A neobank license in Brazil is a Central Bank (BCB) authorization for what the company does with customer money: a bank authorization to take deposits, a payment institution authorization to hold balances in reais, or a licensed partner that holds one on its behalf. The app, the brand and the screens need none.
Two rules changed in the past year: every payment institution now applies before it starts (Resolution BCB 494 of September 5, 2025), and the capital floor was rebuilt (Joint Resolution 14 of November 3, 2025). The stablecoin regulation guide has the wider picture.
Which authorization does a neobank in Brazil need?
A neobank that holds reais, lends or lets users hold stablecoins without an authorization, its own or a partner's, breaks the rules. Brazilian law asks what the company does with the money and who is authorized to do it, and Pix (Brazil's instant payment system, run by the Central Bank) follows the same logic. The answer sorts into five cases.
What a neobank does in Brazil, the authorization it triggers and whether a partner can hold it
What the neobank does | Authorization | Norm | Can a partner hold it? |
Runs the brand and app on a partner's accounts, holding nothing | None of its own, the partner's | Pix Regulation, Arts. 90 and 90-A | Yes, this is the arrangement |
Holds customer balances in reais and provides payment accounts | Payment institution as e-money issuer (emissor de moeda eletrônica), or a bank | Resolution BCB 80/2021, Art. 3, item 1 | Yes, within the Pix limits |
Issues credit cards, acquires merchants, or initiates payments from accounts held elsewhere | Payment institution as post-paid issuer, acquirer (credenciador) or initiator, or a bank | Resolution BCB 80/2021, Art. 3, items 2 to 4 | Yes |
Takes deposits or lends from its own balance sheet | A bank, or another type on the CMN list (direct credit company, person-to-person lender) | Resolution CMN 4.970/2021, Art. 1 | Only through the partner's own product |
Lets users hold, convert or send stablecoins | SPSAV (Sociedade Prestadora de Serviços de Ativos Virtuais, the company type that holds a PSAV authorization) | Law 14.478/2022, Resolution BCB 520/2025, Arts. 7 and 9 | Yes, through an authorized provider |
Only the first row needs nothing of its own, because someone else does the regulated part.
Can an app call itself a bank? Not while it runs on a payment institution, whose name carries the words "Instituição de Pagamento" and whose channels state that status clearly (Resolution BCB 80, Art. 5, §4). Whether a brand may say "bank" on a partner's accounts is a question for counsel.
On Lumx, the neobank discloses what it does with client funds during onboarding, and the docs say that not disclosing relevant activity can lead to rejection, suspension or termination.
Four routes to launch, compared
The route decides who answers to the BCB for the balance on day one. Partner routes let a small team launch, at the cost of the partner's standards.
Four routes to a Brazilian neobank, by who holds the balance and what the team carries
Route | Who holds the balance | What the team carries |
Own bank | The neobank | Deposit and credit supervision, the capital floor, authorization under Resolution CMN 4.970/2021 |
Own payment institution | The neobank, with liquid resources matching e-money balances, held in cash at the BCB or federal bonds (Resolution BCB 80, Art. 22) | Authorization under Resolutions BCB 80 and 81/2021, the capital floor, governance, Pix participation (direct or through a third party) |
Partner bank or payment institution | The partner | Product, brand and users, plus a contract the BCB can inspect |
Partner first, own authorization later | The partner now, the neobank later | Both, plus moving balances and contracts |
On Lumx, each user of the neobank is onboarded as a Lumx customer and gets a wallet of their own once approved.
What does your own payment institution authorization take?
Applying first is now the rule, and it has a cost for anyone already running: an issuer or acquirer that did not file in the May 2026 window could keep operating only thirty days after it (Resolution BCB 494, Art. 9-A, §1). Article 9 of Resolution BCB 80 now has every payment institution request authorization to begin, listing each service type it plans to run, and the old R$500 million trigger is revoked.
The company has a set shape. It is a limited company or a corporation, never with a natural person as its only partner (Art. 5, §1), and a limited company needs at least three administrators (Art. 7). Under Resolution BCB 81 of March 25, 2021, the BCB reviews the controllers' finances, the origin of the capital, the business model and the IT infrastructure (Art. 2).
Capital follows a formula. Joint Resolution 14 revoked the flat R$2 million per service type (Resolution BCB 80, Art. 17). The new floor starts at R$2 million for each category of operational activity reported, and Article 4 lists four, from lending to plain services (Art. 9). It adds R$5 million when the services depend on data and network infrastructure, capped at R$10 million for that component, and then an activity-based portion (Art. 10).
How long does it take? For a payment institution, Resolution BCB 81 sets no number: Article 4 leaves procedures and deadlines to the BCB's published rules. For a bank, Annex 1 of Resolution BCB 108/2021, rewritten by Resolution BCB 594 of September 30, 2026, caps the decision at 540 days, up from 360, and a missed deadline is not an approval (Art. 5, sole paragraph). The clock starts only when the file is complete (Art. 2).
