial in the DOU (process 304022, Higher Global Payments / Higherway Tech).
• Crypto balances are not covered by Brazil's deposit guarantee fund (FGC) — Res. 520 requires providers to say so clearly to clients.

How Brazil Compares With MiCA and Argentina

Under Regulation (EU) 2023/1114 (MiCA), a crypto-asset service provider needs Article 63 authorisation, or an already-regulated entity uses the Article 60 notification; a licensed CASP can passport across the EEA. Member-state transitional periods under art. 143(3) could last no longer than 1 July 2026; ESMA has stated that from that date providing crypto-asset services to EU clients without a MiCA licence breaches EU law. Contrast: Brazil is a single-supervisor, single-country authorisation with no EEA-style passport; foreign groups must localise (art. 23); incumbent relief is a filing deadline (30 Oct) plus continued operation while the file is open — plus the 6 November bank-rail rule. Broader UK comparison: Brazil vs MiCA vs UK.

In Argentina, the CNV keeps a public PSAV register under Law 27,739 and General Resolution 1058/2025. Registration and cancellation run through the national TAD portal. Art. 9 of RG 1058 sets explicit minimum net-worth floors in US dollars: U$S 150,000 for categories 1, 2 and 4; U$S 75,000 for category 3; U$S 35,000 for category 5 (with a 50% reduction below stated volume thresholds). Contrast: Argentina publishes a simple USD table by category; Brazil uses the Joint Resolution 14 formula and folds SPSAVs into the central-bank / financial-system perimeter (capital, Cosif, Unicad, Deorf).

Practical Checklist Before You File

1. Confirm whether you are an incumbent, a new entrant, a foreign operator under art. 23, or an already-authorised institution on the art. 22 path.
2. Pick the modality and map capital under Joint Resolution 14.
3. Assemble the Phase 1 Sisorf package and three years of CVM-audited financials in time for 30 Oct 2026.
4. Plan Phase 2 early: business-plan summary, origin-of-funds file, administrator packs and the IN 739 AML assurance report.
5. Assume banking partners will re-read art. 91 before 6 Nov 2026.
6. After filing, monitor your process number in BCB open data and on VASP Tracker's Brazil hub.

This guide summarises publicly available Brazilian, EU and Argentine legal instruments and open data for general information. It is not legal advice, not a BCB, ESMA or CNV publication, and not a recommendation to use any platform. Rules and open-data cuts change; cite the original text for any filing decision.