Banking in Brazil Regulatory Changes Analysis¶
Potential Regulatory Changes¶
The Brazilian banking value chain is significantly influenced by a dynamic and evolving regulatory landscape, primarily overseen by the Banco Central do Brasil (BCB). Several key regulatory changes are currently in progress or anticipated, carrying substantial potential impacts across the various stages of the value chain.
Open Finance: The ongoing implementation of Open Finance is a major regulatory initiative aimed at promoting competition, innovation, and efficiency by allowing customers to share their financial data securely across different institutions. This will particularly impact the Fundraising/Captation, Financial Intermediation/Lending, and Transaction Processing & Payments stages by increasing transparency, enabling more personalized product offerings, and fostering new business models based on data sharing.
DREX (Brazilian Central Bank Digital Currency): The development and eventual implementation of DREX is poised to revolutionize the Transaction Processing & Payments step. As a digital form of the Real, it could fundamentally alter payment flows, settlement processes, and potentially impact the role of traditional intermediaries in certain types of transactions. Its impact on other value chain steps, such as Fundraising/Captation and Financial Intermediation/Lending, will depend on its final design and use cases.
BaaS (Banking as a Service) Regulations: The BCB is establishing clearer regulatory frameworks for BaaS, which enables non-financial companies to offer banking services. This will significantly influence the relationship between traditional banks, digital banks, and fintechs, particularly impacting the Fundraising/Captation, Financial Intermediation/Lending, and Transaction Processing & Payments steps by facilitating new partnerships and distribution channels. New rules for BaaS require preparation from institutions.
ESG (Environmental, Social, and Governance) Requirements: Increasing global and domestic focus on ESG factors is leading to new regulations and expectations for the financial sector. This will primarily impact Risk Management, Financial Intermediation/Lending (through integration of ESG risks in credit analysis and financing of sustainable projects), and Asset Management & Wealth Management (through demand for ESG-compliant investments).
Potential Tax Changes: Discussions and potential implementation of tax reforms could significantly impact the profitability and operational costs across the entire value chain. The specific effects would depend on the nature of the changes, but they could influence everything from transaction costs in payments to the tax burden on financial products and services.
Stricter Compliance and Data Privacy (PLD-FTP, LGPD): The continuous reinforcement of Anti-Money Laundering and Combating the Financing of Terrorism (PLD-FTP) regulations and the enforcement of the Lei Geral de Proteção de Dados (LGPD) necessitate significant investments in compliance infrastructure, processes, and technology across all support activities. This impacts Legal & Compliance and Technology & IT Management, with downstream effects on all core functions due to increased operational complexity and costs., Compliance perspectives for 2025 highlight continued trends in this area.
Regulation of Financial Education: The BCB has regulated the actions of the financial sector in financial education, indicating a regulatory push towards improving financial literacy and inclusion. This impacts the Marketing & Sales and potentially the Fundraising/Captation and Financial Intermediation/Lending steps as institutions may need to develop and implement financial education programs for customers.
These regulatory changes collectively point towards a future where the Brazilian banking value chain will be more open, digitally integrated, subject to increased scrutiny on risk and compliance, and potentially influenced by new forms of digital currency and evolving tax structures.
