Brazil BCB Normative Instruction 701/2026 on VASP Technical Certification

The instruction provides that the communication must include two procedural steps: registration and updating of information in Unicad, and submission of the independent technical certification through APS-Siscom, in the Módulo de Comunicação Relevante. The text states that failure to complete all required procedures leaves the communication without effect before the central bank, meaning the applicant remains unable to provide the covered services under the applicable regulation.

The certification must be prepared by a qualified independent company. The certifier’s package must include an institutional presentation showing suitability for the work, existing and valid qualifications or credentials, and a declaration that there are no corporate or business relationships with the contracting institution that would create a conflict of interest or impair the independence of the analysis.

Article 4 describes the certification as a conclusive opinion on the applicant’s adequacy across multiple control domains. The required review areas include:

• segregation between the provider’s own virtual assets and customer or user virtual assets;
• proof-of-reserves procedures demonstrating that the provider holds the virtual assets it states it holds for customers and users;
• relevant outsourced services, including processing, data storage and cloud computing arrangements;
• technical, operational and regulatory capability of relevant service providers, including foreign providers where applicable;
• recovery plans for virtual asset positions and customer financial resources after incidents;
• AML/CFT and anti-proliferation controls, cybersecurity, incident response, internal controls, risk management, compliance and internal audit;
• asset listing, suspension and delisting policies, including controls for fiat-referenced virtual assets; and
• custody contracts, custody safeguards, redundancy mechanisms and recovery procedures for control instruments over virtual assets.

The instruction also requires the independent opinion to assess whether the provider makes adequate information available to customers and users. The specified information categories include the provider and its services, support channels, contracted institutions and services, the existence or absence of guarantee fund or insurance coverage, rights and obligations, custody and storage processes, risks related to the relevant asset and distributed-ledger system, staking information, educational risk content and updated customer position reports.

The certification must address each item specifically. General consolidated opinions are not accepted under the text. The Banco Central do Brasil may request deeper analysis or clarification, and the independent entity must keep working papers and supporting memoranda available to the central bank for at least five years.

IN BCB No. 701/2026 is dated January 22, 2026, was published in Brazil’s Federal Official Gazette on January 23, 2026, and entered into force on February 2, 2026. No separate future milestone appears in the instruction itself. Related implementation dates under Resolution BCB No. 520/2025 should be tracked separately from this technical-certification profile.