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While Racing To Obtain A Banking License, Nubank Ends Up Being More Than Just A Payment Institution, Starts Paying More Taxes, Assuming Compulsory And Free Essential Services, Following Strict Capital And Governance Rules, But Remains Fully Digital, Without Needing To Open A Physical Branch To Serve Customers All Over Brazil Today.
By the turn of November, after the Central Bank and the National Monetary Council approved new rules restricting the use of “bank”, and following announcements made on Wednesday, 3, and reactions from Febraban on Thursday, 4, Nubank decided to accelerate its transition to a real bank, assuming more costs and obligations in exchange for full regulatory status with customers.
Subsequently, Febraban itself intensified its criticisms of the model from the purple one, questioning taxes, interest rates, and credit profiles, while specialists in taxation, governance, and compliance pointed out that the change could make Nubank even more similar to the large traditional banks, but without opening a physical branch and maintaining a 100% digital operation in Brazil.
Why Nubank Needs To Become A Real Bank Now
Today, from a regulatory perspective, Nubank is not a bank, despite being perceived as such by a good portion of its customers.
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It operates with a payment institution license and a Credit, Financing, and Investment Society (SCFI) license, which limits its actions in classic financial intermediation.
In practice, Nubank can make Pix, issue cards, maintain payment accounts, and lend money, but cannot accept deposits from the public and lend those same resources like a traditional bank, directly using the balances of current account holders and savers.
When it wants to offer credit, Nubank needs to rely on shareholder capital, its own cash, or market structures like SCD and SEP, which makes the operation more complex.
At the end of November, the Central Bank, together with the National Monetary Council, published a resolution that regulates the nomenclature and presentation of authorized institutions.
The rule states that payment institutions cannot use “bank” or “bank” in the business name, brand, trade name, or internet domain unless they have authorization to operate as a bank.
These institutions will have up to one year to adapt, presenting a plan within 120 days with the procedures and timeline for adaptation.
In practice, Nubank faced two options: either change its brand, discourse, and way of presenting itself to the public, or fully embrace the banking license.
By announcing on Wednesday, 3, that it is working to obtain the license, Nubank chose the path of becoming a real bank, with all associated obligations.
What Changes In Taxes: CSLL, IR And PIS/COFINS
The main immediate impact for Nubank is in taxation. The Social Contribution on Net Profit (CSLL) is the central point of this shift.
Today, fintechs like Nubank pay about 9% of CSLL, while banks pay 20%, which represents an increase of 11 percentage points in the rate for the purple one.
Tax specialist Emanuelle Lemos reminds us that an incumbent bank like Itaú or Caixa can reach 45% total tax burden on profit, adding about 15% of basic IRPJ, 10% additional IR, and 20% of CSLL.
Fintechs are treated as ordinary legal entities, with a much lower burden. By becoming a bank, Nubank starts to play under the same tax rules as large banks, reducing the fiscal difference that generated discomfort among traditional competitors.
In PIS/COFINS, Nubank also loses flexibility. As a fintech, it can opt for:
- 3.65% under the cumulative regime, or
- 9.25% under the non-cumulative regime, which allows for credits on operations.
Among banks, this choice does not exist. PIS/COFINS is necessarily collected in the cumulative regime, at a rate of 4.65%, which tends to increase Nubank’s tax bill when it is officially classified as a bank.
On the other hand, Nubank already has access to typical banking institution tools, such as Interest on Own Capital (JCP). If a bank has R$ 100 million in profit and distributes R$ 20 million via JCP, the taxable profit drops to R$ 80 million.
Nubank can use JCP today and will continue to be able to after obtaining the banking license, although fintechs, in general, prefer to reinvest profits instead of remunerating shareholders with this instrument.
Minimum Capital, Basel And Heavier Governance Structure
From a prudential standpoint, becoming a bank means living under the same capital and risk rules as large banks, with a requirement for Reference Equity (PR) compatible with the risk of operations and adherence to the standards of the Basel Accord.
Under the old reference rule, a simple commercial bank needed R$ 17.5 million in initial capital, while a multiple bank, with more portfolios, needed to combine capitals, reaching something between R$ 25 million and R$ 30 million.
In 2025, the Central Bank updated the model through Joint Resolution No. 14, requiring capital based on the type and volume of operations.
Today, the simple use of the word “Bank” in the brand already adds about R$ 30 million to the capital requirement, in addition to extra amounts for each relevant activity, such as R$ 7 million for granting credit and R$ 5 million for financial intermediation, among others.
In specialists’ assessments, there should not be a lack of capital for Nubank to meet these requirements, as the institution has been consolidating with a base of more than 100 million customers and a size comparable to that of large banks in terms of volume of operations.
The challenge lies less in raising capital and more in structuring controls, committees, audits, and layers of governance compatible with bank status.
According to lawyer Fernando Moreira, the banking system is much heavier and more expensive in terms of governance and compliance, requiring processes of due diligence, documentation, and continuous auditing.
Still, Nubank starts from a more advanced level than smaller fintechs, which would have to build this structure practically from scratch.
Essential Free Services That Nubank Will Have To Offer
Upon obtaining the license, Nubank will be required to follow the Resolution No. 3,919/2010 of the National Monetary Council (CMN), which defines the Package of Essential Services.
