BC calls for public consultation on tokenization of digital payments

On April 04, 2025, the Central Bank of Brazil (“BC”) published Public Consultation Notice No. 118/2025, regarding the participation of data token storage service providers of debit, credit, and prepaid cards as suppliers of payment categories provided in payment arrangement regulations. Thus, the BC intends to collect contributions to regulate the services provided by digital wallet agents such as Apple Pay, Samsung Pay, and Google Pay.

These tokens replace users’ original credentials and enable payment card transactions without exposing sensitive data. With the increasing digitalization of payment methods via smartphones, smartwatches, and other devices through near-field communication (NFC), token applicants have become a strategic role in the sector, which can influence costs for card issuers and, consequently, impact consumers and merchants.

According to the corresponding notice, Public Consultation No. 118/2025 seeks to collect inputs regarding the impacts of the request and storage of tokens in numerous aspects, including:

• (i) Market structure: Analysis of the performance of tokenization service providers and the degree of influence they exert on card issuers and other participants in the payment scheme.
• (ii) Security and efficiency: Examine the practices adopted in requesting and storing tokens and whether they comply with the safety and efficiency guidelines of the Brazilian Payment System (“SPB”).
• (iii) Costs and pricing: Assessment of potential impacts of tokenization on card issuers’ tariffs and effects on consumers and merchants.
• (iv) Regulatory need: Identification of regulatory gaps and the potential need for regulatory intervention to regulate the activity.

According to the BC, incorporating tokenization service applicants into the payment scheme and imposing tariffs on them can lead to significant effects that require attention. These include discouraging innovation, creating barriers for new entrants, and reducing the quality of services, which were fundamental reasons for initiating the public consultation. Additionally, concerns about safety and efficiency can result in less robust alternative solutions.

Public Consultation No. 118/2025 is structured as a questionnaire addressing topics involving tokenization service providers and other agents integrating the sector, including operational, competitive, and regulatory matters.

Participation in the public consultation

Public Consultation No. 118/2025 will be available until June 02, 2025, and can be accessed via the Participa Mais Brasil platform.

Demarest’s Banks, Financial Services, Fintechs, and Digital Assets team is monitoring the developments of this topic and remains available to assist clients as necessary.