Brazil's New SPSAV Regime
This guide separates authorization from reporting. It explains what belongs in the 30 October 2026 phase 1 filing, what enters later in phase 2 and which reporting obligations begin as soon as the application is filed.
It also looks at the operational requirements behind those filings: reconciled client positions, sequential submissions, reporting precision and the evidence needed to show that controls are working in practice.
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About the report
Brazil's SPSAV Regime is a condensed guide to the Banco Central do Brasil's virtual asset framework ahead of the 30 October 2026 filing deadline. It covers the regulatory perimeter, what the authorization process requires at each phase and the CADOC 5711, 5710 and DeCripto reporting obligations that begin once an application is filed.
It is written for the responsible directors, compliance, finance and engineering teams who must turn those requirements into operating controls and evidence. The focus is not only on what the rules require, but also on whether the underlying operation can demonstrate that those requirements are being met.
Regulatory claims are cited to primary sources, including the BCB's resolutions and normative instructions, the official CADOC 5710 and 5711 layouts, RFB IN 2,291/2025 and Parecer de Orientação CVM 40.
Inside the report
- 01The regime and core instruments in one table.
- 02What the 30 October filing requires: the eight phase 1 documents and what moves into phase 2.
- 03Why phase 2 requires operating evidence: assurance tests whether controls work in practice, not just on paper.
- 04Where the authorization perimeter sits: wallets, MPC, fintechs, crypto-as-a-service, tokenizers, gaming and DeFi.
- 05Serving Brazil from abroad: the transfer requirement and available routes for foreign providers.
- 06The reporting cycle after filing: daily CADOC 5711, monthly CADOC 5710 and DeCripto.
- 07Why daily reporting is hard: sequential filings, precision requirements, omnibus wallets and CRD findings.
- 08A readiness checklist: test whether your controls already produce the evidence regulators and auditors expect.
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