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Bank accounts in Brazil: a guide for non-resident companies

How foreign companies can hold and operate bank accounts in Brazil, in reais and now, under Resolution BCB 575/2026, in foreign currency, and the rules that govern each route.

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The framework Accounts in reais Foreign-currency accounts Resolution BCB 575/2026 What changes in practice Other routes Practical steps Key risks
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Brazil now offers non-resident companies two distinct account routes: the long-established account in reais, and, from 1 October 2026, foreign-currency deposit accounts for foreign direct investors and foreign lenders.

Brazil’s foreign exchange framework was rebuilt by Law 14,286/2021 (the novo marco cambial, in force since the end of 2022), under which the Central Bank of Brazil (BCB) regulates both accounts in reais held by non-residents (article 10) and accounts in foreign currency held in Brazil (article 11). The main implementing rules are Resolution BCB 277/2022, which governs the foreign exchange market and both types of account, and Resolution BCB 278/2022, which governs the reporting of foreign capital flows.

Until now, foreign-currency accounts in Brazil were reserved for a narrow list of holders. Resolution BCB 575/2026, published on 18 June 2026 and in force from 1 October 2026, widens that list significantly: it reaches, for the first time, non-resident companies that hold a direct stake in a Brazilian company or that are creditors of external credit to Brazilian residents, alongside Brazilian exporters, Brazilian companies with external debt and Brazilian companies with a non-resident direct shareholder. This guide explains both routes and what the change means in practice.

Overview

The regulatory framework

Three instruments do most of the work: the foreign exchange statute, the BCB’s consolidated FX-market resolution, and the BCB’s capital-flows reporting resolution. Resolution BCB 575/2026 amends the last two.

Law 14,286/2021 modernised Brazil’s foreign exchange and international capital rules. Its article 10 provides that accounts in reais held by non-residents are opened and operated under the BCB’s regulation, aligned with resident accounts except where specific rules apply, and its article 11 permits accounts in foreign currency in Brazil in situations defined by the BCB.

Resolution BCB 277/2022 is the consolidated FX-market regulation, governing authorised institutions, foreign exchange operations, accounts in reais held by non-residents and, in its articles 70 and following, the closed list of eligible holders of foreign-currency deposit accounts. Resolution BCB 575/2026 expands that list.

Resolution BCB 278/2022 governs the provision of information on foreign capital to the BCB, including declaratory registration of foreign direct investment (SCE-IED) and external credit operations (SCE-Crédito). Resolution BCB 575/2026 also adjusts this resolution, recognising settlement through debits and credits in foreign-currency accounts and refining declaration timing rules.

The real remains Brazil’s sole legal tender for domestic payments. Neither Law 14,286/2021 nor Resolution BCB 575/2026 changes the restrictions on using foreign currency for domestic payments, and the BCB has been explicit that the reform does not interfere with exchange-rate formation. The new accounts are treasury and settlement infrastructure for international flows, not a step towards domestic dollarisation.

Terminology

This guide uses “account in reais” for the non-resident account in Brazilian currency (historically known as a CC5 account under the pre-2022 rules), and “foreign-currency account” for the deposit account denominated in a foreign currency held with an institution in Brazil. The two are governed by different chapters of Resolution BCB 277/2022 and serve different purposes.

Route One

The account in reais: the established route

Any non-resident company can, in principle, hold a bank account in reais in Brazil. It is the standard vehicle for receiving and making payments in Brazilian currency, and movements through it to or from the rest of the world are treated as international transfers in reais, with their own reporting framework.

Treatment
Aligned with resident accounts, with an international-transfer overlay
The account in reais is opened and operated on terms aligned with resident accounts, subject to specific non-resident rules. Transfers between the account and the rest of the world constitute international transfers in reais, carrying classification, documentation and reporting obligations.
Uses
What non-resident companies use it for
Receiving dividends and interest on net equity from Brazilian subsidiaries, paying Brazilian suppliers, holding reais between investment steps, and settling contracts priced in Brazilian currency. It can also serve as the settlement leg for eFX international payment services.
Opening
What opening one requires
A Brazilian taxpayer registration (CNPJ), a legal representative or attorney-in-fact resident in Brazil, and corporate and beneficial-ownership documentation, typically notarised, apostilled and sworn-translated. Banks apply ordinary KYC/AML rules; onboarding is at each institution’s commercial discretion.
Limits
What it does not do
The account is denominated in reais. A company with dollar or euro flows must convert on each side, bearing the exchange spread and IOF, and carrying currency risk while funds sit in reais. That friction is what the new foreign-currency account route addresses.
Route Two

Foreign-currency accounts in Brazil: from narrow exception to practical tool

Deposit accounts denominated in foreign currency have always existed in Brazil, but only for a restricted list of holders set out in article 70 of Resolution BCB 277/2022. The list reflected specific operational needs rather than general corporate treasury use.

