Central Bank opens public consultation on regulation of digital wallets

In early April, the Central Bank of Brazil (BCB) published the Social Participation Notice No. 118/2025, initiating the Subsidy Collection No. 118/2025. The initiative seeks to gather contributions from society on the future regulation of the activities of so-called token requesters – such as Apple Pay, Google Pay and Samsung Pay – that offer token request and storage services in payment card transactions.

Tokenisation technology replaces real card data with digital representations (tokens), providing greater protection for transactions, especially on mobile devices with NFC technology.

With the growing adoption of digital wallets and the concentration of this market in the hands of big techs, the BCB began to assess potential competitive risks and tariff impacts, both for issuers and end users.

According to the BCB, there is special attention to the strategic role that token applicants have come to play, given their integration into devices considered essential in consumers’ daily lives.

This privileged position can confer significant bargaining power over card issuers, with the potential to pass on costs to the system and the end consumer.

Given this scenario, the BCB proposes two alternative regulatory approaches:

• Indirect regulation: requiring payment scheme regulations to recognise token requesters as a category of participant, establishing clear rules on fees and operating conditions;
• Direct regulation: subject token applicants to the BCB authorization and supervision process, with normative definition of tariff limits.

Contributions to the public consultation can be submitted until June 2, 2025, via the BCB website.

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