Key takeaways:
Brazil’s moves are corporate and municipal, not sovereign.
B3’s spot ETFs and resized 0.01-BTC futures let treasurers gain, size and hedge exposure using familiar tools.
New VASP standards (licensing, AML/CFT, governance, security), effective February 2026, reduce operational uncertainty.
Key sequence: Write rules → list plain-vanilla access products → add hedging tools → enforce disclosure.
What’s actually happening in Brazil?
To be clear, Brazil’s National Treasury and central bank are not adding Bitcoin to the country’s sovereign reserves. There is also no law requiring government bodies or state-owned firms to hold Bitcoin (BTC).
What is happening instead is a patchwork of city initiatives, listed companies and new market infrastructure coming online:
In the following sections, we’ll outline the “whats,” the “whys” and the risks involved.
Did you know? B3 (short for Brasil, Bolsa, Balcão) is Brazil’s main stock exchange, formed in 2017 through the merger of São Paulo’s securities, futures and commodities exchanges. It is one of the largest market infrastructures in the world and the first in Latin America to list a spot Bitcoin exchange-traded fund (ETF).
What has Brazil built so far?
Brazil has spent the past few years building regulated, familiar ways to access Bitcoin.
In 2021, B3 listed Latin America’s first spot Bitcoin ETF (QR Asset’s QBTC11), giving institutions an auditor-friendly instrument without requiring self-custody from day one. Derivatives followed.
In mid-2025, B3 reduced the Bitcoin futures contract size from 0.1 BTC to 0.01 BTC to broaden participation and improve hedging. The change was formally implemented on June 16, 2025, through circular and public notice.
Product innovation kept pace. Asset managers launched hybrid funds that blend Bitcoin and gold on B3, showing that regulators and the exchange are comfortable hosting crypto-linked products in public markets.
The rulebook is maturing alongside the products. In November 2025, the central bank published detailed standards for VASPs covering licensing, AML/CFT, governance, security and consumer protection, with enforcement starting in February 2026.
For treasurers, that reduces operational uncertainty as they rely on ETFs, futures and regulated intermediaries.
Why Brazilian treasurers are doing this
Treasury teams are trying to smooth earnings and protect purchasing power in a market where the Brazilian real can swing sharply on policy decisions and external shocks.
A small Bitcoin allocation, held through audited instruments, adds a liquid, non-sovereign hedge alongside dollars and local notes without requiring new custody operations.
It’s also about using familiar pipes. Spot ETFs and listed futures on B3 let treasurers size, rebalance and hedge within the same governance and audit routines they use for other assets. The smaller 0.01-BTC futures contract makes hedging more precise and cheaper to implement at a treasury scale.
There’s a governance blueprint now. Méliuz showed the sequence boards want to see: shareholder approval → clear disclosure → execution → additional capital to scale the position. That reduces career risk for other chief financial officers considering a pilot allocation.
Access matters for those who can’t hold crypto directly. OranjeBTC’s B3 listing gives equity exposure to a large on-balance-sheet BTC position, allowing institutions to participate through a listed vehicle while staying within mandate.
Finally, the regulatory arc lowers operational uncertainty. With the central bank’s VASP standards covering licensing, AML/CFT, governance and security set to take effect in February 2026, treasurers can rely on licensed intermediaries and documented controls rather than bespoke crypto infrastructure.
Did you know? A spot Bitcoin ETF is a fund that holds actual Bitcoin and lets you buy shares of that Bitcoin on a stock exchange, just like any other ETF. It gives you price exposure, daily liquidity and audited custody without managing your own wallet or keys, which is why treasurers and institutions often prefer it over holding coins directly.
The risks and how Brazil is addressing them
Brazil knows the risks and is tightening the playbook.
Market volatility: Bitcoin can swing hard, so treasurers that opt in usually cap position sizes, set rebalancing rules and use listed hedges. B3’s smaller 0.01-BTC futures, effective June 16, 2025, make it easier to hedge profit and loss and liquidity shocks with finer precision.
Operational and counterparty risk: Self-custody, exchange exposure and vendor security are not trivial. The central bank’s new VASP standards push crypto intermediaries toward traditional-finance norms.
Legal and enforcement clarity: Prosecutors and regulators need predictable tools when crypto intersects with criminal cases. A new bill would let financial institutions liquidate seized crypto, aligning treatment with foreign exchange and securities processes and reducing gray areas in enforcement.
Public optics and disclosure: “Bitcoin treasury” remains politically sensitive. Listed paths pull companies into auditor-vetted reporting and continuous disclosure on exposure, custody and risk. That transparency helps boards and regulators get comfortable as the market matures.
How Brazil compares: BTC treasury pathways
What other nations can learn
Remember, Brazil wrote rules. The central bank set clear criteria for when crypto-fiat conversions are treated as foreign exchange and raised standards for VASPs across AML/CFT, governance, security and consumer protection.
Ship simple access products early. QBTC11 and its peers launched in 2021, giving institutions a familiar, audited instrument instead of forcing them to build custody from scratch. With an ETF path, treasurers can size exposure within existing mandates.
Add hedging tools for risk managers. In June 2025, B3 cut the Bitcoin futures contract size to 0.01 BTC. Smaller contracts make hedges cheaper and tighter, allowing boards to approve them and treasury teams to manage value at risk (VaR) and drawdowns with more precision.
Encourage disclosure norms via public vehicles. Listed “Bitcoin-treasury” companies such as Méliuz and OranjeBTC create reference points for audits, board processes, impairment policies and reporting cadence. These become templates others can copy.
Pilot below the federal level. City or agency pilots surface political and accounting questions early. Rio’s 1% signal in 2022 showed how quickly optics become the story and why mandates and risk limits must be explicit.
The sequence is straightforward: write the rulebook, introduce plain-vanilla access products, downsize derivatives to support hedging and allow disclosure standards to develop in public markets. Only then does the conversation about putting BTC in the treasury become meaningful.
