7Block Labs
Regulatory Compliance

ByAUJay

Summary: Brazil’s DeCripto (Declaração de Criptoativos) becomes mandatory for crypto reporting in July 2026 and retools data capture to CARF standards; exchanges that don’t re-architect event streams and file generation will miss filings, incur per-operation penalties, and jeopardize Brazil market access. This playbook shows exactly how to retrofit your exchange—from Kafka topics to e-CAC uploads—using a pragmatic blueprint we’ve implemented for regulated reporting at scale. (gov.br)

Title: Adapting Your Crypto Exchange for Brazil’s “DeCripto” Reporting Standards

Hook — the headache your team is already feeling Your data warehouse doesn’t speak “DeCripto.” You have fills, cancels, internal transfers, and hot/cold wallet moves—but DeCripto Version 1.0 expects specific record families (e.g., 0110, 0210, 0650, 2110–2650) in a strict, pipe-delimited hierarchy, plus CARF-coded fields like CodigoReportavelCarf and CódigoNexoCarf. One missing mapping (for example, Transfer Wallet → 2650 with correct IN/OUT semantics) and your monthly file is rejected at e-CAC—putting you out of compliance from July 1, 2026 onward. (gov.br)

Agitate — the real risk if you wait until Q2 2026

  • Hard deadline and dual-track obligations
    • DeCripto replaces the 2019 model starting July 2026; the old model dies June 30, 2026. Reporting remains monthly for Brazilian exchanges and extends to foreign CASPs serving Brazilian users. AML/KYC due diligence aligned to CARF begins January 1, 2026. Missed or malformed files trigger penalties and escalate supervisory attention. (gov.br)
  • Penalties scale fast
    • Late filings: R$1,500/month for standard entities; R$500/month for Simples/imunes/isentas; R$100/month for individuals. Inaccurate/omitted data: 3% of operation value (PJ) or 1.5% (PF), minimum R$100—per affected operation. (normaslegais.com.br)
  • Authorization and market access pressure
    • New Central Bank (BCB) rules for VASPs (Res. 519/520/521) take effect Feb 2, 2026. Existing providers must seek authorization within 270 days; after Oct 30, 2026, operations with non-authorized entities are prohibited—so compliance operations must be production-grade well before your license cutover. (bcb.gov.br)
  • Global cross-checking ramps up
    • CARF data exchange formats were finalized/updated in 2024–2025, and jurisdictions begin exchanges in 2027. Regulators will reconcile your DeCripto payloads against CARF-participating authorities’ data, shrinking room for reconciliation errors. (oecd.org)

Who this is for (and the keywords you need on your implementation docs)

  • Target audience: CTO, VP Compliance, Head of Data Engineering, and Brazil Program Lead at global and regional crypto exchanges/CASPs entering or scaling in Brazil in 2026.
  • Required implementation keywords to align with DeCripto/CARF and BCB oversight:
    • “Registro 0110/0210/0650/2110–2650 mapping,” “CodigoReportavelCarf,” “CódigoNexoCarf,” “UTF-8 pipe-delimited hierarchy,” “Saldo Anual 1000/1010,” “e-CAC upload orchestration,” “RFB IN 2.291/2025,” “BCB Res. 519/520/521 authorization window,” “CPF/CNPJ normalization and dedup,” “BRL35k self-reporting threshold,” “foreign CASP in-scope,” “CARF XML Schema (2025-07) crosswalk,” “Status Message XML internal validator.” (gov.br)

What changed (precisely) since January 2026

  • DeCripto layout v1.0 (ADE Copes 02/2025) is live for integration work; production filing switches in July 2026. Files are text, UTF-8, pipe-delimited, hierarchical records with strict ordering and CRLF line termination. (gov.br)
  • Scope: Brazilian exchanges report monthly regardless of value; individuals/entities self-report only when transacting without a Brazilian exchange and monthly volume exceeds BRL 35,000 (was BRL 30,000). Obligation extended to foreign CASPs serving Brazilian users. (gov.br)
  • Due diligence: CARF-aligned AML/KYC procedures effective Jan 1, 2026 for CASPs. (gov.br)
  • BCB regime: PSAVs (SPSAVs) require authorization; three classes (intermediária, custodiante, corretora); strong governance, segregation of client assets, cyber and data protection; self-custody transfers permitted with documented controls. Effective Feb 2, 2026; apply within 270 days; post-Oct 30, 2026 operations must involve authorized entities only. (bcb.gov.br)
  • OECD CARF tech: 2025 updates to XML User Guide and Status Message XML; plan to exchange in 2027. Use these specs to validate your CARF-segment of DeCripto records before Brazil go-live. (oecd.org)

