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Fintech in Brazil: payment institutions, digital lenders, peer to peer lending, crowdfunding and crypto providers

Last verified: 2026-10-27 · Status: Changing

Brazil licenses fintechs by activity. Payment institutions (e-money, post paid cards, acquiring, payment initiation) must obtain Central Bank authorization before starting, a rule extended in 2025 to all modalities. Digital lenders can become a direct credit company (SCD) or a peer to peer lending company (SEP), both S.A. financial institutions, and investment crowdfunding runs through CVM registered platforms with offer and investor caps. Crypto service providers have needed Central Bank authorization since February 2026, and from 6 November 2026 banks may no longer deal with unauthorized ones.

USD figures use the Banco Central do Brasil PTAX selling rate of R$5.3346 per US dollar for 27 October 2026. Conversions are for orientation only.

Key facts

Central Bank authorization required before providing payment services	Yes, all modalities Resolução BCB nº 80 art. 9, as of 2026-10-27 · in force
Cap per lender per borrower in a peer to peer lending company (non qualified)	15000 BRLResolução CMN nº 5.050 art. 24, as of 2026-10-27 · in force
Crowdfunding offer cap per issuer per calendar year	15000000 BRLResolução CVM nº 88 art. 3, as of 2026-10-27 · in force
Maximum annual gross revenue of a crowdfunding issuer	40000000 BRLResolução CVM nº 88 art. 2 VII, as of 2026-10-27 · in force
Annual crowdfunding limit for retail investors	20000 BRLResolução CVM nº 88 art. 4, as of 2026-10-27 · in force
Authorization required for virtual asset service providers	Yes, Central Bank, rule in effect since 2 February 2026 Lei nº 14.478 art. 2; Resolução BCB nº 520, as of 2026-10-27 · in force
Date from which banks may not serve unauthorized virtual asset providers	2026-11-06 dateResolução BCB nº 520 art. 91, as of 2026-10-27 · in force

The rule

1. A payment institution is a company that, within payment arrangements, makes available deposits and withdrawals in payment accounts, executes payments and transfers, manages payment accounts, issues payment instruments, acquires merchants, remits funds or issues electronic money. Payment institutions may not carry out activities reserved to financial institutions. Closed loop instruments accepted only by the issuer are not payment arrangements.Lei nº 12.865 of 9 October 2013, Art. 6, items I to VI and §§ 2 and 3, 2013-10-09 official text · verified 2026-10-27

2. A payment institution must request Central Bank authorization before starting to provide any payment service, listing every modality it intends to perform. E-money issuers operating since before 1 March 2021 without authorization, and post paid instrument issuers and acquirers operating since before 5 September 2025, had to file between 1 and 31 May 2026, and may only continue for 30 days after that window if they did not file.Resolução BCB nº 80 of 25 March 2021, arts. 9 and 9-A as worded by Resolução BCB nº 494 of 5 September 2025, Art. 9 caput and sole paragraph; art. 9-A caput and §§ 1 and 2, 2025-09-05 official text · verified 2026-10-27 · changed: Resolução BCB nº 494 of 5 September 2025 ended the volume thresholds below which payment institutions could operate without authorization (old art. 10 tiers of R$500 million down to R$100 million) and set the May 2026 filing window for legacy players.

3. A direct credit company (SCD) is a financial institution organized as an S.A. that lends, finances and buys receivables exclusively through an electronic platform, using only its own capital or BNDES on lending, and may sell or assign those credits. It may not take funds from the public except by issuing shares. A peer to peer lending company (SEP) is also an S.A. financial institution connecting lenders and borrowers; a lender may not hold more than R$15,000 of outstanding loans to the same borrower in the same SEP, unless the lender is a qualified investor.
Cost to do it: Minimum capital now follows the activity formula of Resolução Conjunta nº 14/2025 (the old R$1,000,000 floor for SCDs was revoked); see Banks and foreign banks.Resolução CMN nº 5.050 of 25 November 2022, as amended by Resolução CMN nº 5.159 of 24 July 2024, Arts. 3, 5, 7, 8, 10, 11, 13 and 24, 2022-11-25 official text · verified 2026-10-27

