Brazil adjusts compliance deadline for crypto asset business, central bank transition list is about to be announced
Brazil's Banco Central do Brasil (BCB) has postponed the date for banks and payment institutions to stop doing business with non-compliant crypto asset counterparties from October 30 to November 6. At the same time, the central bank is compiling an official list of "transitional enterprises" under the new licensing system. This adjustment was achieved through Resolution BCB 589, which was published in the Diário Oficial da União on September 25 and came into effect for Article 91 on October 1. The move replaces previously reported provisions in Resolution 520.
The adjustment at this time point is of great significance, marking that Brazil's regulatory model is shifting from "rule-making" to "strict control." At present, the central bank has announced its first decision to refuse to issue encryption service licenses, and a public process inquiry shows that only seven applications are still being processed by the central bank.
Specific amendments to Article 91 by Resolution No. 589
According to the original Article 91, starting from October 30, regulated financial institutions and payment institutions will be prohibited from providing or assisting in the operation of virtual assets to providers that are neither authorized nor "applying for authorization." Resolution 589 adjusted the operating deadline to November 6 and revised relevant wording. The new text only mentions counterparties that are "not authorized in Brazil" and deletes a clear statement about companies that are "applying for authorization."
The deletion raises an obvious practical question: What will be the status of companies with pending applications after November 6? The central bank stated in its explanatory vote No. 108/2026 that the extended week is intended to allow the central bank to systematize and publish an official list of transition institutions, including virtual asset service providers that have submitted authorization applications and qualified institutions that have notified banks of their intention to enter the market. As of October 6, this comprehensive list of transition periods had not been found on the central bank's public page. Until regulators release the list or directly clarify how pending applications interact with the revised section 91, it cannot be assumed that pending applications alone will ensure that companies will continue to receive banking services after November 6.
Reason for central bank postponement
Paragraph 7 of Vote No. 108 sets out the reason for regulators to grant a seven-day extension: Time is needed to organize and publish a transition list so that markets and government departments can understand which entities fall within the regulated transition. This makes the list a key operational document for crypto companies and their partner banks.
In addition, October 30 still has special significance: it is the deadline for first-phase declarations by existing providers. According to Article 9 of the Central Bank's Normative Instruction 704, existing virtual asset service providers must submit their authorization packages before October 30, 2026. Previous independent audit work must be completed with this declaration.
Brazil has issued its first encrypted license rejection letter
The current transition is no longer a theoretical discussion. The central bank rejected a request for authorization from Highway Tech Soluções, which operates under the name Higher Global Payments. The decision was dated August 25 and published in the Official Gazette of the Federation on September 28. The published announcement did not explain specific reasons for the refusal. Higher Global said it is reviewing the decision under the guidance of legal and regulatory advisers and evaluating possible review or other administrative or judicial measures. This is the first known rejection case under the new virtual asset service provider system.
The central bank also hinted that more negative decisions could be made quickly. Central bank official André Zanon said at an ABCripto webinar on September 29 that regulators intend to speed up the processing of rejection cases that fail to meet basic first-stage requirements, including the reputation of the controller, capital requirements and evidence that the agency was operating when the system came into effect.
Only seven applications have surfaced.
A public search as of early October showed that only seven applications are still being processed by the central bank: Transfero, Mazzera, PFPAY, Masterpay, W Brasil, Onda Finance and Wynx. But that doesn't mean that these companies are the only companies planning to stay in Brazil. Several large exchanges have publicly expressed their intention to seek authorization, while others have restructured products, exited retail operations or moved customers. The consumer level is already visible: Reports this week suggested that as the new regime approaches, Bity is terminating its encryption services and directing users of Bitybank and BitPreço to different migration routes.
Actions that companies must take before November 6
For existing providers, October 30 remains the filing deadline. Applications must meet the central bank's first-stage document requirements, including the addition of independent reasonable assurance work earlier this year. For banks, payment institutions and other central-bank regulated businesses, November 6 is a key counterparty date. Their compliance team needs to know which crypto businesses the central bank will recognize as falling within the scope of authorization or within the transitional framework once the official list is released.
Therefore, Resolution 589 is not just a one-week extension. Brazil changed the language of the law, postponed the bank deadline, rejected its first license and promised to publish a list that would tell the financial system which crypto companies were in transition. The next milestone is not another policy speech, but the release of that list.

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