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Mateus Zorzi • July 30, 2025 • Articles

Digital Bank: what it is and how to launch one

Discover the strategic path to offering a full banking experience in Brazil without becoming a traditional bank, by leveraging modern fintech regulations.

Digital Bank: what it is and how to launch one Digital Bank: what it is and how to launch one
Plano Fintech – QuadradoPlano Startup Quadrado

The concepts of the digital bank and digital services emerged from the need to reduce bureaucracy, increase agility, and improve user experience within the traditionally conservative banking sector. In this article, we will explore the concept of a digital bank, how to structure one, the regulations from the Central Bank of Brazil (Bacen), relevant legal aspects when opening a digital bank, and the requirements for requesting operational authorization. This guide aims to provide a detailed and practical understanding for those interested in entering the digital banking market in Brazil.

Content:

  • What is a digital bank?
  • What is the current landscape of the digital banking market?
  • How to open a digital bank in Brazil?
  • How to structure a digital bank?
  • What are Bacen’s regulations for digital banks?
  • What are the relevant legal aspects when opening a digital bank?

 

What is a digital bank?

 

A digital bank is a financial institution that offers products and services digitally, with customer service and service provision occurring exclusively online. There are various types of banks, such as commercial banks, investment banks, development banks, multiple-service banks, etc. In essence, a bank is a financial institution that intermediates capital between surplus agents and deficit agents.

The type of bank with the most significant presence in the National Financial System and which the general population is most accustomed to are Multiple-Service Banks. According to CMN Resolution No. 5,060/2023:

Art. 4º A multiple-service bank is a financial institution comprised of at least two of the following portfolios, one of which must be commercial or investment:

I – commercial; II – investment; III – development; IV – real estate credit; V – credit, financing, and investment; and VI – leasing.

The large “retail banks” we are used to are multiple-service banks. These banks allow consumers to use services like checking accounts, investments, and payments, as well as obtain real estate credit, loans, and financing, among others.

Despite the falling numbers, a considerable portion of the Brazilian population is still unbanked. It is estimated that about 16% of the adult population in Brazil does not have a bank account. A large part of the banked population still uses banks primarily for services such as demand deposit accounts, credit cards, loans, and financing.

With this data in mind, the fintech market realized it was possible to offer these most sought-after services without necessarily being a multiple-service bank. It is enough to establish a Payment Institution and a Direct Credit Company.

Today, it is possible to offer a banking experience, emulating the services that can be provided by a multiple-service bank, by using two types of institutions regulated by Bacen: a Payment Institution and a Direct Credit Company.

For more information on these topics, we recommend accessing our previous content:

  • What is a Payment Institution?
  • What is a Direct Credit Company?
  • What are SCD and SEP?
  • Regulatory Routines for SCD and SEP
  • Regulatory Routines for a Payment Institution
  • Authorization Request for a Payment Institution – how to file the request with the Central Bank?

In short, a Payment Institution is a company that provides, executes, or manages a payment account; issues or accredits the acceptance of a payment instrument (card); or even performs other activities related to payment services. Examples include Nubank, PagSeguro, and Stone.

A Direct Credit Company, in short, is a financial institution that aims to release credit using its own capital for loan, financing, and credit rights acquisition operations, exclusively through an electronic platform.

With a Payment Institution, it is possible to offer a user a payment account (similar to a checking account), a card for credit and debit operations, as well as Pix payment and receiving services. With a Direct Credit Company, it is possible to offer the user credit options, such as loans and financing.

By combining these two institutions, the end-user can access the following services:

  • Payment account;
  • Debit and credit card;
  • TED, DOC, and PIX;
  • Loans;
  • Financing.

Through these institutions, fintechs can offer a banking experience to their customers without needing to be a multiple-service bank initially. An example is Nubank, which is a Payment Institution.

In this article, we will address the offering of financial services and the banking experience to users, commonly referred to as a “digital bank” without technically being a bank.

 

What is the current landscape of the digital banking market?

 

Currently, the digital banking market in Brazil has made significant progress. It is estimated that digital banks are used as the primary institution by 45.5% of Brazilians, according to the Onboarding Ranking 2022, a survey conducted by idwall. This research also indicated that more than 1 billion Brazilians have some form of digital account.

With the market’s growth, many people want to set up a “digital bank,” believing they wouldn’t need to comply with all the regulatory requirements a traditional bank would. This may be partly true, but it is not absolute. It is possible to be a bank and be digital, like Banco Inter, but it is also possible not to be a bank and offer the experience of a “digital bank,” like Nubank.

Plano Fintech

Today, with the opening for innovation proposed by the Central Bank of Brazil, it is possible to offer a banking experience to the user without the need to be a digital bank. Therefore, it is fundamental to understand how to structure a digital account.

 

How to open a digital bank in Brazil?

 

It is important to highlight that both Payment Institutions and Direct Credit Companies are regulated by Bacen. The SCD depends on prior authorization for its operation, and the IP will need to request operating authorization upon reaching a certain minimum transaction volume.

Central Bank of Brazil Resolutions No. 80 and No. 81 establish the requirements for requesting authorization to act as a Payment Institution. CMN Resolution No. 4,970/2021 governs the authorization process related to the operation of an SCD. The requirements for authorizations include:

  • Economic and financial capacity of the controllers;
  • Lawful origin of the funds used for the capital contribution;
  • Economic and financial viability of the enterprise;
  • Compatibility of the information technology infrastructure with the complexity and risks of the business;
  • Compatibility of the corporate governance structure with the complexity and risks of the business;
  • Unblemished reputation of those holding positions in statutory or contractual bodies, of the controllers, and of holders of qualified participation;
  • Knowledge, by the administration, of the line of business, the segment in which the institution intends to operate, the dynamics of the market, the sources of operational resources, the management of activities, and their associated risks;
  • Technical qualification of the administrators, compatible with the functions to be performed during their term;
  • Compliance with the minimum capital and equity requirements provided for in current regulations.

Therefore, to file the operating authorization request, it is important for the company to have legal counsel to assist with the process, requiring the company to be structured according to the requirements requested and demanded by the Central Bank.

 

How to structure a digital bank?

 

To structure a digital bank, one must choose the appropriate legal form, define the minimum share capital, define the corporate purpose, develop a business plan, define the business model and its structure, create procedural manuals and training for employees, adapt the information technology system, and adopt the other required measures.

As required by the mentioned regulations, the company must also structure a compliance department within the company to meet the requirements for its structuring.

 

What are Bacen’s regulations for a digital bank?

 

BCB Resolution No. 80/2021 establishes the constitution and operation of payment institutions, as well as the parameters for these institutions to file requests for operating authorization. BCB Resolution No. 81/2021 deals with the authorization processes related to the operation of payment institutions.

As already mentioned, the SCD is regulated by Bacen, mainly by CMN Resolution No. 5,050/2022, which establishes the organization and operation of the SCD. Additionally, CMN Resolution No. 4,970/2021 governs the authorization process related to the operation of the SCD.

For both Payment Institutions and SCDs, the existing regulatory routines must be observed and followed for the proper adaptation of the company to what is required by the Central Bank.

 

What are the relevant legal aspects when opening a digital bank?

 

When opening a digital bank, the company must comply with all legal requirements for the adequacy of its structure, according to the demands required by Bacen in the authorization request, as well as the implementation of an adequate compliance structure.

We reiterate that the company must have a compliance program to be in fulfillment with all regulatory requirements established by the Central Bank.

As observed, there are various regulations and requirements to be followed to open a digital bank, making the assistance of specialized legal advisory essential.

 

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