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Brazil's Central Bank Postpones Implementation Dates for Banking as a Service and Prudential Liquidity Transfer Registration Requirements

On September 17, 2026, the Central Bank of Brazil (BCB) published Normative Instruction BCB No. 776, which amends the effective dates established by Normative Instruction BCB No. 754 of July 1, 2026. The amendment delays the implementation timeline for two new registration requirements within the BCB's Information System on Entities of Interest to the Central Bank (Unicad). Normative Instruction BCB No. 754 introduced two new registration provisions to the existing Normative Instruction BCB No. 330: Article 10-G, requiring registration of entities receiving Banking as a Service (BaaS) services, and Article 10-H, requiring registration of liquidity transfers within prudential conglomerates. The original instruction established implementation dates of September 1, 2026, for Article 10-G and October 1, 2026, for Article 10-H. These deadlines have now been postponed due to operational adjustments required within Unicad. The new implementation dates are October 1, 2026, for Article 10-G and November 1, 2026, for Article 10-H. These requirements stem from regulatory developments addressing Banking as a Service arrangements and prudential liquidity management. Joint Resolution No. 16 of November 28, 2025, regulates BaaS provision, requiring service providers to maintain updated information on client entities. Additionally, Resolutions CMN No. 5.222 and BCB No. 477, both of May 30, 2025, amended prudential risk management requirements to ensure timely liquidity transfers between institutions within the same prudential conglomerate during normal and stress situations. The BCB determined that this normative instruction qualifies for exemption from regulatory impact analysis under Decree No. 10.411 of June 30, 2020, as it constitutes a postponement of existing norms without substantive modification. Normative Instruction BCB No. 776 entered into force on its publication date of September 17, 2026.

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Brazil's Central Bank Extends Implementation Deadlines for Banking as a Service and Liquidity Transfer Registration Requirements

On September 17, 2026, the Central Bank of Brazil (BCB) issued Normative Instruction BCB No. 776, amending Normative Instruction BCB No. 754 of July 1, 2026. The amendment postpones the effective dates for registering information in the Information System on Entities of Interest to the Central Bank (Unicad), which maintains cadastral data on financial institutions and other entities authorized or registered with the BCB. Normative Instruction No. 754 previously established two new registration requirements within Unicad. Article 10-G addresses the registration of Banking as a Service (BaaS) service recipients, while Article 10-H covers the registration of liquidity transfers within prudential conglomerates. These requirements implement provisions from Joint Resolution No. 16 of November 28, 2025, which regulates BaaS provision, and amendments to prudential frameworks requiring institutions to identify liquidity transfer capabilities among conglomerate members without statutory, contractual, legal or regulatory restrictions. The original implementation timeline required Article 10-G registrations to commence September 1, 2026, and Article 10-H registrations to commence October 1, 2026. However, due to necessary operational adjustments to the Unicad system, the BCB has deferred these deadlines. Article 10-G registrations now commence October 1, 2026, while Article 10-H registrations commence November 1, 2026. These extended timelines provide financial institutions and BaaS providers additional time to prepare and implement the required system updates and registration procedures. Normative Instruction No. 776 enters into force on the date of its publication, September 17, 2026, with the amended provisions taking effect according to the revised schedule outlined above.

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Central Bank of Brazil Issues BCB Normative Instruction No. 776 on Banking as a Service Registration

On September 17, 2026, the Central Bank of Brazil (BCB) issued Normative Instruction No. 776 to postpone the implementation deadlines for two registration requirements in the BCB's Information System on Entities of Interest (Unicad). The postponement is due to the need for operational adjustments to the Unicad system. Key points of the Normative Instruction include: Banking as a Service (BaaS) registration: The deadline for service provider institutions to register BaaS service recipients in Unicad is extended from September 1, 2026 to October 1, 2026. Intra-conglomerate liquidity transfer registration: The deadline for institutions to register in Unicad the entities between which liquidity transfers within the same prudential conglomerate may occur without statutory, contractual, or regulatory restrictions is extended from October 1, 2026 to November 1, 2026. The Normative Instruction enters into force on the date of its publication.