BC publishes new guidelines on PIX eligibility through BCB Resolution No. 429

On November 11, 2024, the Brazilian National Monetary Council (“CMN”) published CMN Resolution No. 429, which amends CMN Resolution No. 1, of 2020. This update introduces stricter requirements for carrying out transactions through the instant payment system called PIX, including the need for prior authorization, capital adequacy, as well as new governance and compliance procedures.

Key points of BCB Resolution No. 429:

• Mandatory PIX authorization for institutions: As of January 01, 2025, only financial and payment institutions authorized by the BC can join PIX. Current participants who are not authorized can still participate, provided that they file an authorization request within the deadlines established in the regulation, as follows:

(i) from November 2024 to March 2025, for payment institutions that joined PIX by December 2022;

(ii) from April 2025 to December 2025, for payment institutions that joined PIX from January 2023 to June 2024; and

(iii) from January 2026 to December 2026, for institutions that joined PIX from July 2024 to the end of 2024.

• Minimum share capital and equity limits: As of January 01, 2026, institutions that provide transactional accounts must permanently maintain a minimum share capital and net equity of BRL 5 million, except for credit unions.

• Temporary requirements for unauthorized institutions: Until they receive authorization, institutions must comply with specific compliance requirements, including:

• As of July 01, 2025:
  (i) Accounting and audit regulation provided for in the Accounting Plan of the National Financial System (“COSIF”), including with regard to preparing, remitting accounting documents to the BC, and publishing financial statements;
  (ii) submitting information about clients to the Client Registry of the Brazilian National Financial System (“CCS”); and
  (iii) submitting information on daily accounting balances and credit transactions; and

• As of January 01, 2026: Request for settlement and maintenance of share capital and net equity above BRL 5 million. 

• Injunctive Suspension: Participants who fail to comply with the minimum net equity established can be subject to injunctive suspension – including participants whose conduct poses a risk to the regular functioning of the payment arrangement.

Impact on institutions

These changes aim to strengthen PIX safety and supervision. By establishing stricter requirements on share capital and net equity – in addition to introducing deadlines for unauthorized institutions to adjust their situation, the BC seeks to ensure that only financially sound and well-structured institutions can join PIX. These measures aim to mitigate risks, thus providing stability to the financial system while ensuring that PIX remains a trustworthy and efficient platform for electronic transactions in Brazil.

Demarest’s Banks, Financial Services, Fintechs, and Digital Assets is monitoring the developments of this topic and remains available to assist clients and partners with any clarifications that may be necessary.