Brazil’s CVM opens a 60-day path toward an experimental rulebook for tokenized securities

Brazil’s securities regulator is taking a more explicit step toward onchain capital-markets policy. The Comissão de Valores Mobiliários, or CVM, has created a dedicated tokenization working group and told it to deliver an initial proposal for an experimental regulatory regime within 60 days of installation. That is an important shift for the RWA market because it signals that Brazil is no longer treating tokenized securities as a collection of isolated pilots. The regulator is now moving toward a framework that could govern how securities are issued, recorded, held, traded and settled when distributed ledger infrastructure is part of the stack.

The official mandate is broader than a simple technology review. In its announcement, the CVM said the new Grupo de Trabalho de Tokenização will study, test and recommend rules for activities tied to the registration, deposit, custody, negotiation and liquidation of securities on distributed ledger technologies. The body was created by Portaria CVM/PTE 177 and will run for an initial 120 days, with a possible 30-day extension. It brings together representatives from 14 organizational units inside the regulator, which is a notable detail in itself: tokenization is being handled as a cross-functional market structure issue rather than a niche innovation topic assigned to a single office.

That scope reflects the real regulatory problem. Tokenization does not just change how an instrument is represented on a ledger. It can collapse functions that are usually split across central depositories, registrars, custodians, brokers and settlement systems into one integrated workflow. Once that happens, legal and operational questions become unavoidable. Which record is definitive for ownership? Who controls key management and recovery? How should transaction reversals work when there is an operational failure or dispute? What liabilities attach to the infrastructure provider, the intermediary and the issuer? The CVM’s announcement makes clear that cybersecurity and the adequacy of the current regulatory perimeter are part of the review, which suggests the regulator is aiming at practical implementation questions, not only conceptual ones.

Brazil is not starting from zero. The CVM has already accumulated live-market experience through its regulatory sandbox. Under the framework now consolidated in Resolução CVM 29, the regulator admitted projects that tested blockchain-based issuance and secondary trading of securities, including structures tied to private-company fundraising, tokenized debentures and fund interests. The sandbox page maintained by the regulator shows how seriously those experiments were treated: proposals were screened through a formal admissions process, only a small subset were approved, and some of the selected models involved organized over-the-counter trading venues and DLT-based token representations of securities. In other words, the regulator has already seen where tokenization collides with existing rules in the wild.

The broader policy groundwork is also visible in Brazil’s innovation forums. Through the Laboratório de Inovação Financeira, a public-private initiative in which the CVM participates, Brazilian policymakers and market participants have spent the past several years studying cryptoassets, decentralized-finance design and digital market infrastructure. A 2023 CVM note on that work highlighted dedicated streams on market infrastructure, digital identity, legal treatment and tokenized issuers, along with the development of theoretical materials, pilots and prototypes. That matters because the new task force is not emerging in a vacuum. It sits on top of a longer domestic effort to map which parts of securities law remain technology-neutral and which parts become ambiguous once token-based workflows start replacing traditional post-trade plumbing.

For market participants, the most important phrase in the new mandate may be “experimental regime.” That wording implies the CVM is not trying to force a fully mature permanent rulebook before the market has been properly tested. Instead, it appears to be designing a controlled pathway for continued experimentation under clearer supervisory expectations. If executed well, that could reduce uncertainty for issuers, infrastructure providers and investors who want to use blockchain rails without stepping outside securities-law protections. It also gives the regulator room to observe edge cases around disclosure, investor eligibility, governance, custody and operational resilience before locking in a final framework.

The timing is notable for the global RWA market as well. Many jurisdictions have embraced tokenization in speeches and pilot programs, but far fewer have begun the harder work of determining how existing securities-market functions should be reassigned or supervised when ledger-native workflows are introduced. Brazil’s approach now looks more concrete than a generic innovation endorsement. Within 60 days, the CVM’s board is supposed to receive an initial proposal; by the end of the group’s work, it should have a fuller set of recommendations on how tokenized securities can be accommodated inside a modernized regulatory architecture. That does not guarantee fast commercialization, but it does create a clearer policy runway. For onchain capital markets, that kind of institutional follow-through is often more valuable than another pilot announcement.