Resolution 249 allows testing of issuance, trading, custody and settlement within a single structure, including arrangements without an intermediary or a central securities depository. The findings could inform changes to Brazil’s market rules and structure.
October 14, 2026
Brazil’s Securities and Exchange Commission (Comissão de Valores Mobiliários, or CVM), the country’s capital markets regulator, has launched an experimental initiative with the potential to reshape how Brazilian capital markets are organized. Under Resolution 249, released on Wednesday, the regulator will allow testing of on-chain operations that bring functions such as securities issuance, distribution, trading, custody and settlement together under one entity and within a single digital environment. The experiments may include arrangements without an intermediary or a central securities depository.
The economic significance of this opening lies in the possibility of reorganizing the services that underpin an investment. By allowing different combinations of functions, the CVM is creating conditions to assess which activities can be integrated, which controls must accompany them and how responsibilities should be allocated.
For financial institutions and infrastructure providers, the discussion involves costs, revenues and competitive positioning. If the experiments demonstrate that certain services can operate safely within an integrated structure, their findings could support proposals to change market rules.
Integrating functions is the central issue
The provision with the broadest implications for this discussion is Article 15, item VIII. It allows arrangements in which a single entity performs two or more stages of the securities lifecycle in an environment based on distributed ledger technology (DLT), which includes blockchains.
The scope allows testing of operations involving shares, debentures, receivables certificates and investment fund units, among other instruments. Test cases may also cover income payments, amortization, redemptions, conversions and the creation of liens and encumbrances. The assessment can therefore follow an investment from issuance through subsequent lifecycle events.
The economic hypothesis is that shared records and programmable procedures can reduce duplicated tasks, discrepancies between systems and the need for reconciliation. A trade could update positions and trigger settlement procedures within a coordinated workflow.
The resolution provides, for example, for delivery-versus-payment mechanisms, in which the transfer of an asset is conditional on the corresponding transfer of funds. Both sides will be simulated using test tokens in the pilot.
The benefits will depend on how far this integration actually simplifies operations. Savings in processing and verification will have to be weighed against development, security, maintenance, connectivity and incident-response costs. A simpler investor experience may still require complex operations behind the scenes.
Costs, revenues and responsibilities
For banks, intermediaries and infrastructure providers, the experiments offer an opportunity to assess which services they can deliver within an integrated structure and which responsibilities they are prepared to assume.
A structure combining trading and settlement, for example, will need to demonstrate how it manages failures, controls access and reconstructs transactions. If it also combines other functions, the conflicts arising from that combination and the mechanisms that maintain a balance among participants will need to be assessed.
The resolution requires the controls, checks and balances associated with capital markets to be embedded, wherever possible, in the network architecture, participants’ rights and duties, and smart contracts. It also establishes the prevention of information asymmetries as a guiding principle for the experiments.
These requirements make governance part of the performance being assessed. The ability to execute a transaction must be accompanied by evidence of who can authorize it, who is accountable for it and how its compliance with the rules can be verified.
There is also a competition issue. Integration may create opportunities for new providers and service models, but it may also favor operators capable of concentrating multiple stages of an investment. Potential efficiency gains will need to be examined alongside their effects on access to infrastructure, conflicts of interest and the distribution of economic power.
Public and private networks will be compared
The CVM plans to assess private networks and permissioned public networks. Proposals must explain their architecture, protocol, consensus mechanism, permissioning, interoperability and security controls. The program allows different solutions to be compared against common requirements.
This opening matters for the development of on-chain markets because it brings different architectures into regulatory experimentation. The assessment should consider how each arrangement controls participation, protects information and enables supervision.
The rule adopts the principle of auditable privacy: confidentiality and data protection must coexist with the ability of competent authorities to identify and trace the ultimate beneficial owner.
External dependencies will also receive attention. Smart contracts can execute instructions automatically, but some of the information needed for an operation may arrive from outside the network through so-called oracles. The resolution requires security checks for these integrations and requires concluding reports to describe activities performed off-chain and their governance.
This requirement will help measure the reach of automation: how much of the process operates within the shared environment and how much continues to depend on external systems, decisions and procedures.
Supervision embedded in the infrastructure
The networks must provide the CVM with direct, real-time, read-only access to all experimental records. This access will include transactions, smart contract states and metadata, along with tools for queries, data extraction and audit trails that can reconstruct operations.
The design allows testing of supervision closer to execution. The regulator will be able to consult records directly while remaining separate from operational decisions: the CVM will not validate transactions, produce blocks or participate in the network’s consensus mechanism.
“It is the CVM’s role to keep pace with this development by testing solutions and engaging with the market,” the agency’s chair, Otto Lobo, said in the announcement of the program. According to the CVM, the initiative is intended to gather evidence to assess possible regulatory paths.
The ability to give the supervisor visibility will therefore be a condition for operating the experimental infrastructure.
A short window requires concrete preparation
Proposals must be submitted within 15 business days of publication. Representative associations and self-regulatory organizations participating in the CVM’s Tokenization Working Group may propose and manage networks, either individually or as a consortium. Admission will be automatic once the requirements are met, with no limit on the number of networks.
Submissions must include test cases, participants, a schedule, the architecture and regulator-access facilities ready for connection. The experiments will run for 60 days, with a possible extension of up to 30 days at the Steering Committee’s discretion.
The timetable requires proponents to arrive with systems and operating arrangements sufficiently prepared for examination. Participation will be voluntary and funded by the participants themselves, including development, connection, operation and decommissioning costs.
At the end, the CVM will consolidate findings, risks and recommendations for possible regulatory or legislative improvements. A public version of the final report is planned, with confidential information protected.
Decisions on commercial operations will be left to later stages. Even a technically successful experiment will leave questions about scale, economic viability and operation with real assets.
Even so, the subject of the assessment already matters for institutional strategy. By allowing tests that combine services and dispense with certain participants in experimental arrangements, the CVM has put the market’s division of functions itself under examination.
The findings could indicate which activities still require separate structures and which can be integrated into on-chain infrastructure with efficiency, accountability and supervision. That assessment could lead to a lasting change in how Brazil’s capital markets operate.