What other nations can learn

Key points to remember:

• The measures taken by Brazil are corporate and municipal, not sovereign.

• B3’s spot ETFs and 0.01 BTC resized futures allow treasurers to earn, scale and hedge their exposure using familiar tools.

• The new VASP standards (licensing, AML/CFT, governance, security), which came into force in February 2026, reduce operational uncertainty.

• Key sequence: write rules → list simple access products → add coverage tools → mandate disclosure.

What is really happening in Brazil?

To be clear, Brazil’s National Treasury and central bank are not adding Bitcoin to the country’s sovereign reserves. There is also no law requiring government agencies or public companies to hold Bitcoin (BTC).

What’s happening instead is a patchwork of municipal initiatives, listed companies and new market infrastructures coming online:

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

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

What has Brazil built so far?

Brazil has spent the last few years creating regulated and familiar ways to access Bitcoin.

In 2021, B3 listed Latin America’s first Bitcoin ETF (QBTC11 from QR Asset), providing institutions with an auditor-friendly instrument without requiring self-custody from day one. Derivative products followed.

In mid-2025, B3 reduced the size of the Bitcoin futures contract from 0.1 BTC to 0.01 BTC to broaden participation and improve coverage. The change was officially implemented on June 16, 2025, through a circular and a public notice.

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

The rules evolve alongside the products. In November 2025, the central bank published detailed standards for VASPs covering licensing, AML/CFT, governance, security and consumer protection, the application of which will begin in February 2026.

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

Why do Brazilian treasurers do this?

Treasury teams are trying to smooth profits and protect purchasing power in a market where the Brazilian real can fluctuate sharply depending on political decisions and external shocks.

A small allocation of Bitcoin, held using audited instruments, adds a liquid, non-sovereign hedge alongside dollars and local notes without requiring new custody operations.

It’s also about using familiar pipes. Spot ETFs and futures listed on B3 allow treasurers to size, rebalance and hedge according to the same governance and audit routines they use for other assets. The smaller 0.01 BTC futures contract makes hedging more precise and less expensive to implement on a treasury scale.

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

Access is important for those who cannot hold crypto directly. OranjeBTC’s B3 listing gives equity exposure to a large BTC position on the balance sheet, allowing institutions to participate via a listed vehicle while remaining within their mandate.

Finally, the regulatory arc reduces operational uncertainty. With central bank VASP standards covering licensing, AML/CFT, governance and security due to come into effect in February 2026, treasurers can rely on approved intermediaries and documented controls rather than bespoke crypto infrastructure.

Did you know? A spot Bitcoin ETF is a fund that holds real Bitcoin and allows you to buy shares of that Bitcoin on an exchange, just like any other ETF. It gives you price exposure, daily liquidity, and audited custody without managing your own wallet or keys, which is why treasurers and institutions often prefer it to holding coins directly.

The risks and how Brazil faces them

Brazil knows the risks and is tightening the rules.

• Market Volatility: Bitcoin can fluctuate wildly, so treasurers who opt for this option typically cap position sizes, set rebalancing rules, and use listed hedges. B3’s smaller 0.01 BTC futures contracts, effective June 16, 2025, make it easier to hedge profit and loss and liquidity shocks with finer precision.

• Operational and counterparty risk: Personal guarding, trade exposure and supplier security are not trivial. The central bank’s new VASP standards are pushing crypto intermediaries toward traditional financial standards.

• Legal clarity and application: Prosecutors and regulators need predictable tools when crypto intersects with criminal cases. A new bill would allow financial institutions to liquidate seized cryptocurrencies, aligning processing with foreign exchange and securities processes and reducing gray areas in enforcement.

• Public view and disclosure: The “Bitcoin Treasure” remains politically sensitive. The listed pathways encourage companies to produce auditor-approved reports and provide ongoing information on exposure, conservation and risks. This transparency helps boards and regulators feel comfortable as the market evolves.

How Brazil Compares: BTC Cash Paths

What other nations can learn

1. Remember, Brazil wrote rules. The central bank has set clear criteria for when crypto-to-fiat conversions are treated as currencies and raised standards for VASPs on AML/CFT, governance, security and consumer protection.

2. Ship single access products quickly. QBTC11 and its peers launched in 2021, giving institutions a familiar, audited instrument instead of requiring them to create a custody from scratch. With an ETF trajectory, treasurers can size exposure within existing mandates.

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

4. Encourage standards of disclosure through public vehicles. Listed “Bitcoin treasury” companies such as Méliuz and OranjeBTC create benchmarks for audits, board processes, depreciation policies and reporting cadence. These become models that others can copy.

5. Pilot project below the federal level. Pilot projects by cities or agencies raise political and accounting questions very early on. Rio’s 1% signal in 2022 showed how quickly optics become history and why mandates and risk limits must be explicit.

The sequence is simple: write the rules, introduce simple access products, reduce the size of derivatives to support hedging, and enable the development of disclosure standards in public markets. Only then does the conversation about putting BTC into the treasury make sense.