Table of Potential Impact of Regulatory Changes¶
| Regulatory Change | Potential Impact on Value Chain Stage | Nature of Impact (Positive/Negative/Neutral/Mixed) |
|---|---|---|
| Open Finance | Fundraising/Captation: Increased competition for deposits, opportunities for personalized offerings. Financial Intermediation/Lending: Enhanced credit assessment with more data, new lending models. Transaction Processing & Payments: Increased competition, potential for integrated payment experiences. Asset Management & Wealth Management: Easier data aggregation for financial planning, new distribution channels. Support Activities (Technology, Compliance): Need for API development, enhanced data security and consent management. |
Mixed (Increased competition, new opportunities) |
| DREX (CBDC) | Transaction Processing & Payments: Potential disruption of existing payment systems, new settlement mechanisms. Fundraising/Captation: Potential new form of digital liability. Financial Intermediation/Lending: Potential for new forms of digital collateral or loan disbursement. Technology & IT Management: Need for new infrastructure and system integration. |
Mixed (Disruption, efficiency gains) |
| BaaS Regulations | Fundraising/Captation: New avenues for deposit taking through partnerships. Financial Intermediation/Lending: Expanded reach for lending products via third parties. Transaction Processing & Payments: Increased volume and new service offerings through partnerships. Support Activities (Legal, Compliance, Technology): Need for clear contractual frameworks, risk sharing models, and robust APIs. |
Positive (New business models, expanded reach) |
| ESG Requirements | Financial Intermediation/Lending: Integration of ESG factors in credit decisions, financing of green projects. Asset Management & Wealth Management: Increased demand for and offering of ESG funds and sustainable investment products. Risk Management: Development of frameworks for assessing climate and social risks. Compliance: Reporting and disclosure requirements. |
Mixed (New opportunities, increased compliance burden) |
| Potential Tax Changes | All Core Functions: Impact on profitability, pricing of products and services. Support Activities (Finance & Accounting): Changes in tax calculation, reporting, and planning. |
Mixed (Depends on the specific changes, likely increased complexity) |
| Stricter Compliance (PLD-FTP, LGPD) | All Core Functions: Increased operational costs due to enhanced verification and monitoring. Support Activities (Legal & Compliance, Technology): Significant investment in systems, processes, and training. Risk of penalties for non-compliance. |
Negative (Increased costs, operational complexity) |
| Regulation of Financial Education | Fundraising/Captation: Development of educational programs for depositors. Financial Intermediation/Lending: Education for borrowers on responsible credit use. Marketing & Sales: Integration of educational content in customer interactions. |
Positive (Improved customer base, long-term sustainability) |
References¶
- Agência Gov. (2023, December 28). BC regula atuação em educação financeira do setor financeiro. Retrieved from https://www.gov.br/pt-br/noticias/financas-e-impostos/2023/12/bc-regula-atuacao-em-educacao-financeira-do-setor-financeiro
- Banco Central do Brasil. (2024, March 15). Open Finance, tokenização, inteligência artificial e medidas prudenciais: conheça a agenda da área de regulação do BC para 2024. Retrieved from https://edicao-www.bcb.gov.br/detalhenoticia/11026/tags/Agenda%20BC%23
- Banco Central do Brasil. (2025, April 28). BC elenca prioridades regulatórias para 2025/2026. Retrieved from https://edicao-www.bcb.gov.br/detalhenoticia/11364/tags/Agenda%20BC%23
- CBRdoc. (2024, December 12). Reforma tributária e seus impactos no setor bancário em 2025. Retrieved from https://www.cbrdoc.com.br/blog/reforma-tributaria-setor-bancario-2025/
- Deloitte Brasil. (n.d.). Perspectivas para a indústria bancária em 2025. Retrieved from https://www2.deloitte.com/br/pt/pages/financial-services/articles/perspectivas-industria-bancaria.html
- IT Forum. (2025, April 3). Novas regras do Banco Central para BaaS exigem preparação. Retrieved from https://itforum.com.br/noticias/novas-regras-do-banco-central-para-baas-exigem-preparacao/
- IPLD. (2025, February 20). Previsões para 2025: O que está no horizonte para o setor financeiro em relação à PLD-FTP, Compliance e Integridade? – Parte 2. Retrieved from https://www.ipld.com.br/previsoes-para-2025-o-que-esta-no-horizonte-para-o-setor-financeiro-em-relacao-a-pld-ftp-compliance-e-integridade-parte-2/
- Mattos Filho. (2025, January 28). Perspectivas de Compliance para 2025: tendências e oportunidades. Retrieved from https://www.mattosfilho.com.br/pt/insights/artigos/perspectivas-de-compliance-para-2025-tendencias-e-oportunidades
- PwC. (n.d.). Perspectivas do setor bancário a partir de 2025. Retrieved from https://www.pwc.com.br/pt/servicos/assets/financial-services/pwc-perspectivas-setor-bancario-2025.pdf