BCB Normative Instruction 701: the technical certification banks and brokers need to offer virtual asset services
BCB NI 701/2026 sets how banks, CTVMs, DTVMs and FX brokers notify the Banco Central that they will provide virtual asset services, and what the technical certification by a qualified independent firm must assess.
BCB Normative Instruction 701, of 22 January 2026, regulates one specific point of BCB Resolution 520: how an institution already authorized by the Banco Central do Brasil, such as a bank or a broker, notifies it that it will provide virtual asset services, and what the technical certification attached to that notice must contain.
NI 701 does not cover the authorization application of an SPSAV, the company set up specifically to provide virtual asset services. That application follows BCB Resolution 519 and BCB NI 704, as amended by BCB NI 739. The regulations are published in Portuguese; the quotes below are our translation.
What BCB NI 701 says
Its summary:
Sets the form of notice and the minimum requirements to be observed when a qualified independent firm prepares the technical certification that accompanies the notice of interest in providing virtual asset services in Brazil, under BCB Resolution 520 of 10 November 2025.
It was published in the Official Gazette on 23 January 2026 and took effect on 2 February 2026 (art. 6), the same day as Resolution 520. It is a short regulation: six articles, split into general provisions, certification requirements and final provisions.
Who must comply with NI 701
Art. 1 points to the institutions in arts. 20, I and II, and 23, § 3, of Resolution 520:
- commercial banks, FX banks, investment banks, multiple banks and Caixa Econômica Federal;
- securities brokers (CTVMs), securities distributors (DTVMs) and FX brokers, the latter only for intermediation;
- an institution in this group that takes over from a foreign entity already providing virtual asset services in Brazil.
These institutions do not apply for a new authorization to provide intermediation and custody of virtual assets. They file a formal notice, and the technical certification gives the Banco Central what it needs to judge whether they are ready.
How to file the notice with the Banco Central
Art. 2 sets two steps, and the notice only takes effect when both are done:
- register and update the institution’s data in Unicad, the Banco Central’s registry of supervised entities;
- send the technical certification through APS-Siscom, in the Relevant Communication Module.
If either is missing, the notice has “no effect before the Banco Central do Brasil”, and the institution remains barred from providing the services (art. 2, § 1). The filing procedure is in the Relevant Communication Module manual on the Banco Central website.
BCB NI 712/2026 detailed the Unicad entry: the institution records the date of the formal notice, the intended services (intermediation, custody or both) and the name, legal name and CNPJ of the firm that prepared the certification.
Deadlines: new entrants and institutions already active
The deadlines are in Resolution 520, not in NI 701.
An institution that does not yet provide virtual asset services may only start 90 days after the formal notice. During that window, the Banco Central may block the start based on the result of the technical certification (art. 21). The institution must also have been authorized by the Banco Central for at least 365 days.
An institution that was already providing these services on 2 February 2026 has 270 days from that date to file the notice with the certification (art. 22). If it misses the deadline, it may continue for up to 30 days after it ends. Even after a notice is filed, the Banco Central may order the institution to wind down operations within 30 days.
Who can issue the technical certification
The certification is prepared by a qualified independent firm. Art. 3 asks the firm for an institutional presentation showing it is fit for the job, with:
- its existing and valid qualifications and credentials;
- a statement that there are no corporate or business ties creating a conflict of interest, signed by the institution’s responsible officer and by the certifying firm.
The presentation goes with the certification. NI 701 does not list which credentials or registrations the firm must hold. That sets it apart from the NI 739 report, which only an independent auditor registered with the CVM, the Brazilian securities regulator, can issue.
What the technical certification must assess
The core of the regulation is art. 4. The certification includes a conclusive opinion on the institution’s adequacy across at least 17 items. We grouped them by theme below for easier reading; the numbers are those of the items in the regulation.
The opinion has to reach a conclusion on each item separately. Paragraph 2 rules out “a conclusive opinion of a general nature covering all items in a consolidated way”.
Customer information is in scope as well. Paragraph 1 asks the certification to assess whether the institution clearly informs customers about its services, its contractors, the absence of a guarantee fund, custody, the asset and its DLT, staking and each customer’s holdings.
The bar is higher for institutions that were already active. In the cases of arts. 22 and 23 of Resolution 520, the certification “must ensure that the virtual asset service provider already effectively and fully meets the requirements” of the resolution (§ 5).
The Banco Central may ask for more detail on any item, within a period compatible with its complexity (§ 3). The certifying firm keeps its working papers for at least five years, available to the Banco Central (art. 5).
BCB NI 701 vs. BCB NI 739
Both normative instructions call for independent work on the operation, but they are different documents for different audiences.
| BCB NI 701/2026 | BCB NI 739/2026 | |
|---|---|---|
| Document | Technical certification | Reasonable assurance report |
| Issued by | Qualified independent firm | Independent auditor registered with the CVM |
| Filed by | Already authorized banks, CTVMs, DTVMs and FX brokers | SPSAVs applying for authorization |
| When | With the formal notice to the Banco Central | With the application or, for companies already operating, in phase 2 |
| Scope | 17 items of Resolution 520, from segregation to cybersecurity | AML/CFT controls, fraud and asset freezes |
Frequently asked questions
Does NI 701 apply to crypto exchanges?
Not directly. An exchange set up as an SPSAV applies for authorization under Resolution 519 and NI 704. NI 701 applies to banks, brokers and distributors that are already authorized and start working with virtual assets.
Does NI 701 require periodic reports?
No. It covers the certification that goes with the formal notice. Recurring obligations are in Resolution 520, such as the biennial proof-of-reserves audit.
What is the deadline for institutions already providing virtual asset services?
270 days from 2 February 2026, the date Resolution 520 took effect (art. 22). Counting the days, the deadline falls on 30 October 2026.
How Clav helps
Clav has BCB NI 701 mapped as a framework, with the opinion items organized into controls and the evidence the certifying firm will ask for. The institution’s team gathers the material in one place and tracks what is ready for the certification.