Crypto Law Profile

Brazil BCB Resolution 520/2025: Virtual Asset Service Provider Operations

Brazil’s Central Bank VASP operating rules covering authorization, operating categories, client-asset segregation, disclosures, outsourcing, AML/CFT controls and transition deadlines. In force from Feb. 2, 2026.

Brazil Effective Regulation Feb 2, 2026

At a glance

Status In force since Feb. 2, 2026; transition authorization filings remain active.
Regulator Banco Central do Brasil supervises the SPSAV operating framework.
Covered Providers Creates intermediary, custodian and virtual-asset broker SPSAV categories.
Next Deadline Existing providers must seek authorization by Oct. 30, 2026.

Overview

Brazil Central Bank Resolution BCB No. 520/2025 is Brazil’s operating rulebook for societies that provide virtual asset services, known in the Portuguese text as sociedades prestadoras de serviços de ativos virtuais or SPSAVs. The Banco Central do Brasil issued the resolution on Nov. 10, 2025, it was published in the Diário Oficial da União on Nov. 11, 2025, and it entered into force on Feb. 2, 2026. As of July 6, 2026, the profile status is In force.

The measure implements part of Brazil’s broader virtual asset framework under Law No. 14,478/2022. It does not regulate every crypto asset activity in isolation; instead, it defines who may provide covered services in Brazil, how SPSAVs must be organized, and which operational safeguards apply when virtual assets are offered, intermediated, held in custody, staked, listed, suspended or delisted.

What Resolution BCB 520 covers

The resolution applies to SPSAVs and to other financial or payment institutions already authorized by the Central Bank when they provide covered virtual asset services. It treats a provider as operating in Brazil where it is constituted in Brazil and has its seat and administration in Brazilian territory, subject to Brazilian law and authorities.

The rule classifies SPSAVs into three operating categories. Virtual asset intermediaries may conduct activities such as subscription, purchase, sale, exchange, portfolio administration, fiduciary functions, staking, virtual asset services in the foreign exchange market and other BCB-authorized activities. Virtual asset custodians focus on safekeeping, control and movement of private keys and related instruments. Virtual asset brokers combine intermediation and custody. Intermediaries and custodians are barred from combining other SPSAV modalities unless operating as brokers.

Key provisions for VASP operations

Resolution 520 makes Central Bank authorization central to the SPSAV model. A society must request authorization before beginning covered services, while entities already operating when the rule entered into force must follow a transition route. Existing operators have 270 days from Feb. 2, 2026, to file an authorization request, setting an Oct. 30, 2026 practical deadline.

  • Client asset segregation: providers must separate their own virtual assets from client and user assets, document the segregation policy, use proof-of-reserve methods, commission biennial independent assurance and appoint a responsible director or administrator.
  • Restrictions on use of client assets: the rule generally prohibits using client, user or counterparty assets for proprietary operations, with stated exceptions for regulated staking and express consent by qualified or professional investors.
  • Governance and controls: SPSAVs must maintain policies for risk management, business continuity, relevant third-party services, private-key protection, AML/CFT, cybersecurity, cloud and data-processing outsourcing, and personal data protection.
  • Customer disclosures: providers must disclose authorization status, licenses, policies, terms, involved third parties, conflicts of interest, coverage or insurance arrangements, custody arrangements, fees, risk-profile procedures and support channels.
  • Asset listing standards: intermediaries must use clear and public criteria for listing, suspension and delisting, including heightened checks for fiat-referenced virtual assets and reserve arrangements.

Status and transition timeline

The rule is operative, but several implementation points remain relevant. Firms that file authorization requests on time may continue providing services until the Central Bank concludes the process, but may not assume another modality during the transition. Those that miss the filing deadline must cease covered services within 30 days after the deadline.

Information-transfer and monitoring procedures under Article 44 phase in over two 365-day periods: first for Brazil’s domestic virtual asset market by Feb. 2, 2027, then for international coverage by Feb. 2, 2028. The resolution also makes Article 44 compliance mandatory for all authorized SPSAVs from Feb. 2, 2028.

Editorial context

Resolution 520 should be read together with Resolution BCB No. 519/2025, which addresses authorization processes, and Resolution BCB No. 521/2025, which addresses foreign exchange treatment of certain virtual asset services. Subsequent prudential rules, including Resolution BCB No. 580/2026, may affect SPSAV capital and risk-management treatment but should be profiled separately.

Key provisions

Scope and regulated virtual assets

Applies to SPSAVs and BCB-authorized institutions providing virtual asset services in Brazil, using Law 14.478’s virtual-asset perimeter subject to statutory exclusions.

Market Structure Feb 2, 2026 Source

SPSAV operating categories

Classifies SPSAVs as virtual-asset intermediaries, custodians or brokers; brokers may combine intermediation and custody while pure intermediaries and custodians are restricted.

Licensing Feb 2, 2026 Source

Central Bank authorization

Requires SPSAVs to request BCB authorization before providing covered services, with existing operators subject to a transition request deadline.

Licensing Feb 2, 2026 Source

Client asset segregation

Requires separation of client virtual assets, proof-of-reserve methods, biennial independent assurance and a responsible director or administrator.

Custody Feb 2, 2026 Source

Governance and AML/CFT controls

Requires policies and controls for risk, business continuity, third-party services, private keys, AML/CFT, cybersecurity, cloud/data outsourcing and data protection.

AML/CFT Feb 2, 2026 Source

Customer disclosures and fees

Requires disclosures on authorization status, licenses, policies, terms, third parties, conflicts, safeguards, coverage, risk profile, support channels and fees.

Consumer protection Feb 2, 2026 Source

Asset listing and fiat tokens

Requires clear listing, suspension and delisting criteria, with due-diligence checks for fiat-referenced tokens, reserves, backing and public criteria.

Disclosure Feb 2, 2026 Source

Timeline

  1. BCB board session

    BCB’s collegiate board considered the resolution during its Nov. 6, 2025 session.

    Enacted Source
  2. Resolution issued

    Resolution BCB No. 520 was issued to discipline SPSAV constitution, operation and virtual asset services.

    Enacted Source
  3. Published in DOU

    The resolution was published in the Diário Oficial da União, Section 1, pages 101-110.

    Enacted Source
  4. Entered into force

    Article 92 provided that the resolution entered into force on Feb. 2, 2026.

    In force Source

Who it affects

Actors

Banco Central do Brasil, Virtual asset service providers

Asset classes

Fiat-referenced tokens, Virtual assets

Official sources

Editorial note

Profile covers Resolution BCB No. 520/2025 only. Authorization procedures under Resolution BCB No. 519/2025 and Instruction BCB No. 704/2026, foreign-exchange treatment under Resolution BCB No. 521/2025, and prudential classification under Resolution BCB No. 580/2026 should be tracked as related law profiles where available.