When the chairman of a regulatory body like the CVM places asset tokenization at the center of their management agenda, it is not just another item on the news cycle, it is a sign of market maturity.
The relationship between tokenization and the CVM has moved beyond exploratory discussions and into the realm of institutional priorities, with a name, a timeline and concrete regulatory implications.
For those operating in the structured market, this movement cannot be read as political noise. It needs to be read as a driver of operational decisions.
This article analyzes what the CVM’s new agenda means in practice: which regulatory pillars are in focus, how the expected regulatory updates affect platforms and structurers, and why security, traceability and governance are no longer optional differentiators but conditions for operating in the regulated digital asset market.
What are the priorities of the CVM’s new leadership?
The CVM’s new leadership presented a structured plan starting in the first months after taking office and unfolding over a one-year cycle.
Within this plan, two topics stand out explicitly: tokenization and market security, and the two are directly connected.
On the tokenization front, the agenda involves updating regulatory frameworks (INSERIR LINK PARA O ARTIGO “Popularização das operações de crowdfunding: O que mudou com a evolução da CVM 88?”) that currently limit the scale of operations. On the security front, which the new chairman calls surveillance, the focus is on governance, cybersecurity, structural compliance and the prevention of financial crime.
In practice, this combination means the regulator does not simply want more tokenization. It wants tokenization with traceability, with auditable processes and with agents who demonstrate real internal control capabilities.
Pillars that were once considered best practices are now being positioned as structural requirements.
For the capital market, this movement has an immediate effect: it raises the bar for entry.
Platforms and structurers operating without solid governance or without integration with regulated agents will find it increasingly difficult to stay in the market, not because of direct punishment, but because they will be unable to keep up with the new level of requirements the regulator is formalizing.
What does it mean for tokenization to become a priority on the CVM’s agenda?
The tokenization market under CVM 88 surpassed R$ 3 billion in issuances in just over two years, according to a report published by Capital Aberto.
Operations that were previously unviable, in the R$ 1 million to R$ 30 million range, gained real access to the capital market through tokenized structures. This volume did not go unnoticed by the regulator.
When a market grows quickly and in volume without the regulatory framework keeping pace, two risks emerge: poorly structured operations gaining ground alongside serious ones, and the regulator itself losing its monitoring capacity.
The CVM’s response on the tokenization agenda addresses exactly these two risks.
Why is regulatory attention to the topic a sign of maturity, not risk?
There is a recurring misconception in the market: treating regulatory attention as a threat. In practice, the opposite is true.
When the regulator begins to actively monitor a segment, it is because that segment has become relevant enough to require a matching structure.
The tokenized real estate market, digital FIDCs and tokenized private credit structures all benefit from a clear regulatory agenda.
Without it, the institutional market stays at a distance. Asset managers, pension funds and family offices do not allocate capital to structures without well-defined regulatory guidance.
The inclusion of tokenization on the CVM’s agenda is therefore what enables the sector’s next phase of growth: the institutional phase. And that phase requires operations that were built from the start for this level of rigor.
What is the difference between regulation that limits and regulation that structures scale?
Not all regulation works the same way. Some rules create barriers to entry without generating systemic efficiency, while others define the perimeter within which serious operations can scale with legal certainty.
The expected update to CVM 88, the connection with CVM Resolution 175 and the FÁCIL Regime (CVM Resolution 232) are being read by organizations such as ABToken as regulation of the second kind: not limiting, but structuring.
The expectation is that the new frameworks will expand operational limits for crowdfunding platforms, create conditions for tokenized funds to scale and connect the digital asset market to a more robust institutional layer.
This changes the competitive landscape. Those who already operate with integrated compliance, end-to-end traceability and auditable governance do not need to adapt. They are already positioned for the market that regulation is designing.
Those who still rely on improvised structures will need to rebuild, and the cost of that rebuilding tends to be high.
What are the pillars of the new regulatory agenda for tokenization?
The CVM’s regulatory agenda for tokenization is not limited to rule updates. It is organized around operational pillars that define what it means to operate seriously in the digital asset market.
Understanding each of these pillars is a prerequisite for anticipating what will be required.
- Surveillance: this is the central concept of the new CVM chairman’s security agenda. It encompasses continuous monitoring of operations, the ability to identify irregularities in real time and transaction traceability. In the context of tokenization, this means that every issuance, every transfer and every settlement must be recorded in an auditable way and be accessible to the regulator when needed.
- Structural compliance: goes beyond having KYC/AML policies on paper. It involves operational processes that ensure ongoing verification of participants, segregation of duties and the ability to demonstrate compliance at any point in the asset’s lifecycle.
