Our partner Tiago Severo Gomes published in Portal do Bitcoin an analysis of BCB Resolution No. 580/2026 and what it means for those who currently treat VASP authorization as the finish line.
The central point: the 2025 rules organized market entry; Resolution 580 deals with what comes next. Its nine articles classify virtual asset service providers as Type 3 institutions and require them, from January 1, 2027, to comply with the prudential framework that already applies to the rest of the financial system. Authorization captures a moment (capital, managers, controls and business plan on a given date). What Resolution 580 adds is ongoing verification that this remains true in the following quarter.
In practice:
- 1.The two clocks run in parallel. The deadline to file the application is October 30, 2026, and the prudential requirements begin on January 1, 2027. Article 7 states in no uncertain terms that the rule applies to the provider even if there is no final decision on its application: it is possible to be under the full prudential regime in January while still awaiting a decision on the license.
- 2.The second layer of capital. Alongside the entry floor (somewhere between R$ 10.8 million and R$ 37.2 million, depending on the modalities), a regulatory capital requirement of at least 8% of risk-weighted assets applies, plus a 2.5% capital conservation buffer. This calculation is not done once: it follows the operation and grows with it.
- 3.The surgical adjustment that costs the most money. Resolution 580 amended article 4 of BCB Resolution No. 201/2022 to exclude providers from the optional simplified methodology for calculating regulatory capital. The criterion adopted is the activity carried out, with size out of the equation: no company is small enough to escape.
- 4.The bottleneck over the next eighteen months is people, not capital. A risk appetite statement, ICAAP, stress testing, a risk committee, a CRO and three lines of defense depend on professionals whom the banking market trains, pays well and is not letting go. A written policy takes a few weeks and is the cheap part; hiring a team, implementing systems and running the routine until it survives an inspection cannot be rushed.
As Tiago sums up, "a licença é uma fotografia" [the license is a snapshot]. The risk he highlights is not that the regulator will forget the promised proportionality, but that companies will over-implement out of fear, building the apparatus of a mid-sized bank for an operation of a different size and discovering too late that the cost that made them unviable was their own choice.
Full article: https://lnkd.in/dnQfqtMZ
