BCB Resolution No. 594

The Central Bank of Brazil (BCB) issued Resolution BCB No. 594 on September 30, 2026, which amends Table I (public acts of release with risk level III) of the annex to Resolution BCB No. 317/2023 and Annexes I and II to Resolution BCB No. 108/2021, rules that establish the maximum deadlines for administrative decisions on requests submitted to the agency by institutions under its supervision. Although the rule covers several supervised segments, this article focuses on the changes affecting virtual asset service providers (VASSPs). According to its Article 3, the new deadlines apply only to requests filed from October 2, 2026, the date of its publication and entry into force. Processes initiated before that date remain subject to the previously applicable deadlines.

What changes

For SPSAVs (Special Purpose Vehicle Securities and Exchange Commissions), certain requests whose decision could take up to 360 days, a deadline set by BCB Resolution No. 548/2026, will now have a maximum deadline of 540 days, an increase of 180 days, or 50%. The extension covers requests for (i) change of SPSAV type; (ii) transfer or alteration of corporate control; (iii) merger, spin-off or incorporation; (iv) change of corporate purpose; and (v) authorization to carry out operations in the foreign exchange market. With the change, these requests will now observe the same deadlines applicable to foreign exchange brokerage firms and securities distribution and brokerage firms, with which SPSAVs share the same group in Table I, except for the change of type, a case specific to SPSAVs.

Resolution BCB No. 594 is not limited to the virtual asset market. By providing a complete new wording to Table I and Annexes I and II of Resolution BCB No. 108/2021, which deal, respectively, with the maximum deadlines for applications from institutions governed by Law No. 4,595/1964 and Complementary Law No. 130/2009 and the specific deadlines per phase, the regulation consolidates the deadlines applicable to various segments supervised by the BCB, such as payment institutions, consortium administrators, leasing companies, savings and loan associations, and institutions operating financial market systems. Participants in these segments should check the new tables for the deadlines applicable to their respective applications.

What remains unchanged

The deadlines for initial authorization to operate SPSAVs, established by BCB Resolutions No. 548 and 549/2026, have been maintained. For companies that were already providing virtual asset services when the regulation came into effect, the total deadline remains up to 1,080 days, divided into two phases (up to 360 days in Phase 1 and up to 720 days in Phase 2), as per Annex II to BCB Resolution No. 108/2021. For companies that were not in operation, the deadline remains up to 720 days. The deadlines of 180 days for corporate transformation and changes in the value of share capital and 90 days for changes in company name also remain in effect.

Regulatory context and the October 30, 2026 deadline

Resolution BCB No. 594 is part of the regulatory framework for virtual assets established by Law No. 14,478/2022 and regulated, within the scope of the BCB, by BCB Resolutions No. 519, 520 and 521, published in November 2025 and in force since February 2, 2026. Under the transition rules, companies that already provided virtual asset services must file a request for authorization to operate as a SPSAV, with the Phase 1 documentation, by October 30, 2026, in accordance with BCB Normative Instruction No. 704.

Companies that file their application in a timely manner may continue operating during the BCB's analysis, but are prohibited from expanding their activities. Those that do not file their application within the regulatory deadline may only continue operating for up to 30 days after the deadline for submitting the authorization application. Furthermore, as of November 6, 2026, the date set by BCB Resolution No. 589/2026, financial institutions, payment institutions, and other institutions authorized to operate by the BCB are prohibited from carrying out or facilitating operations in the virtual asset market with counterparties that provide these services without authorization to operate in the country, except for the cases expressly permitted in BCB Resolution No. 520/2025.

Impacts on corporate transactions in the sector

The extension of deadlines directly affects the planning of operations involving SPSAVs (Single Service Providers, Sales and Assistance Companies). Corporate reorganizations, acquisitions of stakes that imply a change of control, mergers, spin-offs and incorporations, as well as changes in business type or corporate purpose, now require schedules that consider the possibility of analysis for up to 540 days.

This refers to the maximum time limit for an administrative decision, the counting of which, according to BCB Resolution No. 108/2021, begins with the proper processing of the application and may be suspended when the BCB requires additional documents or in the event of new facts. As a general rule, the expiration of the deadline does not imply tacit approval of the application. The actual processing time will therefore depend on the proper processing of the application and the timely fulfillment of any requirements made by the BCB.

This timeline should be reflected in share purchase and sale agreements, especially in the precedent conditions linked to BCB approval, the final closing dates for transactions, and the obligations assumed by the parties between signing and closing. For SPSAVs whose authorization request is still under review, attention should be paid to the sequencing of any corporate-related requests before the BCB.

Mazzucco & Mello Advogados monitors regulatory developments and advises clients on structuring authorization requests and corporate transactions before the Central Bank of Brazil.

Article prepared by: Antonio Mazzucco, Paula Suraci and Marcos Buzo.

• “The extension to 540 days does not alter the initial authorization deadlines for SPSAVs, but it lengthens the path for subsequent reorganizations. Operations involving changes of control, mergers, spin-offs, or acquisitions should be planned with this timeframe in mind from the outset.”
• “BCB Resolution No. 594 was issued less than a month before the October 30, 2026 deadline for companies already operating in the sector to file their authorization requests. For them, timely filing is a condition for the continuation of operations during the Central Bank's analysis.”