Crypto Law Profile

Brazil CVM Resolution 175/2022 Investment Funds Framework

Brazil’s in-force investment funds framework consolidates fund rules and treats eligible cryptoassets as financial assets for FIFs under venue and concentration limits.

Brazil Effective Regulation Oct 2, 2023

At a glance

Status In force since Oct. 2, 2023, with later implementation deadlines for existing funds.
Crypto exposure Annex I treats eligible cryptoassets as financial assets for FIFs when traded on authorized or supervised venues.
Retail limit CVM staff guidance says the 10% public-fund crypto limit includes direct and certain indirect offshore exposure.
Structure The rule uses a general part plus annexes for fund categories and has been amended through CVM 240/2026.

Overview

Brazil’s CVM Resolution No. 175/2022 is the core investment funds framework administered by the Comissão de Valores Mobiliários. As of July 7, 2026, the rule is in force and the CVM’s official page identifies it as amended by Resolutions 181/2023, 184/2023, 187/2023, 200/2024, 206/2024, 209/2024, 214/2024, and 240/2026.

What CVM Resolution 175 Covers

The resolution provides for the constitution, operation, and disclosure of information by investment funds, as well as the provision of services to funds. It replaced a fragmented set of fund rules with a general part applicable across fund categories and normative annexes that address specific fund types, including financial investment funds (FIF), credit-rights funds (FIDC), real-estate funds (FII), private-equity funds (FIP), ETFs, agribusiness-chain funds, and other specialized vehicles.

The framework is important for crypto-law tracking because it is not a standalone virtual-asset service-provider regime, but it establishes how Brazilian regulated funds may treat cryptoasset exposure inside securities-market products. Its practical effect is most visible in Annex I, which governs FIFs such as equity, currency, multimarket, and fixed-income funds.

Cryptoasset Treatment in Financial Investment Funds

Annex I treats certain cryptoassets as financial assets by nature or equivalence when they are traded through entities authorized by the Central Bank of Brazil or the CVM. For offshore transactions, the relevant trading venue must be supervised by a local authority with legal authority to oversee trading, address abusive market practices, and supervise anti-money laundering, counter-terrorist financing, and counter-proliferation controls.

Annex I also places cryptoassets within a group of assets subject to concentration limits. For funds aimed at the public in general, CVM staff guidance states that the 10% cryptoasset limit includes direct cryptoasset investments and exposure through local funds, offshore funds, or offshore ETFs whose principal risk factor is cryptoasset exposure. The same guidance states that certain onshore crypto ETFs and local funds investing exclusively through those onshore ETFs are not counted in that specific cryptoasset limit.

Fund Structure, Disclosure, and Governance

Resolution 175 modernized fund structuring by allowing different classes of quotas with distinct rights and obligations, provided each class has segregated assets. Where a fund’s regulation limits quotaholder liability to the subscribed amount, the class name must include the Portuguese suffix for limited liability. These provisions align the fund rulebook with broader Brazilian legal reforms while leaving detailed fund-category rules to the applicable annex.

The resolution also sets an operating model based on essential service providers, including administrators and managers, and states that fund operation is carried out through those providers and third parties contracted in the name of the fund. For FIFs offered to the public in general, Annex I includes requirements for a basic information sheet and periodic disclosure of net asset value, performance information, and other class-level information.

Status and Implementation Timeline

The CVM issued Resolution 175 on Dec. 23, 2022, and the official CVM page records publication in Brazil’s Diário Oficial da União on Dec. 28, 2022, with a correction published on Mar. 31, 2023. The rule originally had an April 2023 entry date, but Resolution 181/2023 postponed the general effective date to Oct. 2, 2023.

Implementation continued through later phase-ins. Resolution 200/2024 extended adaptation deadlines for existing funds, including a Nov. 29, 2024 deadline for existing FIDCs and a Jun. 30, 2025 deadline for the remaining existing fund stock. As of the latest verified official materials, there is no separate future crypto-specific milestone in Resolution 175 itself.

Why It Matters for Crypto Markets

For CryptoSlate readers, Resolution 175 is best understood as part of Brazil’s regulated-market infrastructure for investment products. It creates a formal fund-law context for cryptoasset exposure, ties that exposure to authorized or supervised trading venues, and places retail-oriented exposure inside concentration and disclosure rules. The framework should be read alongside Brazil’s broader virtual-asset and securities perimeter developments rather than as a comprehensive crypto licensing law.

Key provisions

Unified investment fund rulebook

Creates a general regime for Brazilian investment funds, supported by normative annexes for specific fund categories.

Market structure Oct 2, 2023 Source

Classes of quotas and segregated assets

Allows different quota classes with distinct rights and obligations, with segregated assets for each class.

Fund structure Oct 1, 2024 Source

Essential service provider model

Fund operation is carried out through essential service providers and contracted third parties, with responsibility tied to each actor’s sphere of activity.

Governance Oct 2, 2023 Source

Cryptoassets as financial assets for FIFs

Annex I includes cryptoassets as financial assets when traded on entities authorized by Brazil’s BCB or CVM, or by a competent foreign supervisor.

Crypto assets Oct 2, 2023 Source

Cryptoasset concentration limit

Annex I places cryptoassets in a group of assets subject to a 10% net-asset-value limit for public-oriented FIF exposure.

Risk limits Oct 2, 2023 Source

CVM crypto exposure interpretation

CVM staff guidance clarifies how direct, local-fund, offshore-fund, and offshore ETF crypto exposure count toward the 10% public-fund limit.

Supervision Sep 27, 2023 Source

Existing fund adaptation deadlines

Resolution 200/2024 extended existing-fund adaptation deadlines to Nov. 29, 2024 for FIDCs and Jun. 30, 2025 for other existing funds.

Implementation Mar 12, 2024 Source

Timeline

  1. Resolution issued by CVM

    CVM issued Resolution 175 as the new investment funds framework.

    Enacted Source
  2. Published in official gazette

    CVM records publication in Brazil’s Diário Oficial da União.

    Enacted Source
  3. Effective date postponed

    CVM approved Resolution 181/2023, postponing the general effective date to Oct. 2, 2023.

    Enacted Source
  4. General entry into force

    Resolution 175 entered into force generally after the postponement.

    In force Source
  5. Implementation deadlines extended

    CVM approved Resolution 200/2024, extending adaptation deadlines and phase-in dates.

    Enacted Source
  6. FIDC adaptation deadline

    Existing FIDCs had until this date to adapt under the extended schedule.

    Effective Source
  7. Existing fund adaptation deadline

    The extended deadline for remaining existing funds to adapt to Resolution 175.

    Effective Source
  8. FIDC annex amended by CVM 240

    CVM announced Resolution 240/2026, a targeted amendment to Annex II for FIDCs.

    Enacted Source

Who it affects

Actors

Banco Central do Brasil, Comissão de Valores Mobiliários, Fund administrators, Fund managers

Asset classes

Cryptoassets, ETFs, Investment fund interests

Official sources

Editorial note

Crypto relevance is concentrated in Annex I for FIFs. This profile does not treat Resolution 175 as a standalone VASP licensing law; it covers how the fund framework addresses eligible cryptoasset exposure.