Brazil: lending & credit regulation

Regulated

Strictly regulated banking sector; no specific fintech lending license; Open Finance mandates data sharing

Also involved
CVM (securitization/CRIs) · SUSEP (insurance collateral) · PROCON (consumer disputes)
Core law
Law No. 4,595/1964 (Financial System) · Law No. 15,252/2025 (Consumer Rights)
Entry capital
BRL 100m (Bank) · BRL 50m (Savings Bank) · BRL 10m (Development Bank)
Approval timeline
6-18 months for banking charter; 3-6 months for credit securitization
Customer assets
Banks only; non-banks must use licensed custodians
Data protection
LGPD (Lei Geral de Proteção de Dados) · ANPD
Sandbox
Yes - BCB Sandbox Regulatório

Brazil maintains a highly concentrated banking sector where lending is a reserved activity for authorized financial institutions supervised by the BCB. There is no specific 'fintech' or 'lending' license; non-banks must partner with banks or obtain a banking charter. Recent regulatory focus has shifted to consumer protection (Law 15,252/2025) and Open Finance, which mandates data portability and credit score sharing to increase competition.

Which licence do you need?

Your activityRequirementCapitalTimelineAuthority
Consumer lendingLicenceFinancial Institution Charter[1][2]

Reserved activity; non-banks must partner with licensed banks

BRL 100m (Bank)6-18 monthsBanco Central do Brasil
SME / commercial lendingLicenceFinancial Institution Charter[1]

Commercial lending requires full banking license or BNDES partnership

BRL 100m (Bank)6-18 monthsBanco Central do Brasil
MicrofinanceLicenceSavings Bank or Credit Cooperative[1][3]

Pronaf rules apply; credit cooperatives have lower capital floors

BRL 50m (Savings Bank)6-12 monthsBanco Central do Brasil
Buy-now-pay-laterLicenceFinancial Institution Charter[1]

Treated as consumer credit; requires banking license or bank partnership

BRL 100m (Bank)6-18 monthsBanco Central do Brasil
P2P lending platformLicenceFinancial Institution Charter[1]

P2P lending is not a distinct legal category; requires banking license

BRL 100m (Bank)6-18 monthsBanco Central do Brasil
Credit bureau / scoringRegistrationSCR Data Provider[4][5]

Mandatory reporting to SCR; Open Finance enables data sharing

Banco Central do Brasil
Debt collectionLicenceFinancial Institution Charter[1]

Debt collection is part of credit operations; requires banking license

BRL 100m (Bank)6-18 monthsBanco Central do Brasil

New — what changed recently

  • 2026-05-04CMN Resolution No. 5,299Establishes new regulatory guidelines for natural person rights in financial services under Law 15,252/2025[1]
  • 2026-05-04BCB Resolution No. 567Mandates advisory services and minimum information disclosure for credit operations to natural persons[2]
  • 2026-02-20CVM Internal Office No. 3/2026Proposes removing non-standardized classification for credit rights in judicial recovery[6]
  • 2025-11-28Joint Resolution No. 15Amends Open Finance rules to introduce detailed provisions for credit operation portability[4]

Market-entry checklist

  1. 1Obtain BCB Banking CharterSecure authorization from Banco Central do Brasil with minimum BRL 100m capital for a bank.
  2. 2Register with SCR SystemImplement reporting systems for Credit Risk Data (Document 3040) as mandated by BCB.
  3. 3Comply with Open FinanceIntegrate with Open Finance APIs for data sharing and credit portability per Joint Resolution 15.
  4. 4Adhere to Law 15,252/2025Implement new consumer rights guidelines and advisory service requirements for credit clients.
  5. 5Secure Data Protection ComplianceEnsure full compliance with LGPD and ANPD regulations for handling customer credit data.
This guide is compiled automatically from 6 primary-source documents published by Brazil's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.