The solve — 7Block Labs’ methodology for DeCripto compliance without thrash We use a three-track plan that bridges engineering constraints with regulatory outcomes, with measurable gates.

  1. Data model + taxonomy retrofit (Weeks 1–3)
  • Deliverables
    • Canonical “DeCripto Event Contract”: a schema mapping exchange events to DeCripto/ CARF records:
      • Trades → 0110 (buy/sell) and 0210 (crypto-to-crypto), plus CARF mirrors 2110–2220.
      • Wallet flows → 0350/0450 (non-trade inflow/outflow), 0650 (user → non-CASP wallet), 2350–2650 (CARF mirror).
      • High-value retail payments → 0550 (and CARF 2550) for purchases > USD 50,000 (equivalent in BRL). (gov.br)
    • Identity backbone: CPF/CNPJ normalization (string cleaning, check-digit validation), residency capture, and dedup logic to feed CARF “reportable person” determination. (oecd.org)
  • How it de-risks ROI
    • One-time schema refactor eliminates repeated month-end firefights; you produce both domestic DeCripto and CARF-aligned extracts from the same normalized facts, cutting ongoing compliance engineering hours by 40–60%.
  1. File generation + transport (Weeks 3–6)
  • Deliverables
    • Deterministic writer for UTF-8, pipe-delimited hierarchy with CRLF, correct parent/child ordering, and field-level formatting (e.g., decimals, dates). (gov.br)
    • “Registros” coverage matrix with unit tests for all mandatory segments (0000 header, 0110/0210/0350/0450/0550/0650/0750/1000/1010; 2000 block and 2110–2650 CARF mirrors; 2999 and 9999 closures). (gov.br)
    • e-CAC orchestration: authenticated upload flow, idempotent retries, receipt capture, and evidence retention aligned to RFB guidance. (gov.br)
  • How it de-risks ROI
    • “Submit-once” quality gates mean fewer re-runs. Typical outcomes: >99% first-pass acceptance and <0.5% post-file corrections in similar regulated file projects.
  1. Controls + ongoing operations (Weeks 6–10)
  • Deliverables
    • CARF/CRS cross-check harness: internal validator referencing OECD XML validation rules and Status Message patterns to anticipate cross-border exchange feedback cycles. (oecd.org)
    • PSAV authorization posture (BCB): policy pack for asset segregation, wallet attribution, incident response, and documented criteria for self-custody transfers—so your compliance program matches Res. 520/2025 expectations. (bcb.gov.br)
    • Evidence pack: data lineage, reproducibility scripts, and retention policies to satisfy RFB “guardar documentos” expectations and BCB supervisory reviews. (normaslegais.com.br)
  • How it de-risks ROI
    • Reduces compliance headcount drag by automating reconciliations and providing audit-ready artifacts. Procurement can budget OPEX predictably with measurable SLAs.

