Key takeaways:

• Brazil’s moves are corporate and municipal, not sovereign.

• B3’s 0.01 BTC spot ETFs and floating futures allow treasurers to profit, size and hedge exposure using familiar tools.

• Novel VASP standards (licensing, AML/CFT, management, security), effective from February 2026, reduce operational uncertainty.

• Key sequence: write rules → list regular access products → add security tools → force disclosure.

What is actually happening in Brazil?

To be clear, Brazil’s 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 companies to hold Bitcoin (BTC).

Instead, what’s happening is a patchwork of city initiatives, publicly traded companies, and recent market infrastructure coming online:

In the following sections we will describe the “what”, “why” and risks involved.

Did you know? B3 (tiny for Brasil, Bolsa, Balcão) is the main stock exchange in Brazil, created in 2017 by the merger of the São Paulo stock, futures and commodity exchanges. It is one of the largest market infrastructures in the world and the first in Latin America to list a Bitcoin spot fund (ETF).

What has Brazil built so far?

Brazil has spent the last few years building regulated, high-profile ways to access Bitcoin.

In 2021, B3 listed Latin America’s first spot Bitcoin ETF (QR Asset’s QBTC11), providing institutions with an auditor-friendly instrument without the need for self-audit from day one. Then derivatives emerged.

In mid-2025, B3 reduced the size of Bitcoin futures contracts from 0.1 BTC to 0.01 BTC to expand participation and improve hedging. The change was formally implemented on June 16, 2025 through a circular and public announcement.

Product innovations kept pace. Asset managers have launched hybrid funds that combine Bitcoin and gold on B3, showing that regulators and the exchange are comfortable hosting cryptocurrency-related products on public markets.

The collection of recipes matures along with the products. In November 2025, the central bank published detailed standards for VASPs on licensing, anti-money laundering and counter-terrorism financing, governance, security and consumer protection, with enforcement starting in February 2026.

For treasurers, this reduces operational uncertainty as they rely on ETFs, futures and regulated intermediaries.

Why Brazilian treasurers do it

Treasury teams are trying to velvety out profits and protect purchasing power in a market where the Brazilian real can swing wildly due to political decisions and external shocks.

A petite allocation of Bitcoin, held through controlled instruments, provides a liquid, non-sovereign security alongside dollars and local notes, without the need for recent custodial operations.

It’s also about using known pipes. Spot ETFs and futures contracts listed on B3 enable treasurers to size, rebalance and hedge under the same governance and audit procedures they exploit for other assets. The smaller 0.01 BTC futures contract makes hedging more precise and cheaper to execute on a treasury scale.

There is already a management plan. Méliuz showed that sequence boards want: shareholder approval → clear disclosure → implementation → additional capital to scale the position. This reduces career risk for other CFOs considering a pilot assignment.

Access matters for those who cannot directly store cryptocurrencies. The listing of OranjeBTC on the B3 exchange provides capital exposure to a huge BTC balance sheet position, enabling institutions to participate through a listed vehicle while still complying with the mandate.

Finally, the regulatory circle reduces operational uncertainty. With the central bank’s VASP standards covering licensing, anti-money laundering, anti-terrorist financing, governance and security scheduled to come into effect in February 2026, treasurers can rely on licensed intermediaries and documented controls rather than purpose-built cryptographic infrastructure.

Did you know? The Spot Bitcoin ETF is a fund that holds actual Bitcoin and allows you to buy shares of that Bitcoin on an exchange, just like any other ETF. It provides price exposure, daily liquidity, and controlled custody without having to manage your own wallet or keys, which is why treasurers and institutions often prefer it to direct coin custody.

The threats and how Brazil deals with them

Brazil knows the risks and is tightening the rules.

• Market Volatility: Bitcoin can fluctuate wildly, so treasurers who typically choose capped position sizes set rebalancing rules and exploit exchange-traded hedges. Smaller 0.01 BTC B3 futures, effective June 16, 2025, facilitate more correct hedging of gains and losses and liquidity shocks.

• Operational and counterparty risk: Self-care, foreign exchange exposure, and provider security are not insignificant. Novel central bank VASP standards push crypto intermediaries towards time-honored financial norms.

• Legal clarity and enforcement: Prosecutors and regulators need predictable tools when cryptocurrencies intersect with criminal cases. The recent law would enable financial institutions to liquidate seized cryptocurrencies, aligning treatment with foreign exchange and securities processes and limiting gray areas in law enforcement.

• Public Optics and Information Disclosure: The “Bitcoin Vault” remains politically sensitive. The above-mentioned paths encourage companies to conduct audit-verified reporting and continuous disclosure of information on exposure, storage and risk. This transparency helps boards and regulators feel comfortable as the market matures.

Brazil Comparison: BTC Treasury Paths

What other nations can learn

1. Remember that Brazil made the rules. The central bank has set clear criteria for treating cryptocurrency conversions as foreign currency and raised standards for VASPs in terms of anti-money laundering and counter-terrorism financing, governance, security and consumer protection.

2. Ship products with simple access sooner. QBTC11 and its peers launched in 2021, giving institutions a familiar, controlled instrument rather than forcing them to build a depository from scratch. With the ETF route, treasurers can scale exposure within existing mandates.

3. Add security tools for risk managers. In June 2025, B3 reduced the Bitcoin futures contract size to 0.01 BTC. Smaller contracts make hedging cheaper and safer, allowing boards to approve them and treasury teams to more precisely manage value at risk (VaR) and payouts.

4. Encourage disclosure standards in public vehicles. Listed “Bitcoin treasury” companies like Méliuz and OranjeBTC create benchmarks for audits, governance processes, impairment policies and reporting cadence. They become templates for others to copy.

5. Pilot below federal level. City or agency pilots disclose political and accounting issues early. The 1% signal from Rio in 2022 showed how quickly optics are becoming a mainstream topic and why mandates and risk limits need to be clear.

The sequence is straightforward: write a rule book, introduce regular access products, reduce the size of derivatives to support hedging, and allow disclosure standards to develop in public markets. Only then does the conversation about placing BTC in a vault make sense.