Brazil's VASP capital formula: R$10.8m to R$37.2m, explained
The headline range, and where it comes from
When the Banco Central do Brasil published its virtual asset package on 10 November 2025 — Resolutions BCB 519, 520 and 521 — it attached a price to entry: minimum capital for a virtual asset service provider (prestador de serviços de ativos virtuais, or PSAV) of between R$10,800,000 and R$37,200,000, depending on what the firm actually does.
That range is the most quoted figure in the Brazilian regime and also the most misread. It is not a menu with three prices. It is the span between the cheapest possible authorised PSAV and the most expensive one, produced by a calculation each applicant has to run for itself.
Your category sets the starting point
Resolution BCB 520, article 4, divides PSAVs into three modalities. Which one you fall into is the first input to the capital number, and it is determined by function rather than by branding:
- Intermediary — subscription, purchase, sale, exchange and portfolio management of virtual assets on behalf of third parties.
- Custodian — safekeeping and control of virtual assets, or of the instruments that allow access to them.
- Broker — intermediation and custody carried on together.
A firm that both matches orders and holds client keys is a broker, and it will not be priced as an intermediary. Most exchanges serving retail customers in Brazil fall into that combined category, which is why the numbers many operators were planning around turned out to be too low.
Two parcels, not one number
The arithmetic does not live in the virtual asset resolutions. It sits in the general minimum capital framework the BCB rebuilt in late 2025 — Resolução Conjunta nº 14/2025 together with Resolução BCB nº 517/2025 — which replaced flat per-licence amounts with a calculated floor assembled from two components:
- a cost parcel, driven by how many operational categories the institution registers and whether it runs its own technology infrastructure rather than outsourcing it;
- an activity parcel, driven by the services actually performed, the nature of the funds handled and multipliers applied to those activities.
Component values circulate widely in Brazilian commentary — a base amount per operational category, an uplift for in-house technology, a ceiling on the cost parcel, and percentage factors on the activity side. Those figures are not reported consistently across sources, and the annexes to Resolução Conjunta 14 are the only authoritative version. Do not budget from a summary table, including this one. Run your own activity mix through the annex and have the result checked by Brazilian counsel.
Why published worked examples disagree
You will find law-firm notes putting intermediation-only capital at roughly R$9.2m and intermediation plus custody at around R$13m. Those sit below the R$10.8m the BCB quoted as the bottom of its own range. The gap is not necessarily an error in either: the formula produces different answers depending on assumptions about technology, the number of registered categories and how client funds are treated, and the announced range describes the outcome across the regime rather than any one firm.
The practical lesson is that a single number seen anywhere — including from the regulator — is an illustration and not a quotation for your business. The only figure that matters is the one your own inputs produce.
Capital has to be real, and it has to be there early
Capital must be subscribed and paid up in cash, with integralisation immediately following subscription. There is no arrangement under which a commitment letter or a parent guarantee substitutes for money in the company. That has consequences for group structures where the Brazilian entity has historically been thinly capitalised and funded by intercompany transfers.
How the deadline interacts with the number
Resolutions 519 and 520 entered into force on 2 February 2026, opening a transition window of roughly nine months for providers already operating in the market. Sources differ by a few days on the exact cut-off in late October to early November 2026, and the applicable date can turn on whether the provider is already a supervised financial institution — confirm your own date against the resolution text rather than a summary. A provider that does not file in time must cease activities within thirty days and return client assets.
The authorisation procedure itself is set by Instrução Normativa BCB 704. Providers already in the market are assessed in two phases: the first tests operating status at the start of the regime, the reputation of the administrators and capital adequacy; the second examines economic viability, the origin of the funds and the remaining qualification criteria. Capital is therefore a phase-one gate. A shortfall does not surface late in the process as a condition to be remedied — it stops the file at the front door.
What to do before you file
- Fix your category under Resolution 520 article 4 on the basis of what you actually do, not what your licence application says you intend to do.
- Compute the floor from the Resolução Conjunta 14 annexes with your real activity mix, then add headroom — the calculated minimum is a floor, not a target.
- Confirm whether in-house technology infrastructure applies to you, since it moves the cost parcel materially.
- Plan the cash injection and its documentation now; proving the lawful origin of the funds is a phase-two requirement and takes longer than the transfer itself.
- Verify every figure in this article against the current text of the resolutions before committing capital.
The checklist behind this article
Everything above is drawn from the same working document I use when I read a file: an 11-page readiness checklist for PSAV authorisation with the Banco Central do Brasil, covering the four layers of the framework, the three modalities under article 4 of Res. BCB 520, why the R$10.8m–R$37.2m range is a calculation rather than a price list, the Phase 1 and Phase 2 document sets under IN BCB 704 with their clocks, the refusal consequences, and the points that are still genuinely open. Figures that come from Brazilian legal commentary rather than from the instruments are marked as such. It is USD 79, and buyers get the updated edition free as the position develops.
If your situation is straightforward, the checklist is genuinely enough and you will not need to speak to me. If it is not, the 48-hour gap check reads what you have and returns a written list of what is missing, in the order it should be fixed.