This means that Nubank, as a bank, will not be able to charge fees for a range of basic services for individuals, among them:
- Provision of debit card
- 4 withdrawals per month at a counter or ATM
- 2 transfers per month between accounts in the same institution
- 2 monthly statements with operations from the last 30 days
- Unlimited online inquiries
- Provision of up to 10 check slips per month, if there is an offer of a checking account with checks
- Check clearance
For the customer, this tends to make what is free and what may be charged clearer at Nubank, aligning the purple one with the same minimum obligations of large banks.
For Nubank, it is yet another layer of regulatory compliance, but one that reinforces the image of basic services without fees for the average user.
Compulsory, Credit And The Destination Of Customers’ Money
Another central point is the compulsory collection, a mechanism by which banks are required to deposit part of the resources raised in accounts held by them at the Central Bank.
This money remains immobilized and serves to control the liquidity of the system, limiting how much can be used for loans.
Currently, Nu Financeira S.A., which is already a financial institution, is subject to the compulsory rules applicable to the operations it carries out.
On the other hand, Nu Pagamentos S.A., responsible for the payment account, does not collect compulsory on the funds held in those accounts, since payment institutions cannot use these balances for their own operations.
As it consolidates as a bank, Nubank tends to deal more directly with the compulsory, while at the same time gaining the ability to operate in classic financial intermediation. This means that Nubank can collect deposits more broadly and lend those resources, provided it meets the capital, risk, and allocation requirements defined by the Central Bank.
In addition, Nubank, as a bank, will have to:
- Apply part of the collections for specific purposes, such as real estate credit and microcredit
- Send periodic reports to the Central Bank, detailing operations, balances, and risks
- Maintain more robust risk management systems, covering credit, liquidity, market, and operational risk
In practice, customers should perceive more offers of structured credit and, potentially, greater product diversity, while, behind the scenes, Nubank starts to follow the same regulatory architecture as traditional banks.
Nubank Continues Without A Physical Branch And 100% Digital
A common question is whether, by becoming a bank, Nubank will have to open a physical branch. The answer is no. The Central Bank’s requirements are focused on capital, governance, risk, and transparency, not on the existence of branches.
This means that Nubank can continue operating 100% digital, without a single storefront, as long as it meets all prudential requirements.
The app remains the main relationship channel, the purple card continues to be the symbol of the brand, and customer service remains centralized in online channels.
For the customer, the Nubank user experience should not change suddenly in day-to-day use.
The big transformation occurs in the regulatory and accounting plan, with more obligations for Nubank and more layers of protection and clear rules around the customer relationship.
Febraban, Criticism And Dispute Over Taxes Of The Purple One
Nubank’s transition to a bank occurs amid a climate of tension with Febraban, the entity representing large banks.
In a post, Nubank’s CEO, David Vélez, stated that the purple one is a “champion of financial inclusion” and “champion of tax payers”, implying that the institution pays more taxes than the big banks and increases competition in the system.
Febraban reacted by stating that the publication is “totally biased” and that there are facts that need to be addressed.
In the statement, the entity highlighted that 97.7% of Nubank’s individual portfolio is in the most expensive lines of the market, with 64.8% in credit cards and 32.8% in unsecured personal credit, with zero exposure in real estate financing, vehicles, and agribusiness.
Febraban also stated that, despite Nubank having a higher return on equity (ROE), the ratio between due taxes and profit is the lowest compared to four large retail banks, which would create a significant competitive advantage.
Additionally, the entity pointed out high interest rates, elevated delinquency rates, and a strong impact on customers’ indebtedness for the purple one.
On another front, Febraban considered the Central Bank’s decision to protect the use of the word “bank” only for those who hold a banking license as “correct”, arguing that this reinforces the security, transparency, and credibility of the financial system and avoids ambiguities for the consumer.
Why Few Fintechs Should Follow The Path Of Nubank
According to Fernando Moreira, the Central Bank’s decision increases transparency for the consumer, but also raises the entry barrier for fintechs that want to transform into banks.
The specialist states that almost no fintech besides Nubank should chase a banking license in the short term, precisely because the banking model requires a heavy structure of governance, controls, auditing, and diligence. This changes the way of forming partnerships, structuring products, and managing risks, with significant fixed costs.
While many fintechs may prefer to adjust branding and discourse to distance themselves from the word “bank”, Nubank opts to embrace the label, trusting that the impact of more tax, more capital, and more oversight will be offset by more credibility, more competitiveness, and more clarity for the customer.
What Changes In Practice For Nubank Customers
For those already using the purple one in their daily lives, the immediate effect of the banking license will be more invisible than spectacular. The app remains the same, the card stays purple, and services continue concentrated on the mobile device.
What changes is that Nubank starts to operate as a fully regulated bank, with more obligations for capital, risk, reports, and transparency, in addition to having to comply with the package of free essential services and deal more intensely with compulsory collection.
On the other side, new types of credit, greater portfolio diversification, and potentially adjustments in fees and interest rates over time will open up.
In summary, Nubank becomes a real bank, pays more taxes, assumes stricter Central Bank rules, and remains 100% digital, without a physical branch, which could change the balance of power between fintechs and big banks and reshape the relationship of the purple one with millions of Brazilians.
And you, do you believe that Nubank becoming a bank will bring more advantages or more risks to your life as a purple customer?
sim mim ligaran do banco
Não!!!
Sou cliente da nubank desde que começou. Fiquei três anos com o mesmo limite no cartão de crédito,sendo que não estava negativada, mas sempre com fé que um dia eles aumentariam o meu limite. Quando eu comecei a saber usar o cartão,e como usar a conta, começaram a aumentar o meu limite. Hoje eu tenho um limite muito bom. Nunca tive problema com o BC.o melhor BC digital que existe.