4. Investment crowdfunding offers by small companies are automatically exempt from CVM offering registration if run through a CVM registered platform, with a target of up to R$15,000,000 per offer and per calendar year, a maximum offer period of 180 days and a cooling off period of at least 5 days. The issuer must be a Brazilian company not registered with the CVM with annual gross revenue up to R$40,000,000 (R$80,000,000 consolidated if controlled by another company or fund). Each investor may put up to R$20,000 per calendar year into such offers, unless a lead, qualified investor or person with income or investments above R$200,000.Resolução CVM nº 88 of 27 April 2022, as amended by Resoluções CVM nº 158/22 and 226/25, Art. 2 VII and § 2; art. 3 caput I to III and § 3; art. 4, 2022-04-27 official text · verified 2026-10-27

5. Virtual asset service providers may only operate in Brazil with prior authorization of the federal body designated, which is the Central Bank. The law created the crime of fraud using virtual assets, securities or financial assets, punished with 4 to 8 years of imprisonment and a fine.Lei nº 14.478 of 21 December 2022, Arts. 2, 5, 9 and 10 (Penal Code art. 171-A), 2022-12-21 official text · verified 2026-10-27

6. Virtual asset service companies are Central Bank authorized institutions in three modalities: intermediaries, custodians and brokers, and must be incorporated with headquarters and management in Brazil. The rule took effect on 2 February 2026; providers already active had 270 days from then to request authorization while sending client, balance and proof of reserves data to the Central Bank. From 6 November 2026 financial and payment institutions may not trade, open accounts, run FX or make payments for unauthorized providers.Resolução BCB nº 520 of 10 November 2025, as amended by Resolução BCB nº 589 of 23 September 2026, Arts. 1, 4, 88 and 91; entry into force clause, 2025-11-10 official text · verified 2026-10-27 · changed: Resolução BCB nº 589/2026, effective 1 October 2026, set 6 November 2026 as the date of the ban on banks dealing with unauthorized virtual asset providers (art. 91).

Model	License	Regulator	Key norm
Wallet, prepaid account, card issuing, acquiring, payment initiation	Payment institution	Central Bank	Lei nº 12.865; Resolução BCB nº 80
Balance sheet digital lender	Direct credit company (SCD)	Central Bank	Resolução CMN nº 5.050
Marketplace lending	Peer to peer lending company (SEP)	Central Bank	Resolução CMN nº 5.050
Equity or debt crowdfunding	Crowdfunding platform registration	CVM	Resolução CVM nº 88
Crypto exchange, broker or custody	Virtual asset service company	Central Bank	Lei nº 14.478; Resolução BCB nº 520

Which license for which fintech model

Worked example

Crowdfunding round. A Brazilian startup with R$6,000,000 (US$1,124,733) of revenue raises R$3,000,000 (US$562,366) through a CVM registered platform in a 120 day offer. It is under the R$40,000,000 revenue and R$15,000,000 annual offer caps, so no CVM offering registration is needed; each retail backer can invest up to R$20,000 (US$3,749) a year across all platforms (Resolução CVM nº 88 arts. 2, 3 and 4). A second offer must wait 120 days after a successful one (art. 3 § 5).

Step by step

1. Map each product to its activity: payment, lending, investment or crypto, since licenses are by activity.
2. Incorporate a Brazilian company with management in Brazil: an S.A. for an SCD or SEP (Resolução CMN nº 5.050 arts. 3 and 11), while payment institutions may also be limitadas (Resolução BCB nº 80 art. 7).
3. Size capital with Resolução Conjunta nº 14/2025 for every activity and any technology services.
4. File the authorization request before launch; for crypto, players active before 2 February 2026 must have filed within 270 days.
5. For crowdfunding, run offers only on a CVM registered platform and track the investor and issuer caps.

Common traps

Relying on volume exemptions. Since Resolução BCB nº 494/2025 there is no longer a size threshold below which a payment institution can run without authorization.
Funding an SCD with deposits or notes to the public. An SCD may not take funds from the public except by issuing shares (Resolução CMN nº 5.050 art. 10).
Using an offshore crypto exchange through Brazilian banks. From 6 November 2026 banks and payment institutions must stop serving unauthorized providers (Resolução BCB nº 520 art. 91).
Reading consolidated Central Bank texts at face value. Superseded paragraphs (for example the old payment institution thresholds) still appear next to the revocation note; check the amendment list.

Sources

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