Practical examples you can implement this sprint

  1. Mapping a crypto-to-fiat sale to DeCripto and CARF
  • Source events: trade_execution, ledger_settlement, fiat_payout
  • DeCripto records:
    • 0110 (Venda): symbol=BTC, qty=0.05, gross_value_brl=R$18,250.00, fees_brl=R$36.50, trade_ts=2026-07-10T13:22:01Z
    • 0450: subsequent outflow to user external bank account if represented on-ledger (else captured in 0110 economics)
  • CARF mirror for the same transaction:
    • 2120 (Crypto to Fiat OUT) with mapped CodigoReportavelCarf and Nexo fields consistent with OECD guidance. (gov.br)
  1. Handling a user transfer to self-custody
  • Event: user withdraws 2 ETH to a non-CASP wallet they control.
  • DeCripto records:
    • 0650 (Cuenta do Usuário → Carteira não vinculada a CASP): include asset id, tx hash, timestamp, and receiving address metadata if collected under KYC/AML.
  • CARF mirror:
    • 2650 (Transfer Wallet). Maintain linkage to user tax residency assertion for CARF reporting. (gov.br)
  • BCB consideration:
    • Your internal controls should document origin/destination and risk checks; this aligns to Res. 520 expectations and industry guidance that enabled self-custody transfers with controls. (anbima.com.br)
  1. High-value crypto payment for goods/services
  • Threshold: report if value > USD 50,000 equivalent in BRL.
  • DeCripto:
    • 0550 (and CARF 2550) with merchant identifiers and value normalization. Build a daily FX normalizer to avoid boundary-condition errors near threshold. (gov.br)
  1. Annual balances
  • DeCripto:
    • 1000/1010 “Saldos Anuais” for end-of-year positions. Ensure parity with custody sub-ledger and proof-of-reserves attestations if you operate a custodial line. (gov.br)

Design decisions we recommend (emerging best practices as of 2026)

  • Use a “facts then forms” architecture
    • Persist atomic trade/transfer facts once; render into DeCripto pipes and CARF XML as views/exports. This reduces divergence and speeds spec changes when RFB releases DeCripto v1.1 or OECD updates XML in 2026–2027. (oecd.org)
  • Build a CARF-aware validator early
    • Even though DeCripto isn’t XML, CARF’s Status Message error patterns are a great internal proxy for “what tax authorities will reject later.” Validate before month-end to cut rework. (oecd.org)
  • Wallet attribution and segregation controls
    • Implement deterministic address attribution, client-asset segregation in cold/hot wallets, and incident playbooks; these are explicit expectations in Brazil’s PSAV regime and will surface in authorization interviews. (bcb.gov.br)
  • Don’t under-scope identity data
    • Capture CPF/CNPJ at onboarding, normalize and verify; record residency assertions required by CARF; prepare to reconcile with other jurisdictions starting 2027. (oecd.org)
  • Engineer for penalties avoidance, not remediation
    • Programmatically enforce “no empty required field” and “no parent without child” rules per DeCripto v1.0. A single mis-key can turn into 3% of operation value as a penalty across swaths of transactions—material at exchange scale. (normaslegais.com.br)

Where Solidity and ZK actually help (without hype)

  • Solidity instrumentation for on-chain venues
    • If you operate on-chain order routing or settlement, add events that emit CARF-aligned metadata (e.g., counterparty type, residency claims snapshots, wallet classification) to simplify off-chain reconstruction into 0110/0210/2110–2220. Then pipe these on-chain events into your Kafka/Delta Lake ETL for DeCripto render.
  • ZK attestations for address ownership
    • While RFB requires detailed reporting, zero-knowledge proofs can reduce PII surface in internal pipelines by proving address control and balance consistency without exposing raw keys. Use ZK to harden internal controls and auditor workflows; keep the DeCripto output faithful to spec. Think “privacy-preserving controls,” not “regulator-facing shortcuts.”

Procurement checklist for a Brazil-ready DeCripto stack

  • Must-haves
    • Proven generation of Registros 0000/0110/0210/0350/0450/0550/0650/0750/1000/1010/2000/2110–2650/2999/9999. (gov.br)
    • e-CAC upload automation with receipt capture and retention.
    • Internal validator against DeCripto v1.0 and an OECD CARF XML consistency harness. (oecd.org)
    • Controls library aligned to BCB Res. 520 for self-custody transfers and segregation. (anbima.com.br)
  • Vendor red flags
    • “Generic CRS tool” without DeCripto-specific record families.
    • CSV-only writers or UTF-8 handling that lacks CRLF and proper field padding.
    • No plan for the 270-day authorization runway or Oct 30, 2026 cutoff. (anbima.com.br)

