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This new regulatory framework — fully aligned with Law No. 14,478/2022, which establishes the legal foundation for virtual‑asset activities — aims to strengthen market security, governance, and transparency.

But what does this really mean for your company’s operations and regulatory timeline?

Compliance Deadlines: What Companies Cannot Ignore

The new rules take effect on February 2, 2026, and the countdown for compliance has already begun. Companies must pay close attention to the following critical deadlines:

1. PSAVs Already Operating in Brazil

If your PSAV is active on the effective date, your company has 270 days to:

• Submit a formal authorization request to the Central Bank
• Begin the internal process of structural and regulatory adjustment

This includes meeting requirements related to governance, cybersecurity, internal controls, and minimum capital thresholds.

2. Foreign Entities (Exchanges)

Foreign companies serving Brazilian clients must comply with a mandatory restructuring:

• Operations and customer bases must be transferred to a locally incorporated PSAV,
  or
• Be migrated to a financial institution already authorized by the BCB

This requirement prevents offshore exchanges from operating in Brazil without local supervision.

3. Transitional Rules for Traditional Financial Institutions

Banks, brokerages, and other traditional financial institutions already operating with cryptoassets must also:

• Notify the BCB formally within the same 270‑day deadline
• Demonstrate how they will adapt their structures to the new regulatory model

This transition reinforces regulatory symmetry across traditional and digital financial players.

Compliance Is Not Just Bureaucracy — It’s Structural

Adapting to the new PSAV rules goes far beyond submitting documents. Companies must prepare for:

• Governance adjustments, including clearer internal responsibilities
• Cybersecurity enhancements, aligned with BCB’s operational‑risk standards
• Minimum capital and net‑equity requirements, which may be substantially higher than previous expectations

Failing to meet these standards may result in operational restrictions, delays in authorization, or even forced discontinuation of activities in Brazil.

How DGN Advogados Can Help

DGN Advogados closely monitors the regulatory evolution of Brazil’s virtual‑asset market and has extensive experience advising fintechs and technology‑driven financial businesses.

Our team supports companies by:

• Preparing and filing authorization requests with the Central Bank of Brazil (BCB)
• Designing complete compliance and governance programs tailored to PSAV requirements
• Reviewing and adapting structures related to asset segregation, cybersecurity, and operational risk
• Guiding foreign exchanges through the mandatory localization process

Don’t wait until the final deadline — preparation is key to avoiding operational and regulatory setbacks.

Contact our team to ensure your company is fully compliant with the new regulatory framework for virtual‑asset service providers.

👉 Access the full briefing on this topic here.