Joint Resolution No. 17/2025 – New Rules on the Naming of Regulated Institutions and Fintechs
Joint Resolution No. 17, issued by the Central Bank of Brazil (“BCB”) and the National Monetary Council (“CMN”) and published in the Federal Official Gazette on December 1, 2025 (“RC 17”), introduces a new regulatory framework governing the nomenclature and public presentation of institutions authorized to operate by the BCB. The regulation, which took effect on the date of its publication, reinforces the need for clarity, transparency, and standardization in the communication of institutions with clients and users, particularly in light of the increasing diversity of financial business models and the expansion of technological partnerships in the sector.
The rule provides a clear definition of what constitutes institutional nomenclature—including corporate name, trade name, brand, and internet domain—and sets out how these elements may be used.
RC 17 also requires that the institution’s corporate name include terminology that clearly reflects the scope of the authorization granted by the BCB. Accordingly, the use of expressions that may expressly or implicitly suggest activities or institutional types for which the entity does not hold specific authorization is prohibited.
From a contractual perspective, the regulation introduces restrictions on the execution of partnerships and correspondent agreements within Brazil involving entities not authorized by the BCB that use nomenclature suggesting that they are regulated institutions, or that fail to clearly indicate their role as engaged or partnered entities of a BCB-authorized institution. The rule establishes a one-year period for institutions to review and adjust contracts executed prior to the entry into force of RC 17, ensuring an orderly transition to the new regime. Specific exceptions apply to partnerships with microcredit-promoting entities and to engagements limited to strictly operational or ancillary services, such as information technology, infrastructure, and third party atm network.
Institutions that are not in compliance with RC 17 must prepare an adjustment plan to be completed within one (1) year. If the required adjustment relates solely to the institution’s name, an adjustment plan is not required. However, in such cases, the change in corporate name must be finalized within one (1) year from the effective date of the rule. It should also be noted that name changes carried out strictly to comply with RC 17 are deemed pre-approved by the BCB and need only be communicated to the regulator within ninety (90) days from their implementation.
According to the BCB, the issuance of RC 17 aims to enhance transparency for consumers, particularly with respect to the responsibilities inherent to providers of regulated services. Despite this legitimate objective, the rule imposes significant restrictions on fintechs generally, requiring meaningful adjustments to the strategic and marketing positioning of companies operating in the market and using nomenclature prohibited under the new regulation.
