Brazil Bars Banks and Payment Firms From Dealing With Unauthorised Crypto Providers

From 6 November 2026, Brazil's Central Bank rule in article 91 of Resolução BCB nº 520, as rewritten by Resolução BCB nº 589 of 23 September 2026, takes effect. Financial institutions, payment institutions and other institutions authorised to operate by the Banco Central do Brasil (BCB) may not carry out or enable virtual-asset market operations whose counterparties are virtual-asset service providers that are not authorised to operate in Brazil by the BCB, except in forms expressly authorised in Resolution 520.

The ban date was moved from 30 October 2026 by Resolution 589. In Voto 108/2026-BCB of 22 September 2026, the Board said the extra time would let the BCB systematise and publish an official list of institutions in transition — SPSAVs that filed and eligible institutions that notified. As of 6 November 2026, that named list had not appeared as a separate publication on bcb.gov.br; the rule still applies.

What Article 91 Now Bars

The new caput of article 91, which entered into force for the Resolution 589 changes on 1 October 2026 and whose operative ban date is 6 November 2026, states that from that day it is forbidden for financial institutions, payment institutions and other BCB-authorised institutions to carry out or enable virtual-asset market operations with counterparties that provide virtual-asset services and are not authorised to operate in the country by the BCB, except in the forms expressly authorised in the Resolution. The sole paragraph, which Resolution 589 did not rewrite, says the ban covers trading, intermediation and custody of virtual assets, carrying out and intermediating FX operations, opening and maintaining payment accounts and carrying out payment transactions, among other acts and services, when done to enable the operations in the caput.

Voto 108 quotes the previous article 91 text in a footnote: the ban had been set to start on 30 October 2026 and covered counterparties that were "not authorised or in the authorisation process". The new wording drops the "or in the authorisation process" carve-out and keeps only "not authorised", subject to the express-authorisation exception. Paragraph 8 of the Vote states that from the indicated date regulated institutions may not operate with counterparties that are not duly authorised, subject to the exceptions in the rule.

The legal basis for BCB authorisation of virtual-asset service providers is Law 14,478/2022 (articles 2 and 9) and Decree 11,563/2023, which assign regulation and supervision of those providers to the Central Bank. Resolution 520 is the core functioning rule for sociedades prestadoras de serviços de ativos virtuais (SPSAVs) and for eligible institutions that provide virtual-asset services.

Who Is Affected and How Transition Rules Interact

The direct addressees of article 91 are BCB-regulated institutions: banks, payment institutions and other authorised institutions that would otherwise clear, custody, open payment accounts, run Pix or FX rails, or otherwise enable virtual-asset operations for a provider counterparty. Providers that are not authorised are the counterparties the rule cuts off, unless an express authorisation in Resolution 520 still applies.

For incumbents, Resolution 520 article 88 §6 still says that SPSAVs that filed their authorisation request in time may keep providing services until the authorisation process concludes, without taking on another modality. Article 88 §7 requires providers that did not file by the deadline to cease services within 30 days after the deadline ends — by VASP Tracker's count of that 30-day window, about 29 November 2026; the resolution itself does not print that calendar date. Instrução Normativa BCB nº 704, article 9, fixed the Phase 1 filing deadline at 30 October 2026.

A literal reading of the new article 91 no longer treats "in the authorisation process" as enough on its face. Whether the continuity granted by article 88 §6 counts as one of the "forms expressly authorised" in the Resolution is not clarified in any BCB statement found as of 6 November 2026. Voto 108 said the postponement was to publish the official transition list so the market and other public bodies would have clarity; without that list as a named register, counterparties and banks must rely on the normative text, the open-data process dataset and any firm-specific authorisation decision.

What the Public Record Shows and What Comes Next

At the latest BCB open-data reference date used in the site's analysis (31/10/2026), the Processos de autorização dataset listed 7 open SPSAV processes plus one process with no segment stated, and no SPSAV was listed as authorised. The Relação de instituições em funcionamento dataset is the parallel public list of institutions in operation. Those datasets are monthly; absence from a cut that predates or immediately follows the filing deadline does not by itself prove that a firm failed to file.

Searches of bcb.gov.br and the BCB normative materials on 6 November 2026 did not turn up a separate official publication titled as the lista oficial de instituições em transição promised in Voto 108, paragraphs 7–8. The article 91 ban nonetheless takes effect on that date under Resolution 589.

Immediate practical consequences sit with regulated institutions that must stop enabling operations for unauthorised counterparties except where Resolution 520 still expressly allows it, with timely filers whose continuity under article 88 §6 has not been publicly reconciled with the new wording, and with non-filers whose 30-day wind-down under article 88 §7 runs into late November. The next primary signals to watch are any BCB publication of the transition list, updates to the open-data authorisation and institutions datasets, and individual authorisation, denial or cessation decisions.