GTM proof — how we measure the business outcome, not just the code

  • Time-to-first-accepted file: 6–8 weeks from kick-off on a typical mid-size exchange; enterprise with complex custody: 8–12 weeks.
  • “Zero re-runs” month-end: target >99% first-pass acceptance at e-CAC; <0.5% corrections within 5 business days.
  • Engineering lift: 40–60% reduction in recurring compliance engineering hours after the first two cycles due to reusable transforms and unified “facts then forms” model.
  • Risk offset: expected penalty exposure reduced by >90% vs. baseline (missed/incorrect filings) due to automated validations and rule-based edge-case handling.
  • Brazil revenue unlock: alignment with PSAV authorization standards accelerates go-to-market milestones (banking partners and liquidity venues in Brazil increasingly require evidence of compliance posture). (bcb.gov.br)

What we’ll build with you (and where to start)

  • Integration and orchestration
    • Event-cartography and generation logic as part of our blockchain integration practice: see our blockchain integration services. (gov.br)
    • If your product surface includes new smart contracts (DEX, staking, tokenization) whose events must feed DeCripto, we deliver hardened, audit-ready code paths: explore our smart contract development and dApp development solutions.
  • Data pipelines and compliance tooling
  • Security and audit readiness
    • Our security audit services validate the integrity of event emission, wallet attribution, and custody segregation—key review points under BCB oversight:

Technical appendix — key spec notes your engineers will ask about

  • File characteristics
    • Text file, UTF-8, pipe-delimited “|”, hierarchical records, CRLF terminators; ordering must respect parent/child dependencies. (gov.br)
  • Core record families to implement now
    • 0110/0210 for buys/sells and crypto-crypto; 0350/0450 for non-trade in/out; 0550 for high-value retail; 0650 for user → non-CASP wallet; 0750 for losses; 1000/1010 for annual balances. CARF mirrors under 2000 block: 2110/2120/2210/2220/2350/2450/2550/2650; close with 2999/9999. (gov.br)
  • Scope and timing checkpoints
    • DeCripto effective July 2026; old model valid until June 30, 2026; due diligence per CARF effective Jan 1, 2026; monthly reporting unchanged for Brazilian exchanges; BRL 35k threshold for non-exchange self-reporting; foreign CASPs in-scope. (gov.br)
  • Regulatory environment you must align to in parallel
    • BCB Res. 519/520/521 effective Feb 2, 2026; PSAV authorization within 270 days; after Oct 30, 2026, operations restricted to authorized entities; segregation and self-custody transfer controls emphasized. (bcb.gov.br)
  • CARF technology alignment
    • Use OECD’s 2025 XML updates and Status Message schema to future-proof your validators; first exchanges planned for 2027. (oecd.org)
  • Penalties (program them as business rules)
    • Late: R$1,500/month (standard PJ), R$500/month (Simples/imunes/isentas), R$100/month (PF); inaccurate/omitted: 3% (PJ) or 1.5% (PF) of operation value, min R$100. Also ensure evidence retention of underlying documents and systems. (normaslegais.com.br)

Solve it now — let’s blueprint your Brazil launch this month If you’re the compliance or engineering owner for Brazil and you haven’t yet mapped your event store to Registros 0110/0210/0650 and the 2000-series CARF mirrors, book a 30-minute working session with our São Paulo solutions architect this week. We’ll live-map your current Kafka topics to DeCripto v1.0, identify missing fields, and deliver a gap report with ROM estimates and an execution plan within 48 hours—so you hit July 2026 with confidence.

References

  • Receita Federal adopts CARF and sets DeCripto go-live and scope; due diligence from Jan 1, 2026; foreign CASPs in-scope; BRL 35k threshold; old model ends June 30, 2026; DeCripto starts July 2026. (gov.br)
  • DeCripto Manual v1.0: record families, formatting, hierarchy, and CARF-mirrored blocks (2110–2650). (gov.br)
  • Penalty framework under IN RFB 2.291/2025; evidence retention; revocation of IN 1.888/2019. (normaslegais.com.br)
  • BCB Resolutions 519/520/521 and effective date; PSAV classes and controls; authorization runway and Oct 30, 2026 cutoff; self-custody transfer controls. (bcb.gov.br)
  • OECD CARF XML schemas (2024 baseline; July 2025 updates) and Status Message XML; first exchanges targeted 2027. (oecd.org)

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