- Governance: covers the decision-making structure within platforms and issuing vehicles. Who signs what, what the limits of each agent’s role are, how conflicts of interest are managed: all of this falls within the scope of governance that the regulator is now watching more closely.
- Blockchain traceability: distributed ledger technology stops being a sales pitch and becomes an operational requirement. End-to-end traceability, from issuance to settlement, is what allows the regulator, the structurer and the investor to follow the asset’s full lifecycle with verifiable transparency.
- Crime prevention: AML/CFT (anti-money laundering and countering the financing of terrorism) was already a regulatory obligation. What changes is the depth of implementation required, and the expectation that platforms demonstrate real technical monitoring capabilities, not just policy documentation.
These five pillars form the core of what the CVM is calling serious and secure operation in the tokenization market.
They are nothing new for those who have already built their structure to this standard, but they are real barriers for those who have not yet reached this level.
What does the evolution of CVM 88 and related rules mean in practice?
The public consultation on the reform of CVM Resolution 88 was concluded in January 2026.
The market’s expectation, shared by organizations such as ABToken in Capital Aberto, is that the new rules will be published throughout 2026 and early 2027, within the new leadership’s term.
In practice, the expected changes affect three main dimensions:
- Expanded operational limits: the current CVM 88 imposes value restrictions per offering and per issuer. The expectation is that these limits will be revised to accommodate the market’s real growth, enabling larger operations within the same regulatory framework for structured crowdfunding.
- Integration with CVM Resolution 175: Brazil’s regulatory framework for investment funds is directly connected to the tokenization agenda, especially for structures that combine collective investment vehicles with tokenized issuance. Consistency between the rules is what allows tokenized funds to operate on a solid legal foundation.
- FÁCIL Regime (CVM Resolution 232): established by the CVM in 2025, the FÁCIL Regime is a regulatory regime that simplifies registration and public offerings for Smaller Companies, with annual gross revenue of up to R$ 500 million, reducing documentation requirements and the cost of accessing the capital market. Designed to simplify access to the capital market for small and medium-sized companies, the FÁCIL Regime overlaps with the world of tokenization by facilitating structured offerings with lower regulatory entry costs. For platforms operating in this segment, clarity on how the FÁCIL Regime interacts with tokenization rules is decisive for designing new operations.
These three regulatory pillars do not work in isolation.
They form a system that, when integrated, creates the conditions for tokenization to stop operating on the fringes of the market and start functioning as a full-fledged capital market structure, with scale, liquidity and institutional participation.
What do platforms and structurers need to be ready for the new regulatory standard?
The direct answer is: you cannot improvise compliance on top of a structure that was not built for it.
The new regulatory standard requires platforms and structurers to demonstrate real operational capability, not just stated intention.
In practice, this means having:
- Integration with regulated agents: DTVM, qualified custody, fiduciary agent and registration with a central depository. Without this integration, the operation has no regulatory basis to scale.
- Operational KYC/AML: automated identity verification and transaction monitoring processes, not manual forms.
- Full-cycle traceability: blockchain records that follow the asset from issuance to redemption, with real-time auditability.
- Documented and verifiable governance: policies that exist in practice, not just on paper.
- Ongoing compliance capability: not only at the time of issuance, but throughout the asset’s entire life.
For platforms that want to operate at this level of compliance without building each layer from scratch, BLOCKBR Whitelabel offers exactly this foundation: a regulated SaaS infrastructure with separate environments for issuers and investors, native KYC/AML integration and connection with the regulated agents required for operations within the capital market.
It is the model for those who want to operate seriously without having to recreate each operational component independently.
What does this regulatory movement confirm about the market’s direction?
The CVM’s tokenization agenda confirms something well-structured operations already knew: the regulated digital asset market is not an alternative to the traditional capital market, it is an evolution of it. And market evolutions, once they reach scale, require matching infrastructure.
What changes now is that the regulator is formalizing this understanding. This has a filtering effect: it separates operations built on a real structure from those that grew by taking advantage of the lack of clear regulation.
For the institutional market, this separation is decisive: asset managers and qualified investors need legal certainty to allocate capital to tokenized assets.
BLOCKBR, as an asset tokenization infrastructure for the regulated financial market, was built for exactly this scenario.
Not as a response to the CVM’s new agenda, but as infrastructure that already integrates compliance, traceability, governance and regulated agents within an operational environment that matches the level of rigor the regulator is now formalizing.
BLOCKBR Station is the hub that ensures tokenized operations are connected to the complete regulatory layer: DTVM, custody, fiduciary agent and registration with a central depository.
