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Asset tokenization in Brazil: the CVM, Resolution 88 crowdfunding and the Central Bank’s new regime

2 OCT 2026 2 MIN READ Jesús Sánchez Fernández

Asset tokenization in Brazil: the CVM, Resolution 88 crowdfunding and the Central Bank’s new regime

Brazil is the most mature tokenization market in Latin America: more than 13.5 billion reais tokenized since 2012, nearly half of it in 2026 alone, mostly in debentures, commercial notes and receivables. It works because the split of powers is clear: if the token is a security, the CVM is in charge; if it is a virtual asset, the Central Bank.

The split: the CVM for securities, the Central Bank for virtual assets

The Securities and Exchange Commission of Brazil (CVM) supervises securities under Law 6,385/1976. Its Guidance Opinion 40 (2022) sets the test: a token is a security according to its economic substance, and the CVM has clarified that receivables and fixed-income tokens can be securities. Law 14,478/2022 created the crypto-asset framework and Decree 11,563/2023 tasked the Central Bank of Brazil with authorising and supervising providers, leaving out assets that are securities. Central Bank Resolutions 519, 520 and 521, in force since 2 February 2026, govern their authorisation and operation as intermediaries, custodians or brokers, with 270 days for existing providers to adapt.

The three routes to tokenize

  • Investment crowdfunding (CVM Resolution 88/2022): up to 15 million reais per issuer per year; the reform under consultation proposes raising it to 25. It is the most used route for tokenized offerings.
  • Securitisation and debentures with a fiduciary regime and segregated estate (Law 14,430/2022), recorded on DLT through authorised infrastructures such as BEE4, which left the CVM sandbox with definitive licences in 2025.
  • Funds regulated by CVM Resolution 175.

Brazil has no general trust like the rest of the region; the segregated estate of securitisation plays that role.

What is coming: the CVM DLT pilot

On 15 September 2026 the CVM tokenization working group delivered a proposed DLT Pilot Programme to test the issuance, trading, custody and settlement of shares, debentures, receivables certificates and fund units. It is a proposal, not yet a rule. The Central Bank’s Drex, by contrast, starts in 2026 without blockchain or tokenization.

For an issuer from abroad

Brazil is viable if the token qualifies as a security and is placed through one of the three routes. An issuer with assets or investors in Brazil will need a regulated local partner and Brazilian counsel; we bring the technical structure and the comparison with the rest of the region.

How we work with issuers in the country

The anatomy does not change from country to country: classification of the asset, a vehicle with segregated assets, a token with transfer restrictions, verified identity on every transfer and serious custody — the seven-layer platform we build, with the local legal layer on top and a local counsel alongside. The full map of the region is in asset tokenization in Latin America.

Framework as of 2 October 2026, checked against official sources; regimes change — confirm the current status before structuring. A project with assets or investors in Brazil? Talk to us.

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