Before Resolution BCB 575/2026, the eligible holders were, in broad terms, institutions authorised to operate in the foreign exchange market, insurers, reinsurers and brokers for obligations in foreign currency, embassies, consulates and international organisations, companies holding oil and gas exploration and production rights, certain energy-sector and border-trade cases, and a small number of other specific situations. A foreign parent company, a foreign lender or an ordinary Brazilian exporter could not hold dollars on deposit in Brazil; their foreign currency had to be converted into reais through an exchange operation, or kept offshore.

The consequence for cross-border groups was a structural inefficiency: every international flow touching Brazil required a conversion leg, with its spread and IOF cost, even where the funds were destined to leave again in the same currency, and even where both ends of the flow belonged to the same economic group. Resolution BCB 575/2026 is the BCB’s response, and it is a significant one.

The New Rules

Resolution BCB 575/2026: who can now hold foreign currency in Brazil

Resolution BCB 575/2026, approved by the BCB’s board on 18 June 2026, amends Resolutions BCB 277/2022 and 278/2022 and enters into force on 1 October 2026, a lead time designed to let banks adjust systems and processes. It adds five new categories of eligible holder, two of which are non-resident companies.

Non-resident companies with a direct stake in a Brazilian company
Non-resident
Entries must derive from external credit or foreign direct investment operations, consistent with flows evidenced in the SCE-IED and SCE-Crédito systems.
Non-resident companies that are creditors of external credit to Brazilian residents
Non-resident
Entries must derive from the external credit operations concerned, consistent with their registration with the BCB.
Brazilian companies with a non-resident direct shareholder
Resident
Entries must derive from external credit or foreign direct investment operations, with corresponding BCB registrations.
Brazilian private-sector companies with external debt
Resident
Entries must derive from the external credit operations concerned, allowing debt service without intermediate conversions.
Brazilian exporters of goods
Resident
Credits must come exclusively from export receipts and other amounts originating from abroad (new article 75-A).
Operating Rules
How the accounts can and cannot be moved
Cash withdrawals and deposits are prohibited, movement by cheque is prohibited, and conversion to reais requires an ordinary FX operation. Transfers of foreign currency, including between two foreign currencies, are dispensed from a formal exchange contract.
Reporting
Monthly reporting by the account-holding bank
A new article 80-A requires institutions to report client identification, eligibility category and IBAN identifier to the BCB by the fifth day of each month. The holder must be able to evidence that entries match an eligible flow.
Capital Flows
Alignment of the SCE reporting rules
Declarations of external credit must be made before funds enter Brazil (or within 30 days of disbursement in other cases), and settlement by debits/credits in a foreign-currency account is expressly recognised as a settlement method.
Unchanged
What the resolution does not change
Restrictions on using foreign currency for domestic payments remain, the real remains sole legal tender, and AML/CTF obligations and documentation requirements continue to apply in full.
Practical Effect

What the change means for foreign groups

For non-resident companies with Brazilian subsidiaries or Brazilian borrowers, the practical gains are concentrated in three situations.

Foreign Parent
Holding investment flows in currency, inside Brazil
A foreign parent can hold a foreign-currency account funded by its FDI and external credit flows, positioning capital contributions and intercompany loans in the original currency and converting only when needed. The account presupposes, not replaces, the SCE-IED/SCE-Crédito registrations.
Foreign Lender
Managing external credit without forced conversion legs
A non-resident lender can hold disbursement, service and repayment flows of its registered external credit in a foreign-currency account, reducing the number of exchange operations, and therefore spread and IOF events, over a loan’s life.
Brazilian Subsidiary
The subsidiary side of the same coin
A Brazilian company with a non-resident shareholder or external debt can hold and apply foreign currency to matching obligations, reducing the mismatch between real-denominated revenue and foreign-currency debt service.
Exporters
Exporters keep their export currency
Brazilian exporters can retain export receipts in foreign currency and use them for outbound payments in currency. A Brazilian subsidiary exporting within a group can now hold receivables locally, simplifying intra-group netting.
The account is infrastructure, not a tax or registration shortcut

Holding funds in a foreign-currency account in Brazil does not change the tax treatment of the underlying flows (dividend withholding, interest withholding and IOF on exchange operations apply as before), and it does not replace the declaratory registrations of foreign capital. If anything, the account’s operating conditions make clean, timely SCE-IED and SCE-Crédito records more important.