Can founders outside Brazil apply? The applicant is a Brazilian limited company or corporation. Direct control can sit with natural persons, BCB-authorized institutions, foreign financial institutions or a Brazilian holding company (Resolution BCB 81, Art. 7), and the text sets no nationality for the natural persons. Entity and tax presence is its own topic, in our local-entity guide.
Anti-money-laundering rules come with it. Resolution BCB 561 uses Circular BCB 3.978 of January 23, 2020 as the yardstick for eFX providers' internal controls, and our AML guide covers what the rules ask of a stablecoin flow.
Pix access depends on it: since January 1, 2025, only institutions authorized by the BCB can apply to join (Resolution BCB 1 of August 12, 2020, Art. 3, §8, added by Resolution BCB 429 of November 11, 2024).
On Lumx, KYC (know your customer, the verification of an individual) runs through Sumsub and monitoring through Chainalysis, and money services without the licences their jurisdiction requires are on the prohibited list, so a neobank that needs an authorization and has neither it nor a partner holding it is rejected in compliance review.
How does a partner arrangement work, and what does the Central Bank limit?
A partner route fails when the contract splits Pix the wrong way, and the partner answers to the BCB for it. The partner holds the authorization and the accounts, and the neobank runs the product.
The Pix Regulation lets a participant hire third parties by a specific contract (Art. 90). The contract gives the BCB access to the third party's documents and lets the participant end it (§2), and the participant stays directly responsible (§3).
Article 90-A, as amended by Resolution BCB 403 of July 22, 2024, restricts the split. A third party that holds a deposit, savings or prepaid payment account cannot be assigned Pix through an account it provides to the end user, and one without such an account cannot be assigned Pix initiation through the participant's account. Counsel should test both against the real flow of money.
On Lumx, a virtual account is issued by a Lumx banking partner in the customer's name, and the partner holds the funds and runs the rails. BRL accounts are named, so on a Pix payout the recipient sees the customer's name as payer, not Lumx.
When a partner's authorization is not enough
The partner's authorization covers its own modalities only. A neobank steps outside it with lending, deposits or pooled money for people the partner has not onboarded, with balances held by a partner authorized only as a payment initiator (Resolution BCB 80, Art. 3, item 4), and with a stablecoin counterparty that is not authorized.
On Lumx, a customer cannot pass through funds that belong to parties Lumx has not onboarded, so pooled money for the neobank's users is not a workaround.
Stablecoin balances sit under a second regime
Letting users hold USDC puts the neobank or its provider under a separate regime, and from November 6, 2026 your partner under a ban.
Law 14.478/2022 requires authorization for companies that provide virtual asset services to third parties, and Resolution BCB 520/2025 sets the rules (Art. 7 on intermediation, Art. 9 on custody). A neobank that lets users hold USDC uses a provider that performs these services, and whether the neobank itself falls inside the definition depends on the product design, so ask counsel. The PSAV explainer and the regulation guide above hold the detail.
What reaches a neobank is Article 91 of Resolution 520, as rewritten by Resolution BCB 589 of September 23, 2026: from November 6, 2026, financial institutions and payment institutions may not carry out or enable virtual asset operations with counterparties that provide these services and are not authorized in Brazil. The first text set October 30 and also spared counterparties in the authorization process. Ask your partner how Article 91 applies to it, and your provider for its status in writing.
The eFX regime for sending money abroad is separate: a provider outside the listed types must request payment institution authorization by May 31, 2027 (Art. 56-B of Resolution BCB 277/2022, added by Resolution BCB 561 of April 30, 2026).
On Lumx, Lumx Sociedade Prestadora de Serviços de Ativos Virtuais Ltda acts as a virtual asset service provider and is adapting to the SPSAV regime under Central Bank of Brazil Resolution 520/2025, operating under the Article 88 transition regime. It has filed its authorization request, and a VASP status in writing is a fair ask.
How the same question looks in the United States, Mexico and the European Union
A Brazilian authorization does not travel, so each new market restarts the question.
Where the authorization sits in four markets
Market | Regulator | Route for holding customer money | Registration or crypto layer |
Brazil | Central Bank of Brazil | Bank (Resolution CMN 4.970/2021) or payment institution (Resolution BCB 80/2021) | SPSAV under Law 14.478/2022 |
United States | FinCEN | Money services business registration: Form 107, within 180 days of establishment, renewed every two years. State licensing is not covered here | See the GENIUS Act guide |
Mexico | CNBV (Mexico's banking and securities regulator) | Electronic payment funds institution (IFPE), authorized by the CNBV, for the acts in Article 22 of the Fintech Law of March 9, 2018 | See the Mexico guide |
European Union | National authorities | Payment institution (Directive (EU) 2015/2366) or e-money institution (Directive 2009/110/EC) | MiCA, Regulation (EU) 2023/1114 |
On Lumx, Lumx US OP LLC is a FinCEN-registered Money Services Business and not a state-licensed money transmitter, with regulated money transmission conducted through licensed financial-institution partners. EUR and GBP accounts run through a banking partner, with no Lumx licence in the EU.
