Newsletter (#008/2025) on Fintechs, Banks, Financial Services, and Virtual Assets by Campos Thomaz Advogados

Newsletter (#008/2025) on Fintechs, Banks, Financial Services, and Virtual Assets by Campos Thomaz Advogados

Alerts, materials, and updates on Fintechs, Banks, Financial Services, and Virtual Assets.

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Topics for 2025 – Stay tuned for upcoming newsletters

• Open Finance
• Virtual Assets
• Bank as a Service
• Tokenization
• Artifical intelligence

Alerts

Central Bank’s BaaS regulation proposal may concentrate market and increase costs

The Central Bank’s proposal for regulating the Banking as a Service (BaaS) model, introduced in Public Consultation No. 108/2024, has raised concerns within the financial sector. A study by the Brazilian BaaS Association (ABBaaS), in partnership with consultancy Distrito, warns that certain provisions — such as the prohibition of multitier contracting (i.e., obliging fintechs to select only one BaaS provider) — may encourage market concentration, hinder competition and innovation, and increase operational costs. Additional burdens identified include mandatory independent audits, periodic certifications, and public disclosure of BaaS providers’ client portfolios. Learn more.

Central Bank modernizes regulatory framework for finance companies and broadens scope of operations

On July 24, 2025, the National Monetary Council (CMN), supported by the Central Bank of Brazil, approved a resolution that consolidates and updates the regulatory framework for Societies of Credit, Financing, and Investment (SCFI), commonly known as “finance companies.” The measure, effective September 12, 2025, replaces regulatory provisions that had been in place for over sixty years and unifies rules that had been scattered since 1959. It follows Public Consultation No. 101/2024, which received 33 contributions from market stakeholders, including associations, fintechs, and law firms. Learn more.

Central Bank marks five years of Open Finance and announces regulatory developments

On August 11, 2025, the Central Bank of Brazil celebrated five years of Open Finance, emphasizing its position as one of the most advanced frameworks worldwide. Since its launch in 2020, the system has reached over 100 million authorizations for data and payment sharing, connecting 65 million accounts and handling approximately BRL 1.2 billion per month in transactions. During the event (LiveBC #44), Mardilson Queiroz, Head of the Financial System Regulation Department (Denor), highlighted key benefits such as smart transfers, recurring scheduling, and Automatic Pix payments. Learn more.

Regulatory Update

BCB Normative Instructions

Changes in Tables OR1 and OR2 and Resumption of Disclosure of the Pillar 3 Report in Open Data Format

BCB Normative Instruction No. 650, August 19, 2025 – Amends BCB Normative Instruction No. 385, of May 30, 2023.

Operational Changes in the Reserve Transfer System (STR), Bank Reserve Account, and Settlement Account

BCB Normative Instruction No. 649, August 13, 2025 – Amends provisions of BCB Normative Instruction No. 307, of September 21, 2022, which discloses operational procedures related to the Reserve Transfer System (STR), the Bank Reserve Account, and the Settlement Account, as provided for in the Regulation attached to BCB Resolution No. 105, of June 9, 2021.

Establishment of MCR Document 9 for the Calculation of the Loss and Risk Index in the Agricultural Activity Guarantee Program (Proagro)

BCB Normative Instruction No. 648, August 12, 2025 – Establishes MCR Document 9, which specifies the calculation method for the loss index and the risk assessed for beneficiaries and rural properties under the Agricultural Activity Guarantee Program (Proagro), pursuant to the provisions contained in MCR 12-2-16-“h”-II, MCR 12-5-10-E-“b”, and MCR 12-10-2-A-“b”.

Changes in the Layout and Filling Instructions of Document 3050 (Aggregate Credit and Leasing Statistics) of the Credit Information System – SCR

BCB Normative Instruction No. 646, August 1, 2025 – Amends the Layout and Filling Instructions of Document 3050 – Aggregate Credit and Leasing Statistics, of the Credit Information System – SCR, as provided for in Circular No. 3,870, of December 19, 2017, and Circular Letter No. 3,869, of March 19, 2018.

Simplification of Authorization Procedures for Payment Institutions, Institutions under CMN Resolution No. 4,970/2021, and Consortium Administrators

BCB Normative Instruction No. 645, July 31, 2025 – Amends BCB Normative Instruction No. 103, of April 30, 2021, BCB Normative Instruction No. 299, of August 30, 2022, and BCB Normative Instruction No. 398, of June 29, 2023, to provide for the simplification of authorization request procedures related to the operation of payment institutions, institutions governed by CMN Resolution No. 4,970, of November 25, 2021, and consortium administrators, respectively.

Changes in Document 4111 (Daily Accounting Balances) to Include Prepaid Payment Account Entries and Detail Payment Transactions

BCB Normative Instruction No. 644, July 23, 2025 – Amends BCB Normative Instruction No. 524, of September 18, 2024, which establishes procedures for the daily submission of information to the Central Bank of Brazil regarding accounting balances of an active and passive nature and the financial volume of payment transactions carried out on the day, as provided for in Art. 2, items I and III, of BCB Resolution No. 208, of March 22, 2022.

BCB Resolutions

Inclusion of Sustainable Bonds in the Rules on External Credit and Brazilian Capital Abroad

BCB Resolution No. 492, August 14, 2025 – Amends BCB Resolution No. 278, of December 31, 2022, to regulate external credit operations, including in the form of sustainable bonds, and BCB Resolution No. 279, of December 31, 2022, to regulate the reporting of Brazilian capital abroad in the form of sustainable bonds.

Amendments to the Regulation of the Integrity Committee of the Central Bank of Brazil (CIBCB)

BCB Resolution No. 491, August 6, 2025 – Amends the Regulation of the Integrity Committee of the Central Bank of Brazil (CIBCB), attached to BCB Resolution No. 422, of October 9, 2024.

Regulation of the Working Groups for Monitoring the Financial Sector Assessment Program (FSAP)

BCB Resolution No. 490, August 6, 2025 – Approves the regulation of the working groups responsible for coordinating the monitoring of the Financial Sector Assessment Program (FSAP).

Revocation of Historical Rules on Credit, Financing, and Investment Companies

BCB Resolution No. 489, July 24, 2025 – Revokes Chapter IV of Ordinance No. 309, of November 30, 1959, which regulated the incorporation, operation, and responsibilities of credit, financing, and investment companies and established a supervisory regime, item XVI of Resolution No. 45, of December 30, 1966, and Circular No. 1,137, of March 9, 1987.

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Produced by Alan Campos Thomaz and Michelle Chasilew Levy

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