Payment Methods
Impact of the New Central Bank Regulations: The Game Has Changed for Sub-acquirers
The new rules imposed by the Central Bank are not just a bureaucratic update. they represent a new watershed for the segment of sub-accreditors, with a direct impact on autonomy, governance and survival of operations.
Centralized settlement: pressure for transparency and speed
Resolution 150/2021 has already made the centralized settlement via the nuclea mandatory for a market share. Now, the Public Consultation 104/2024 proposes even more aggressive bands, increasing the number of sub-accreditors required to operate in this model — with less time for adaptation and greater visibility of each financial movement.
The pressure is double: on the operational side, it is necessary to implement complex integrations and ensure transactional reconciliation without room for errors; On the reputational side, any delay or inconsistency can be transformed into public exposure, distrust of the market and, in extreme cases, sanctions and millionaire fines.
Restriction of action: the end of flexibility
With the Public Consultation 108/2024, the unauthorized sub-accreditors will see their performance reduced to the role of commercial representatives of already regulated payment institutions. In practice, autonomy disappears — the control of the relationship, the financial flow and even the strategic positioning of the business becomes in the hands of third parties.
It is the end of the regulatory “gray zone”: the choice is to adapt and seek authorization, or accept the loss of relevance and competitiveness in the sector.
Obligation to become a payment institution: new standard of requirement
Exceeded the established volume? According to Resolution 80/2021, the sub-accreditor has up to 90 days to obtain authorization as a payment institution.
This process requires minimal capital, qualified governance, independent auditing, internal controls, constant regulatory reporting and a new standard of transparency and operational robustness. It is not a one-off adjustment — it is a transformation of culture, technology and management.
Real case: integration with the nuclea and the risk of inertia
One of the biggest challenges of the new order is the time and complexity for integration with the nucleus. Today, developing this integration can consume up to 8 months, blocking time-to-market, compromising ROI and exposing the company to high operational risks. Companies have already faced fines of up to R$ 4 million for failures that could be avoided with more predictability and tests.
Reducing that time, eliminating third-party dependency for test scenarios and ensuring operational resilience are critical points for those who want to survive – and thrive – in this new environment.
Contextual Solution: The Path to Regulatory and Technological Maturity
In this environment, sub-acquirers must look beyond mere regulatory compliance. The current landscape demands:Strategic Regulatory Planning: Anticipate the impact of upcoming mandatory compliance thresholds and proactively map the transition process toward becoming a Payment Institution.
Investment in Integration Technology: Implement solutions that enable seamless integration with Núclea, support comprehensive internal scenario simulations, and automate reconciliation, monitoring, and reporting processes.
Strengthening Governance and Compliance: Establish robust governance frameworks, internal controls, and audit mechanisms to ensure resilience, transparency, and accountability for shareholders, investors, and regulators.
Proactive Operational Risk Management: Develop preventive mechanisms to mitigate incidents by adopting structured testing, simulation, and rapid-response practices—reducing the risk of regulatory sanctions, financial losses, and reputational damage.
- A Culture of Continuous Adaptation: Foster the mindset that regulatory change is constant and that proactive preparation will always be more cost-effective—and less risky—than reacting at the last minute.
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