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Brazil financial sector readiness

BACEN Cybersecurity Readiness: CMN 4.893, BCB 85, and the 2025 Controls

BACEN cybersecurity readiness for banks, payment institutions, brokerages, and the technology providers that serve them. We assess your policy, governance, and the 14 controls the Central Bank of Brazil added in December 2025. You get evidence a supervisor can review and a risk-ranked roadmap. Most assessments take 6–12 weeks.

The rules at a glance
14Controls added in 2025
1 Mar 2026Compliance deadline
AnnualIndependent intrusion test
6–12 wksTypical readiness assessment
23+Technical experts
71Countries covered
REGULATION
Supervised, Not Certified
Evidence ready when the Central Bank asks
CONTROL BY CONTROL
All 14 New Controls Checked
From MFA to dark web monitoring
MAPPED
ISO 27001, LGPD, PCI DSS
One control set, several obligations
TAILORED
One Tailored Proposal
After a free scoping review
The rules, in plain terms

What BACEN Cybersecurity Rules Require

BACEN cybersecurity rules are the Central Bank of Brazil's requirements for how regulated institutions protect their systems and data. Banks and other financial institutions follow CMN Resolution 4.893/2021. Payment institutions follow BCB Resolution 85/2021. Both demand a board-approved cybersecurity policy, an incident response plan, an annual report, and control over cloud and data service providers.

The rules got much more specific in December 2025, after a series of attacks on providers connected to Brazil's payment infrastructure. The Central Bank no longer asks only for a sound policy. It now lists the technical controls it expects to see working.

Accredify Global assesses each requirement against your real environment. We check configurations, logs, test reports, and contracts, not just documents, and report what a supervisor would find.

PolicyApproved by senior management
IncidentsA tested response plan
ProvidersCloud and data services controlled
ReportingAn annual report on the plan
Where the rules stand

BACEN Cybersecurity in 2026: 14 New Controls, Now Enforceable

CMN Resolution 5.274/2025 and BCB Resolution 538/2025 were published on 18 December 2025. They amended the two core rules and added 14 mandatory procedures and controls. Institutions had until 1 March 2026 to comply.

Smaller institutions now carry bank-level duties. Payment institutions, brokerages, and distributors must meet the same controls as banks. No filing was due on the deadline. Instead, supervisors test compliance by asking for evidence, such as the date of the last intrusion test and the status of its findings.

Payment infrastructure gets special protection. Environments connected to Pix and the Reserve Transfer System (STR) must be isolated from other systems. Administrative access to them needs multi-factor authentication.

Feb 2021CMN 4.893 replaces the 2018 rule
18 Dec 2025CMN 5.274 and BCB 538 published
1 Mar 2026New controls required

Sources: BCB and CMN cyber requirements (Baker McKenzie) · CMN 5.274/2025 controls (Grant Thornton) · March 2026 deadline (Assbanc)

The 14 controls

BACEN Cybersecurity Controls, and the Evidence We Test

The 2025 amendments list fourteen controls. We group them into six areas and test each against live evidence.

AreaControls in the ruleEvidence we review
Identity and accessAuthentication and access controlsMFA coverage, privileged accounts, and access reviews
Data protectionEncryption and leakage preventionKey management, transaction integrity, and DLP alerts
Detection and responseIntrusion prevention and detection, malware protection, and traceabilityAlert handling, log retention, and incident tickets
ResilienceBackup management and network protectionRestore tests, segmentation, and Pix and STR isolation
Secure buildVulnerability management, hardening, and API securityScan results, configuration baselines, and API reviews
Trust and intelligenceDigital certificate management and cyber intelligenceCertificate inventory and dark web monitoring reports

The annual intrusion test deserves its own check. The rules require a specialized independent company, a documented report, and evidence that findings were fixed. We review the scope and the tester's independence, then follow each critical finding to closure. A test that skipped the Pix environment, or findings left open for months, is what supervisors notice first.

Who this is for

Who Needs a BACEN Cybersecurity Assessment?

Regulated institutions are covered directly. Their providers feel the rules through contracts and due diligence.

Banks and credit institutions

Institutions under CMN 4.893 that must show the new controls working.

Payment institutions

Issuers, acquirers, and wallets under BCB 85, now held to bank-level controls.

Brokerages and distributors

Securities firms newly brought up to the same standard as banks.

Pix participants

Institutions whose Pix and STR environments must be isolated and protected.

Cloud and software providers

Foreign and local providers answering Brazilian clients' due diligence.

Fintechs seeking authorization

Firms preparing evidence before they apply to the Central Bank.

How it works

How Our BACEN Readiness Assessment Works

Six steps, ending with a report your board can approve and a supervisor can read.

ScopeInstitution type, entities, systems, and payment connections.
GovernancePolicy, response plan, annual report, and board approval.
Control testingThe 14 controls checked against live evidence.
ProvidersCloud and data contracts, and provider controls.
RoadmapGaps ranked by supervisory and business risk.
Board reportA plain summary with owners and dates.

Expecting a supervisory request, or a client's due diligence questionnaire? Share the date in your scoping review.

Book a free scoping review
Reusing what you have

BACEN Rules vs ISO 27001, LGPD, PCI DSS, and DORA

Most Brazilian institutions answer to several frameworks at once. This is how they fit together.