It is the integration that turns a tokenized issuance into a capital market operation with a solid legal foundation, exactly what the new CVM leadership’s concept of surveillance requires.
And BLOCKBR Management complements this structure on the distribution side: it organizes investor relations, controls commissions and structures the sales funnel within a governed and traceable environment, ensuring that compliance covers not only issuance but the full cycle.
This is especially relevant for operations that need to demonstrate ongoing compliance throughout the asset’s life, as the new regulatory agenda requires.
For those working with real estate tokenization, FIDC tokenization or tokenized private credit structures, the direction is clear: the institutional market is opening up, but only to those who already operate at the standard it demands.
Infrastructure born regulated does not need to adapt, it is already ready.
There is a fundamental difference between building an operation and then adapting it to regulation, and building an operation on infrastructure that was already designed for the regulated market. This difference is not just technical, it is strategic.
When a platform or structurer needs to retrofit compliance onto an existing structure, the cost is high and the outcome is uncertain. Processes created for speed need to be rebuilt for auditability. Data that was not structured for traceability needs to be reorganized. Integrations with regulated agents that did not exist need to be created from scratch.
Those who start with regulated infrastructure do not go through this cycle. Every operation issued is born with blockchain traceability, integrated KYC/AML, connection to the required regulated agents and documented governance. When the regulator raises the bar, these operations are already at the required level.
This is the position BLOCKBR places platforms, asset managers and structurers in when they choose to operate within its ecosystem. The CVM’s new agenda does not require adaptation from those already building to the right standard. It confirms that this standard has always been the only sustainable path.
To understand how this infrastructure works in practice and what it means for your operation, explore BLOCKBR’s infrastructure and assess what your structure still needs to reach the level the market is demanding now.
FAQ: Frequently asked questions about tokenization, the CVM and the new regulatory agenda
What has the CVM defined as a priority for tokenization?
The CVM’s new leadership has signaled tokenization as a priority, focusing on two main fronts: updating the regulatory framework, including the reform of CVM Resolution 88, CVM Resolution 175 and the FÁCIL Regime, and the security agenda, which the chairman calls surveillance, covering governance, cybersecurity, compliance and the prevention of financial crime.
The market expects new rules to be published throughout 2026 and early 2027.
What is surveillance in the context of asset tokenization?
Surveillance, as defined by the CVM’s new leadership, is the set of practices and structures that ensure continuous monitoring, traceability of operations and the ability to identify irregularities in real time.
In the context of tokenization, this includes auditable blockchain records of all transactions, robust KYC/AML processes and documented governance that allows the regulator to verify the compliance of any operation at any point in its lifecycle.
What changes with the CVM 88 update for tokenization operations?
The reform of CVM Resolution 88 is expected to expand operational limits for structured crowdfunding platforms, enabling higher-value operations within the same regulatory framework.
In addition, greater clarity is expected on governance, compliance and traceability requirements for issuers and platforms, raising the bar for entry and separating serious operations from improvised structures.
These impacts are directly relevant to those structuring assets such as tokenized CRIs and other digital private credit instruments.
Are compliance and traceability mandatory in regulated tokenization operations?
Yes. Within the regulated capital market, compliance and traceability are not optional differentiators, they are operational requirements.
The CVM’s new agenda reinforces this understanding by positioning surveillance as a central pillar for how platforms and issuers operate.
Blockchain traceability, which records the asset’s entire lifecycle from issuance to settlement, is the technical mechanism that makes this requirement work in practice.
How can you tell whether a tokenization operation is aligned with the CVM’s new agenda?
An operation aligned with the new regulatory agenda must demonstrate: integration with regulated agents (DTVM, custody, fiduciary agent), full blockchain traceability, operational and auditable KYC/AML processes, documented and verifiable governance, and the ability to maintain ongoing compliance throughout the asset’s entire life.
Operations that rely on improvised structures or that do not have these components integrated will find it increasingly difficult to operate at the level the regulator is formalizing.
Learning more about banking innovation and technology can help map out what separates prepared structures from those that still need to evolve.
What is the FÁCIL Regime and how does it connect to tokenization?
The FÁCIL Regime, established by CVM Resolution 232, is a simplified regulatory framework designed to make it easier for small and medium-sized companies to access the capital market, reducing costs and regulatory complexity at entry.
Its connection to tokenization lies in the possibility of structuring tokenized offerings with a lower barrier to accessing the regulated market, expanding the range of issuers that can use digital asset infrastructure within a clear regulatory environment.
Clarity on how the FÁCIL Regime interacts with CVM 88 and with tokenization rules is one of the points the market is waiting for with the publication of the new rules.
