#
Brazil's safeguarding regime requires payment institutions to segregate client/end-user funds from proprietary assets and supports traceability and auditability; e-money balances are held in payment accounts with prudential treatment. BCB Rule 80/2021 sets conduct, transparency (institutions must identify themselves as PIs and disclose services), governance and cybersecurity-policy obligations. Joint Resolution No. 16 (CMN/BCB) regulates Banking-as-a-Service, and BCB Resolution 432/2024 set manager compensation policies — collectively tightening conduct accountability.
The conduct perimeter extends to Banking-as-a-Service: Joint Resolution No. 16 (CMN/BCB) regulates BaaS arrangements, defining the conduct and accountability boundary that operators must build to. Manager compensation is addressed by BCB Resolution 432/2024. Together these instruments define the consumer-fund protection model for Brazilian PIs and EMIs.
The bank versus non-bank distinction matters in safeguarding: the segregation obligation binds payment institutions specifically, with e-money balances held in payment accounts under prudential treatment, distinct from the deposit-taking treatment of bank-PSPs.
Outlook
The trajectory is established. The segregation-based safeguarding model is settled, with the BaaS conduct perimeter under Joint Resolution 16 and manager-compensation rules under Resolution 432/2024 forming the standing conduct architecture. This module is assessed rather than confirmed, reflecting the secondary sourcing underpinning the consolidated conduct picture.
Conduct, Safeguarding & Financial Promotions
Medida Provisoria 1.394/2026, signed 25 September 2026, prohibits fixed-odds betting nationwide in Brazil. From a payments-conduct perspective, this converts payment-conduct obligations that previously targeted only unlicensed betting operators into obligations that now cover the entire formerly-licensed sector, since that sector has itself become unauthorised by statute. Institutions that maintained payment relationships with licensed betting operators prior to 25 September 2026 face a conduct-obligation landscape that has shifted from a targeted compliance exercise, screening for unlicensed counterparties specifically, into a sector-wide one, where any betting-sector counterparty now falls outside authorised conduct.
Outlook
Whether this sector-wide conduct obligation persists depends on the pending Supremo Tribunal Federal challenge to the Medida Provisoria and its congressional conversion process. A reversal of the underlying prohibition would likely revert payments-conduct obligations toward their prior, narrower scope targeting unlicensed operators specifically.
Sources and findings (4)
- T1BCB Resolutions 80/81/2021 — PI conduct/governance (bcb.gov.br)
- T1BCB Resolution 494/2025 (Art. 9 authorisation) (bcb.gov.br)
- T1BCB Resolution 494/2025 — IT/cyber & authorisation (bcb.gov.br)
- T2BCB Resolutions 80/81/2021 PI conduct framework (bcb.gov.br)