Central Bank of Brazil and National Monetary Council change the methodology for calculating the minimum capital requirement for financial institutions and other authorized entities

On November 3, 2025, the Central Bank of Brazil (“BCB”) and the National Monetary Council (“CMN”) published new rules reformulating the methodology for determining the minimum limit of capital stock paid in and net equity applicable to financial institutions and other institutions authorized to operate by the BCB.

The main regulation published was Joint Resolution No. 14/2025 (“Joint Resolution 14”), which establishes the methodology for determining the minimum limit of capital stock paid in and net equity to be maintained by financial institutions and other authorized institutions authorized to operate by the BCB, now considering mainly the activities performed, rather than the specific type of institution. The approach adopted by the CMN and BCB converges with the financial regulation principle of same activity, same risk, same regulation. Additionally, BCB Resolution No. 517 (“BCB Res. 517”) was published, which provides for the procedures to be observed by financial institutions and other authorized institutions in determining the minimum limit of capital stock paid in and net equity.

The regulations came into effect on the date of their publication.

Calculation Method

Joint Resolution 14 establishes that authorized institutions must determine the minimum limit of capital stock paid in and net equity by the sum of the amount associated with the following component:

1. Cost component (parcela de custo), associated with the number of operational activities and the use of relevant technological infrastructure; and
2. Activity component (parcela das atividades), which reflects the nature of the transactions, the                investment profile, and the institution’s funding structure.

Credit unions of capital and loan (cooperativas de crédito de capital e empréstimo) must maintain capital stock paid in and net equity of BRL 150,000.00. It is possible to obtain initial authorization with only 20% of this amount, provided that the total amount is paid in within a maximum period of 5 years.

Cost component (parcela de custo).

The cost component (parcela de custo) is determined by the sum of:

• BRL 2,000,000.00 for each category of operational activity reported to the BCB; and
• An additional of BRL 5,000,000.00 if the institution provides services that depend on relevant technological infrastructure, such as data processing and storage, network and security infrastructure, among others; it should be noted that if the institution offers more than one service of this nature, an additional 50% of the amount will be applied for each additional service, limited to a total of BRL 10,000,000.00.

The services considered intensive in technological infrastructure, which require the additional amount provided for in the cost component (parcela de custo), are specified by BCB Res. 517. These services include Banking as a Service, data aggregation and sharing within the scope of Open Finance, the provision of transactional accounts in Pix, and the provision of Pix settlement services for cooperatives.

Activity component (parcela das atividades).

The activity component (parcela das atividades) must be determined by:

1. Sum: amounts assigned to the categories of all operational activities plus the amount of the category in which the investment activity was classified; and
2. Multiplication: amount calculated as described in item (i) above multiplied by the factor assigned to the    category in which the funding activity was classified, in accordance with the charts below.

• Amount assigned to the categories of operational activities carried out by the institution:

• Amount assigned to the categories of investment activity:

• Amount assigned to the factor corresponding to the categories of funding activities:

For the purposes of determining the activity component (parcela das atividades), at least the categories of operational activities associated with the corporate purpose of the institution must be considered. Thus, each institutional type has a minimum set of activities that will necessarily be included in the capital calculation, in accordance with Article 3 of BCB Res. 517, even if the institution does not actually carry out certain operations in practice.

Additionally, both Joint Resolution 14 and BCB Res. 517 introduced relevant definitions for the concepts of “operational activities,” “investment activities,” and “funding activities.”

New Minimum Capital Amounts

Based on the new regulations, the minimum capital of authorized institutions, depending on the activities carried out, may vary between the minimum and maximum amounts indicated below, according to calculations presented by the BCB in a press conference held on the same date the regulations were published:

Communication

BCB Res. 517 establishes that authorized institutions must notify the BCB of the categories of operational activities they intend to carry out, as well as any intention to provide technological services subject to additional capital requirements, at least 90 days in advance of the planned start date of such new activities.

Authorization for scope expansion is conditional on full compliance with prudential requirements, including the minimum capital, as well as the regulatory compliance of the institution, which must not include significant delays in the submission of information or breaches of operational limits in the six (6) months prior to the request.

This rule does not apply to activities subject to specific authorization or communication processes, nor to institutions still in the licensing phase, which remain subject to their own procedures.

Increased capital

Joint Resolution 14 also establishes an additional of BRL 30,000,000.00 for institutions that use or will use the word “bank” or an equivalent expression in their name; provided that such additional amount does not apply to institutions that use in their name the same term used by another institution within the same prudential conglomerate, provided this is authorized under specific regulations governing the organization and operation of such institutions.

Transition period

Institutions already in operation may gradually adjust their capital by applying progressive percentages to the difference between the minimum amount required under the previous regulation and the amount calculated using the new methodology. This transition rule applies to institutions that have submitted to the BCB, by November 2, 2025, requests for authorization to operate or to expand their activities.

Until June 30, 2026, institutions remain subject to the rules of the previous regulation and must only notify the BCB of the categories of operational activities they perform. Starting July 1, 2026, the transition to the new regulation begins, according to the schedule below:

• From July 1, 2026, to December 31, 2027 – the positive difference toward the new minimum capital must be gradually incorporated, according to the following percentages:
  • 25% (twenty-five percent) by December 31, 2026;
  • 50% (fifty percent) by June 30, 2027; and
  • 75% (seventy-five percent) by December 31, 2027.
• As of January 1, 2028, 100% of the amount calculated according to the new methodology will be required.

With the revision of the methodology, the rules on the minimum limit of capital stock paid in and net equity are now consolidated and governed by Joint Resolution No. 14 and BCB Res. No. 517. All other regulations addressing the subject have been repealed.

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