Brazil Tightens Rules on Pooled Accounts, Sets Activity-Based Capital Floors for Financial Firms

Overview

• From December 1, 2025, authorized institutions must close deposit and payment accounts used to deliver unauthorized financial or payment services, including irregular “contas‑bolsão,” using their own detection criteria and keeping documentation available to the Central Bank for at least ten years.
• Regulators clarified that legitimate third‑party arrangements such as eFX flows and marketplaces are not the target of the pooled‑account prohibition.
• The new methodology for minimum capital takes effect immediately with a transition that preserves old minima until June 30, 2026, adds 25% of the difference by December 31, 2026, 50% by June 30, 2027, 75% by December 31, 2027, and reaches full application on January 1, 2028.
• Capital floors now depend on activities performed, include components for initial operating costs and technology‑intensive services, and add an extra tranche for entities using the word “banco”; roughly 500 non‑bank institutions are affected, lifting aggregate requirements from about R$5.2 billion to roughly R$9.1 billion, with payment institutions moving to R$9.2 million–R$32.8 million depending on scope.
• Officials cited recent AML and cyber cases such as Operação Carbono Oculto and a July diversion via Pix infrastructure as impetus; banks’ associations backed the changes, while fintech groups called the new minima higher than expected but said the timetable allows adjustments.