Launch on a partner, and file later
I recommend that a neobank starting in Brazil launch on a licensed partner and file its own payment institution authorization only when the product has shown which accounts it needs to run itself. The reason is sequence: the capital floor and the governance work come due before the first user arrives, and the partner route lets the user arrive first. Before signing with a partner I would ask who is the account holder of record for each balance, what the partner needs to see from the neobank's onboarding and monitoring, and what happens to the balances if the partnership ends. A neobank that cannot answer the third question has not chosen a route yet.
What this looks like on Lumx for a Brazilian neobank
Lumx is stablecoin payments infrastructure for businesses that move money between Latin America and the rest of the world: one API to collect, hold, convert, and pay out in BRL, MXN, COP, USD, EUR, and GBP or in USDC and USDT, over local rails such as PIX, SPEI, PSE, Bre-B, ACH, FEDWIRE, SEPA, and Faster Payments, with SWIFT and on-behalf-of payments and collections (POBO and COBO) in USD, EUR, and GBP, plus named virtual accounts, custodial wallets, and KYB/KYC built in.
Lumx is not a bank or a payment institution, and it does not replace the authorization or the partner. It does serve neobanks that run on a licensed partner, with no authorization of their own. The neobank onboards its users as Lumx customers, who accept Lumx's Terms of Service through an acceptance link your app requests from the API and pass KYC. A business user goes through KYB (know your business, the verification of a company and its owners; see what KYB is).
A named virtual account is a local account number issued in the customer's own name (product page). A company outside Brazil holds a named BRL account without a local entity in Brazil (multi-currency accounts without a local entity), which says where it collects reais, not whether it may serve users there.
The operator map shows which regulated entity handles which step, supported countries lists where Lumx onboards, and coverage page lists rails and settlement times. For the dollar-balance screens, see launching a dollar account app; the basics are in regulation and compliance in stablecoin infrastructure.
Methodology and sources
The BCB resolutions (1/2020, 80/2021, 81/2021, 108/2021, 494/2025, 520/2025, 561/2026, 589/2026), Joint Resolution 14/2025 and Resolution CMN 4.970/2021 were read on November 1, 2026 from the text served by the BCB's normative search endpoint, because the bcb.gov.br pages return only a JavaScript shell. Law 14.478/2022 is cited from the BCB texts that reference it, because planalto.gov.br did not answer. US registration comes from FinCEN's MSB page, and the EU texts are cited by number because EUR-Lex returned no text. Lumx's requirements come from docs.lumx.io, read on November 1, 2026.
Verified on November 1, 2026. Operational context, not legal, tax, or investment advice. BCB resolutions and Resolution CMN 4.970/2021 read from the BCB normative search endpoint on November 1, 2026. FinCEN MSB registration checked against fincen.gov on November 1, 2026. Fintech Law of March 9, 2018 checked against the CNBV page on November 1, 2026.
Cover photo: Miles Smith on Unsplash.
Do you need a license to launch a neobank in Brazil?
You need authorization from the Central Bank of Brazil for whatever the product does with customer money, or a partner that holds it. A bank covers deposits and lending, a payment institution covers balances in reais, cards and payment initiation, and an app that only shows a partner's balances needs none. On Lumx, the neobank is a customer and each of its users onboards as a customer of their own.
How much capital does a payment institution need in Brazil?
Joint Resolution 14 of November 3, 2025 sets a floor of R$2 million per category of operational activity reported, plus R$5 million when the services depend on data and network infrastructure, plus an activity-based portion. On Lumx, KYB asks which regulated activities the company carries out and, when they apply, requests the corresponding licence.
How long does a Central Bank authorization take?
The payment institution rules set no number and leave deadlines to the BCB's published procedures. For banks, Resolution BCB 108, Annex 1, as rewritten by Resolution BCB 594 of September 30, 2026, caps the decision at 540 days from a complete file. On Lumx, a customer that holds client funds is high-risk, and the docs tell it to plan for verification windows beyond the standard SLA.
Can foreign founders or a foreign-owned company get a payment institution authorization in Brazil?
The applicant is a Brazilian limited company or corporation. Resolution BCB 81, Article 7 lets natural persons, authorized institutions, foreign financial institutions and Brazilian holding companies hold direct control, with no nationality set for the natural persons. On Lumx, a company outside Brazil holds a named BRL account without a local entity in Brazil.
Does holding dollar balances in stablecoins need another authorization?
Providing virtual asset services to third parties, such as trading or custody, needs a separate authorization under Law 14.478/2022 and Resolution BCB 520/2025. From November 6, 2026, banks and payment institutions may not enable operations with unauthorized providers (Art. 91). On Lumx, the Brazilian entity has filed its request and operates under the Article 88 transition, and a client can ask for its status in writing.
