Launching an Offshore Neobank: What Brazil Requires in 2026

An offshore neobank can be incorporated outside Brazil, but it cannot take funds or provide financial services to clients in the country without authorization from the Central Bank of Brazil (BCB). Law 4,595/1964 (art. 18) and Law 12,865/2013 (art. 9) make the BCB the gatekeeper. Operating without authorization may constitute a crime under art. 16 of Law 7,492/1986.

Can I launch an offshore neobank for Brazilian clients?

Only if the activity is authorized in Brazil. Having a company and a license abroad does not, by itself, give you the right to offer an account, card or transfer to people who live here. Law No. 4,595/1964 (Lei 4.595/1964), art. 18, says financial institutions may only operate in the country with prior authorization from the Central Bank or a decree of the Executive Branch, when they are foreign.

In practice, the design changes depending on the audience:

Consult a regulatory lawyer before defining the audience. That choice decides the rest of the structure.

What does the Central Bank authorize in Brazil?

The BCB authorizes the incorporation and operation of payment institutions and regulates and supervises them. Art. 9 of Law No. 12,865/2013 (Lei 12.865/2013) lists the BCB's powers, among them authorizing the establishment of payment arrangements (item IV) and the incorporation, operation, transfer of control, merger, spin-off and absorption of a payment institution (item V). Item V expressly mentions cases involving the participation of non-resident individuals or legal entities.

Art. 6, item III, defines a payment institution by the activities it carries out, such as:

• •providing a service for depositing or withdrawing funds held in a payment account;
• •executing or facilitating payment instructions, including transfers to or from a payment account;
• •managing a payment account;
• •issuing a payment instrument;
• •accrediting the acceptance of a payment instrument;
• •executing remittance of funds;
• •converting physical or book-entry currency into electronic money, or the reverse, and managing the use of electronic money.

Anyone who carries out one of these activities with clients in Brazil should look at this list before any launch. The rules on incorporation, capital and applications for authorization of payment institutions are in BCB Resolution 80/2021, which has already been amended. BCB Vote 206/2022, which proposes one of those amendments, states that the resolution covers the categories, the scope of activities, the forms of incorporation, the authorization requirement and the minimum capital. Because the rule changes, always check the current version in the BCB rules search.

What happens if I operate with Brazilians without authorization?

There is criminal and regulatory risk. Art. 1 of Law 7,492/1986 defines a financial institution as a legal entity whose activity, principal or ancillary, is the collection, intermediation or investment of third-party financial resources, in national or foreign currency. Art. 16 punishes anyone who operates a financial institution without proper authorization, with 1 to 4 years of imprisonment and a fine.

This does not mean every digital product is a financial institution. The classification depends on the real activity: someone who receives, holds and moves third-party money is closer to the line than someone who merely licenses software. That is why the contract, the flow of money and who owns the account matter more than the name "neobank".

Does a foreign license replace BCB authorization?

Not for serving clients in Brazil. Each regulator authorizes the activity in its own territory. In the United Kingdom, for example, the FCA explains that payment services are listed in Schedule 1 of the Payment Services Regulations 2017 and that electronic money is governed by the Electronic Money Regulations 2011. That authorization covers what British law defines, not the Brazilian market.

Costs, minimum capital and licensing timelines vary by country and by category. This article does not use price tables without an official source: ask the regulator of each jurisdiction. For the United Kingdom, start with the FCA page on payments and e-money regulations.

Which structures make sense for a Brazilian founder?

There are three paths, and each has its own regulatory logic:

1. •Neobank outside Brazil, for clients outside Brazil. The company is licensed in the chosen jurisdiction and serves only those who are there. A founder resident in Brazil still has personal obligations, described below.
2. •Fintech authorized in Brazil. The company applies to the BCB for authorization as a payment institution or another applicable category, and may have non-resident partners, under art. 9, item V, of Law 12,865/2013.
3. •Partnership with an already authorized institution. The company develops the interface and the product, and the authorized institution keeps the regulated activity. Who answers to the regulator depends on the design of the contract and the BCB rule, so validate the model before launching.

For a software business that does not hold or move client money, a company in Delaware or Wyoming may serve as the operating vehicle, subject to analysis of the specific case. See the profiles of Delaware and Wyoming and the offshore banking service to understand the role of the company's bank account, which is a different thing from being the bank.

What obligations does the Brazilian partner have regarding the company abroad?

Even if licensed abroad, the company has a partner resident in Brazil, and that creates obligations for that partner. Art. 5 of Law No. 14,754/2023 (Lei 14.754/2023) deals with profits earned by entities controlled abroad by resident individuals, in the cases provided by the law, which are taxed on December 31 of each year. The law also defines when an entity is considered controlled, based on direct or indirect ownership and voting rights.

Besides the tax, the individual must report assets and rights abroad. The Central Bank maintains a page on the Declaration of Brazilian Capital Abroad (CBE), with the current rules and thresholds. For the tax side, see international tax planning, the ECF declaration for affiliated companies abroad and the compliance service.

What is the safe order for launching?

Follow a sequence that avoids redoing the structure later:

1. •Define who the client will be, in which countries, and what products it will have (account, card, remittance, credit).
2. •Compare those products with the activities in art. 6, item III, of Law 12,865/2013 and with BCB rules.
3. •Choose the regulator's jurisdiction according to the audience and confirm with it the type of license, the capital and the timelines.
4. •Define the corporate structure, with the Brazilian partner's participation and their obligations under Law 14,754/2023.
5. •Build the anti-money-laundering and know-your-customer policies required by the regulator of each market.
6. •Only then contract technology, partners and issuers.