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eFX in the fintech app: what changes with BCB Resolution 561
eFX in the fintech app changed on October 1, 2026, when BCB Resolution 561 took effect. Since then, only an authorized institution may provide international payments or transfers, the customer's acceptance must be provable, the reais come in from the sender's own account or boleto, and settlement abroad doesn't accept stablecoins.
The legal alerts published since May explain the rule for the institution; this article reads BCB Resolution No. 561, which amended BCB Resolution No. 277, from the side of whoever builds the product. It's a product reading: how your operation is classified is still up to the fintech's legal team.
In 2025, Wama designed and developed the Cappta app, a payment institution that offers payment capture and a white-label digital account. In an app like that, what the Central Bank and the app stores require of a financial app arrives before the first screen, and Resolution 561 adds a layer for all money that crosses the border.
What does BCB Resolution 561 change in a fintech app?
Resolution 561 rewrote the eFX chapter of BCB Resolution 277, the foreign exchange rule. eFX is the international payment or transfer service: purchases abroad, sending money, transfers between accounts of the same person and withdrawals. For the product, the change lands in five places.
Who provides it: only institutions authorized by the Central Bank.
Scope: investment-related transfers are now included, up to US$ 10,000 per transaction.
Terms screen: the customer's acceptance must be provable.
Checkout: reais only come in from the sender's own account or boleto, or through an instrument of up to US$ 200.
Back office: KYC of the counterparty abroad, settlement without virtual assets and records kept for ten years.
The fintech's website is still subject to what the law requires of a fintech website; Resolution 561 touches the app and the operation.
Who can offer eFX since October 1?
Only institutions authorized to operate by the Central Bank (art. 49, § 2): banks, Caixa, development agencies, finance companies, securities brokers and dealers, foreign exchange brokers and payment institutions authorized as electronic money issuers, post-paid instrument issuers or acquirers, even without a foreign exchange authorization.
The service starts five business days after the institution adds the modality to Unicad, the Central Bank's registry of entities (art. 49, § 3). Those already providing it have until October 30, 2026 to make that addition (art. 56-A). A new modality also calls for a review of what the payment institution publishes on its website.
Those providing it without authorization must apply for authorization as a payment institution by May 31, 2027 (art. 56-B). Until the decision, they operate with restrictions by transaction type, and must stop within 30 days if they don't apply or if the application is denied. That's why the app needs to turn each modality on and off without waiting for a new version in the store.
Where does the US$ 10,000 limit apply?
To the transaction. Unilateral transfers, transfers between accounts of the same person, investment and, since October, purchases through a digital payment solution not integrated with an e-commerce platform have a cap of US$ 10,000 or the equivalent in another currency (art. 49). § 1 prohibits splitting transactions to take advantage of these limits.
For the product, the purpose comes before the amount. The same send screen falls under different rules depending on the stated reason, so purpose is a required field, the cap is validated in the transaction currency and consecutive sends to the same destination go into the splitting check.
How does the app prove the customer's acceptance?
By storing the acceptance with version and date. The provider must ensure the customer was informed, clearly and in a timely manner, about the provider's responsibilities, the service terms and the rights tied to the instrument used to pay (art. 51). The sole paragraph requires that it be able to prove the customer's prior awareness and agreement.
A checked box with no record proves nothing. What proves it is knowing which version of the terms was shown, when and to whom, and displaying the new version before the next transaction whenever the text changes. It's worth applying how fintech interfaces handle rejection and trust: a readable summary and acceptance as its own step.
What does the eFX statement need to show?
Date, parties, amount in reais, fee and subtotals of withdrawals, payments and transfers (art. 52). In foreign currency, also the currency and the amount in it. For purchases or withdrawals abroad with an international card, the amount in dollars, the day's conversion rate and the amount in reais.
The amount in reais is final: the rule prohibits indexing it to the foreign currency or converting it again later (art. 54, § 1). If the customer pays after the transaction, the provider may offer conversion at the payment date's rate, with express acceptance (art. 54, § 2). In the app, this becomes a confirmation with a locked amount and, when that offer exists, a second recorded acceptance.
At Milhas Pix, an airline miles marketplace with payment via Pix, Brazil's instant payment system, Wama built everything from the acquisition page to the offer management and transaction tracking screens. It's on a tracking screen like that where the art. 52 statement takes shape, field by field.
How do reais come in and go out?
They come in from the sender's own deposit or payment account, by a boleto on which the sender is the payer, or through an instrument of up to US$ 200 with no top-up or withdrawal (art. 54-A). They only go out as a credit to the recipient's account. Third-party payments are excluded, so the checkout checks account ownership before releasing the transfer.
