Can the authorization process for crypto companies at the Central Bank take up to three years?

Depending on the case, yes.

THE BCB Resolution No. 549/2026 amended Annex II of BCB Resolution No. 108/2021, a regulation governing the structure and timelines of the phases of administrative processes for authorizing economic activity at the Central Bank of Brazil.

Resolution No. 108/2021 establishes the procedural logic applicable to these processes. In certain situations, the administrative process is divided into successive phases, each with defined maximum deadlines for analysis by the regulatory authority.

The main change introduced by Resolution No. 549/2026 was the express inclusion of virtual asset service providers (VASPs) in Annex II of the standard.

With this update, the Central Bank now establishes specific deadlines for the phases of the administrative process for authorizing the operation of these companies, especially in cases where the entity is already in operation.

According to the new regulations, the first phase of the process can last up to 360 days, while the second phase can reach 720 days.

Taken together, these steps can lead to a potential maximum timeframe of up to 1,080 days for completion of the administrative review.

Prior to the amendment introduced by Resolution No. 549/2026, Annex II of Resolution No. 108/2021 included several entities supervised by the Central Bank, such as traditional financial institutions, financial market infrastructures, and other regulated institutions. However, there was no express provision for virtual asset service providers.

The regulatory update expands the scope of the existing procedural structure and incorporates the virtual assets sector into the Central Bank's administrative workflow.

This move reflects the consolidation of the agency's role as the authority responsible for overseeing this market, especially after the evolution of the regulatory framework for virtual assets in Brazil.

From a practical standpoint, the deadlines established by the regulation represent maximum limits for administrative review and do not guarantee the automatic completion of the process within that period. The actual duration may vary depending on the complexity of the operation, the quality of the information presented, and any investigations conducted by the supervisory authority.

Nevertheless, defining these parameters contributes to greater regulatory predictability and to the planning of companies that intend to structure operations in the virtual asset market under the supervision of the Central Bank.

Article written by: Ricardo Alegransi, Marina Moreno and Piao Min You.