FrameworkWhat it coversOverlap with the BACEN rules
ISO 27001Certified information security managementPolicy, risk, and most controls; not Pix isolation or BCB reporting
ISO 22301Certified business continuityBackups, recovery, and incident continuity
LGPDPersonal data protection, enforced by the ANPDSecurity safeguards and incident notice
PCI DSSCard data securityEncryption, access, testing, and logging
DORAEU financial sector resilienceSimilar duties for groups also active in the EU

An accredited ISO 27001 certificate is often the strongest base. It gives independent evidence of a working security system, and Accredify Global holds UAF accreditation for it. The BACEN assessment then covers what ISO 27001 does not: payment infrastructure isolation, the annual report, and the rule's specific provider duties.

Deliverables

What You Receive From the Assessment

Control-by-control results

Each of the 14 controls rated, with the evidence behind it.

Governance review

Policy, response plan, and annual report checked against the rules.

Payment environment review

Isolation and access findings for Pix and STR.

Provider oversight review

Contract terms and evidence gaps for key vendors.

Risk-ranked roadmap

Actions in priority order, with owners and dates.

Board summary

A short report your directors can approve.

Many institutions also need evidence for clients and partners abroad. A SOC 2 report helps providers selling to US customers. ISO 27701 certifies privacy management alongside LGPD, and ISO 42001 covers AI used in credit and fraud decisions. All three can reuse the evidence gathered here. Our certification process guide explains how an assessment leads into an audit.

Cost and timeline

BACEN Readiness Cost and Timeline

No list price applies. The effort depends on your institution and how much evidence already exists, and a free scoping review gives you a tailored proposal.

What changes the effort

  • Institution type — bank, payment institution, or provider
  • Payment connections — Pix, STR, and other infrastructure
  • Service providers — cloud, core banking, and data vendors
  • Group structure — several licensed entities
  • Existing evidence — ISO 27001 or PCI DSS already in place

Typical timeline

Assessment and report6–12 weeks
RemediationSet by your roadmap
Re-checkBefore each annual report
Choosing a partner

Questions to Ask a BACEN Cybersecurity Provider

What compliance and security leaders usually ask us first.

QuestionAccredify Global's answer
Can you certify us for BACEN?No one can. The Central Bank supervises directly.
Do you test or only read policies?We test against logs, configurations, and reports.
Do you run the intrusion test?We review it; where needed, we coordinate a tester.
Can you cover our providers?Yes, through contract and evidence reviews.
Do you give legal advice?No. Interpretation stays with your counsel.
How is it priced?A tailored proposal after a free scoping review.
Common questions

Frequently Asked Questions About BACEN Cybersecurity

Answers on the 2025 changes, intrusion tests, Pix, providers, cost, and timeline.

What is BACEN cybersecurity compliance?

It means meeting the Central Bank of Brazil's cybersecurity rules for regulated institutions. The core rules are CMN Resolution 4.893/2021 for banks and other financial institutions and BCB Resolution 85/2021 for payment institutions, both amended in December 2025.

What changed in December 2025?

CMN Resolution 5.274/2025 and BCB Resolution 538/2025, published on 18 December 2025, added 14 mandatory controls. They include multi-factor authentication, isolation of Pix and STR environments, annual intrusion tests by an independent company, and dark web monitoring.

When did the new controls have to be in place?

By 1 March 2026. There was no formal filing on that date, so supervisors check compliance when they ask for evidence, such as test reports and remediation records.

Who must comply?

Institutions authorized by the Central Bank of Brazil, including banks, payment institutions, brokerages and distributors. The 2025 changes gave payment institutions, brokerages and distributors the same controls as banks.

Does BACEN cybersecurity apply to foreign technology providers?

Not directly, but regulated institutions must control the risk from their service providers. Cloud, software and data providers serving Brazilian financial institutions are asked for evidence and contract terms.

Is there a BACEN cybersecurity certification?

No. The Central Bank supervises compliance directly; there is no certificate. Accredify Global provides an independent readiness assessment and report.

What is the annual intrusion test requirement?

The amended rules require an intrusion test at least once a year by a specialized independent company. The report must be documented and available to the Central Bank, with findings tracked to closure.

What does Pix and STR isolation mean?

The environments that connect to Pix and the Reserve Transfer System must be physically and logically isolated from other systems. Administrative access to them must use multiple authentication factors.

Does ISO 27001 satisfy the BACEN rules?

Not on its own, but it covers much of the ground. ISO 27001 gives you risk assessment, policies and controls. The BACEN rules add specific technical controls, reporting duties and provider requirements that must be checked separately.

How does BACEN cybersecurity relate to LGPD?

They overlap on security and incidents. LGPD protects personal data and is enforced by the ANPD, while the BACEN rules protect the financial system and are supervised by the Central Bank. A single control set can serve both.

What does the board need to approve?

The cybersecurity policy, the incident response plan and the annual report on how the plan was carried out. The amended rules expect the revised policy to be approved by senior management.

Do you perform the annual intrusion test?

Our readiness assessment reviews the test scope, the tester's independence and the remediation of findings. Where you need a tester, we coordinate one within the same plan.

How long does a BACEN readiness assessment take?

Most assessments take 6 to 12 weeks, depending on the number of systems, providers and entities in scope.

How much does a BACEN cybersecurity assessment cost?

There is no list price. The cost follows your institution type, systems, service providers and existing evidence. A free scoping review gives you a tailored proposal.

Do you give legal or regulatory advice?

No. We assess and report on controls and evidence. Interpretation of the rules stays with your compliance team and counsel.

Free BACEN scoping review

Show the Central Bank Your Controls Work, Before It Asks

Tell us about your institution, systems, and providers. We'll map the BACEN cybersecurity requirements that apply and send a tailored proposal.

Book your free scoping review →

Last reviewed by the Accredify Global compliance team.