If the money comes in through Pix, Pix limits and hours in the app also apply. Without a reserve account at the Central Bank, the money goes through an exclusive account of the provider at an institution authorized to operate foreign exchange, for the sole purpose of providing eFX, and offsetting the reais received against those delivered is prohibited (art. 54-A, §§ 2 and 3).
What stays in the back office
The sender must be the provider's customer, and the provider needs a contract with the counterparty abroad and the know-your-customer procedures of Circular No. 3,978, the anti-money laundering rule (art. 50-B). With the counterparty, settlement is only through foreign exchange or a non-resident account in reais, with virtual assets prohibited (art. 50); the legal alerts we read include stablecoins in that prohibition.
The data for each transaction is kept for ten years (art. 50-C) and goes to the Central Bank through the Sistema Câmbio by the 10th of the following month (art. 81-A). Resolution 561 didn't regulate eFX through Banking as a Service, as a legal alert from May notes. For a fintech operating on Banking as a Service, the split of responsibility is still read case by case.
Calendar: what already applies and what's due by 2027
Item | Basis in the rule | Date | Where it lives |
|---|---|---|---|
Only authorized institutions provide eFX | art. 49, § 2 | 10/01/2026 | legal and product |
US$ 10,000 cap and ban on splitting | art. 49 | 10/01/2026 | app and system |
Provable acceptance of the terms | art. 51 | 10/01/2026 | app |
Reais come in and go out through the holder's account or boleto | art. 54-A | 10/01/2026 | checkout |
Settlement without virtual assets | art. 50 | 10/01/2026 | treasury |
Records kept for ten years | art. 50-C | 10/01/2026 | back office |
Adding the modality to Unicad | art. 56-A | by 10/30/2026 | legal |
Authorization request from those not authorized | art. 56-B | by 05/31/2027 | legal and app |
How to put Resolution 561 into the scope of whoever builds the app
By turning each article into a scope item with a date and an owner.
Confirm the fintech's status with the legal team: authorized, with Unicad by October 30, or in transition, with an application by May 31, 2027.
List the app's modalities (purchase, send, between accounts, withdrawal, investment) and the cap for each one.
Separate screen, system and routine: acceptance and statement are design; ownership checks and the splitting lock are engineering; counterparty KYC and records are operations.
Write it all into the product development contract, with the effective date next to each deliverable.
At Wama, a single person is responsible for the project from brief to deploy, and design is the longest phase of the schedule. AI, with Claude Code and Framer's agents, speeds up building, not deciding, and every result goes through human review. Reading each article is the legal team's job; the studio's job is to turn that reading into screens and scope.
Common mistakes
Treating acceptance as a checked box. Without version and date, prior agreement can't be proven.
Accepting third-party payments. The reais have to come from the sender's own account or boleto.
Keeping stablecoins on the rail abroad. With the counterparty, only foreign exchange or a non-resident account in reais.
Frequently asked questions
When did BCB Resolution 561 take effect?
On October 1, 2026. Since then, only authorized institutions provide eFX, and the rules on acceptance, incoming reais and settlement apply. Those already authorized and providing the service have until October 30, 2026 to add the modality to Unicad; those that weren't have until May 31, 2027 to apply for authorization.
Can a fintech without authorization keep offering eFX?
Yes, with restrictions, if it applies to the Central Bank for authorization as a payment institution by May 31, 2027. While the application is pending, it provides only part of the transactions, depending on the type of company. If it doesn't apply in time or if the application is denied, it must stop within 30 days.
Can the app accept a third-party payment for a remittance?
No. The reais reach the provider from the sender's own account, by a boleto on which the sender is the payer, or through an instrument of up to US$ 200 with no top-up or withdrawal. That's why the checkout checks the payer's account ownership before releasing the transfer abroad.
Are stablecoins banned in eFX?
They are banned as a means of payment or receipt between the eFX provider and the counterparty abroad, which can only be settled through foreign exchange or a non-resident account in reais held in Brazil. Virtual asset transactions outside eFX follow other rules, which this article doesn't cover.
What does the eFX statement need to show?
Date, parties, amount in reais, fee and subtotals of withdrawals, payments and transfers. In foreign currency, the currency and the amount in it. For purchases or withdrawals abroad with an international card, also the amount in dollars, the day's conversion rate and the resulting amount in reais.
If your fintech is going to adapt its app to eFX and wants to handle screens, checkout and records in the same scope, talk to Wama.