Adjacent Regimes

Other routes worth distinguishing

Two neighbouring regimes are often confused with the accounts discussed above and serve different purposes.

Portfolio Investors
The 4,373 route for financial and capital markets
Non-resident investors in Brazil’s financial and capital markets (equities, funds, fixed income) generally invest under the regime of CMN Resolution 4,373/2014, through a Brazilian custodian and legal representative, with their own registration and account structure.
Payments
eFX: international payment services for smaller flows
For retail-scale international payments, the eFX regime allows authorised institutions to provide international payment services without the client holding a special account. Refined by Resolution BCB 561/2026, also in force from 1 October 2026, including value limits per transaction category.
Process

Practical steps for a non-resident company

A high-level sequence for a foreign company planning to open and operate a Brazilian account under the new framework.

01
Map the flows and pick the account route
Identify which flows the account will carry and in which currency they naturally arise. Real-denominated flows point to the account in reais; foreign-currency flows tied to registered investment or credit point to the new account, if the company is eligible.
02
Confirm eligibility under article 70 as amended
Confirm the company sits within a category introduced by Resolution BCB 575/2026 and that intended entries derive from those operations. Eligibility is category-based and entry-based, not general.
03
Put the registrations in order first
Ensure CNPJ registration, SCE-IED and SCE-Crédito records are complete and current. Entries must be traceable to these records, and the amended declaration timing rules should be built into the treasury process.
04
Appoint the Brazilian representative
A non-resident account holder needs a resident legal representative or attorney-in-fact, commonly an officer of the subsidiary or the group’s local counsel, documented with notarisation, apostille and sworn translation.
05
Select the bank and run onboarding early
The account must be with an FX-authorised institution; banks retain full commercial discretion over non-resident onboarding, routinely the slowest step. Engage early and agree the documentation list up front.
06
Design the operating procedures around the account’s conditions
Build internal controls: no cash or cheques, entries limited to eligible flows with supporting evidence, conversions only through exchange operations, and cooperation with the bank’s monthly reporting.
07
Plan the transition around 1 October 2026
The new categories only take effect on 1 October 2026. Companies intending to use the accounts from day one should run eligibility analysis, registration clean-up and bank onboarding in advance.
Important Considerations

Key risks and practical points

Issues that arise frequently for non-resident companies banking in Brazil, and the points most likely to trip up early users of the new accounts.

Eligibility Discipline
Entries must match the eligible flow
Each category carries conditions on where credits may come from. Entries that cannot be traced to an eligible operation put the account, and the holder’s standing with the bank and the BCB, at risk. Treat eligibility as a per-entry test, not a one-time qualification.
Onboarding
Bank discretion is the real gatekeeper
Nothing obliges any bank to open an account for a given non-resident company. Institutions differ widely in appetite, documentation demands and timelines. Regulatory eligibility is necessary but not sufficient.
Tax
The account changes plumbing, not tax
IOF applies to exchange operations on conversion; withholding taxes apply according to the nature of the flow, not the account it passes through. The account reduces conversion events, not tax exposure.
Compliance
AML obligations and full traceability
The BCB preserved the entire AML/CTF framework, added bank-level monthly reporting with IBAN-level identification, and tied entries to registered capital flows. These are among the most transparent accounts in the system.
No Domestic Use
Foreign currency still cannot pay Brazilian bills
Salaries, suppliers, taxes and other Brazilian obligations remain payable in reais. Any operation with a domestic footprint still needs a real-denominated leg.
Timing and Maturity
A new product with a settling-in period
The regime starts on 1 October 2026 against a new reporting obligation and new operating conditions. Early adopters should expect conservative bank interpretations and keep fallback arrangements in place.
Read the account alongside the capital flows, not instead of them

For non-resident companies the account is the visible tip of a structure that rests on correct CNPJ registration, correct and timely SCE-IED and SCE-Crédito declarations, properly documented intercompany agreements, and a coherent dividend, interest and repatriation strategy. Weaknesses in that underlying structure surface quickly once flows start moving through a monitored account.

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Need advice on banking and FX structures for Brazil?

Choosing between the account routes, confirming eligibility under the new rules and putting the registrations and documentation in order require analysis of your specific flows and structure.

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This page is a summary only and does not constitute legal advice.

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