Brazil VASP authorisation under IN BCB 704: the two-phase process
Brazil's virtual-asset framework is now four layers deep: BCB Resolutions 519/520/521, the capital formula in Res. Conjunta 14 and Res. BCB 517, the prudential and accounting rules in Res. BCB 552/553, and — the piece that governs the application itself — Instrução Normativa BCB 704, in force since 2 February 2026.
Two regimes, decided by one date
Which path you take depends on whether you were already operating on 2 February 2026.
Existing providers — two phases, deadline 30 October 2026
Phase 1 requires the authorisation request form, a declaration of the activities you carried on through 2 February 2026, unblemished-reputation proof for controllers and qualified shareholders, control declarations, and three years of audited financial statements.
Phase 2, within 60 days of Phase 1 approval (extendable by 60 more), requires a specific authorisation request, controllers' economic-financial capacity, capital-source documentation, a business-plan executive summary (Anexo I), and administrators' reputation and technical-qualification declarations.
New entrants — a single phase
New providers submit essentially the Phase 2 documentation in one step, plus proof of a legitimate capital source, with no prior-operations evidence required. Foreign-exchange activity under Resolution 521 needs a separate justification (Anexo III).
The downside to build in
If authorisation is refused, withdrawn or archived, you must evidence — within 15 days — either corporate dissolution or a change of object to a non-regulated activity with a corresponding name change. Plan for it before you file.
Why start now
Existing providers who miss 30 October 2026 must cease within 30 days, and BCB-supervised institutions must stop facilitating operations with unauthorised providers — so losing banking rails is a practical shutdown ahead of any enforcement. The three-years-of-audited-financials requirement in Phase 1 alone is not something you assemble at the last minute.
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.