BCB Normative Instruction No. 704/2026 reorganizes the processing of authorization applications at the Central Bank, with procedures, deadlines and Sisorf/Unicad tracks. The central point is not paperwork: it is an increase in executive-level complexity. Authorization will now depend on verifiable consistency among corporate structure, governance, controls, IT and AML/CFT, especially for SPSAVs.
SPSAVs: the material change
IN 704 segments the regime by regulatory maturity and creates a transition path for those already operating:
- Non-operational SPSAVs: follow the ordinary procedure, with no transition "shortcuts."
- SPSAVs already in operation: a two-phase procedure, with distinct effects:
- Phase 1 (through October 30, 2026): eligibility/admissibility screening and minimum stabilization of controls and governance; this is not full authorization.
- Phase 2 (after a favorable ruling, within a short window): substantive and prudential analysis: economic and financial capacity, source of funds, officers/governance, and compatibility among operations, technology, controls and AML/CFT.
A change of category (broker/intermediary/custodian) will now require a separate application and revalidation of the risk profile, with greater scrutiny.
Critical outsourcing (cloud, custody, KYC/KYT, monitoring): enters the core of the assessment; outsourcing does not reduce responsibility.
CTVMs, DTVMs and foreign exchange brokers: consolidation
Here IN 704 does not bring a substantial change, but consolidates the authorization process under the new regulatory legal framework.
