Our partner Tiago Severo Gomes has published in Portal do Bitcoin an analysis of BCB Resolution No. 580/2026 and of what it means for those who currently treat PSAV authorization as the finish line.
The central point: the 2025 rules organized market entry; Resolution 580 addresses what comes after. Its nine articles classify virtual asset service providers as Type 3 institutions and require them to comply, as of January 1, 2027, with the prudential framework that already applies to the rest of the financial system. Authorization records a moment in time (capital, officers, controls and business plan on a given date). What Resolution 580 adds is the ongoing verification that all of this remains true in the following quarter.
In practice:
- 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 expressly that the rule applies to the provider even if there is no final decision on the application: it is possible to be under the full prudential regime in January and still be awaiting an answer on the license.
- The second layer of capital. Alongside the entry floor (somewhere between R$ 10.8 million and R$ 37.2 million, depending on the category), a minimum regulatory capital of 8% of risk-weighted assets applies, plus a 2.5% conservation buffer. This calculation is not done once: it follows the operation and grows with it.
- 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 taken out of the equation: no company is small enough to escape.
- The bottleneck of the next eighteen months lies in people, not in capital. Risk appetite statements, ICAAP, stress testing, risk committees, 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 inexpensive part; hiring a team, implementing a system and running the routine until it can withstand an inspection does not allow for compressed timelines.
As Tiago puts it, “the license is a photograph.” The risk he highlights is not that the regulator will forget the proportionality it promised, but that the company 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 it unviable stemmed from an internal choice.
