The National Monetary Council (CMN) and the Central Bank of Brazil (BCB) amended Joint Resolution No. 1, of May 4, 2020 (Joint Resolution 1/20), the primary regulation governing the operation of Open Finance in Brazil. The changes were introduced by Joint Resolution No. 21, of October 22, 2026 (Joint Resolution 21/26).

The amendments seek to provide greater clarity and certainty to the data-sharing regime between Open Finance participants and non-participants. They also aim to reduce interpretative divergences and strengthen privacy, governance, and transparency related to the use of shared information within the ecosystem.

The main changes include: (i) the expansion of the use cases for the Non-Redirect Journey (JSR); (ii) improvements to the framework applicable to data aggregation and Open Finance data-sharing partnership agreements; and (iii) enhancements to the monitoring and control mechanisms that Open Finance participants must adopt.

Data Sharing via JSR

One of the most significant changes is the expansion of the scope of the JSR – now also referred to as the decoupled approval flow.

Previously, the JSR applied only to payment initiation services (PIS). Under the new wording, the regulation now also allows this dynamic for Open Finance data sharing.

As a result, participants may implement journeys in which the receiving institution requests data sharing within its own environment. The request is based on consent previously granted by the user for a specific purpose and still valid within the transmitting institution’s environment. There is no need for additional redirects between the institutions’ environments.

Although the matter still depends on regulation establishing how it will be operationalized, the measure appears to recognize the success of the JSR as an end-user experience and as a tool to encourage new Open Finance solutions.

Data Aggregation and Open Finance Partnerships

With the development of data aggregation activities, particularly within Open Finance, the market and BCB have paid closer attention to the data-sharing partnerships provided for in Article 36 of Joint Resolution 1/20.

In this context, the new regulation improved the rules on partnership agreements for sharing information obtained through Open Finance. The objective is to increase legal certainty and strengthen user protection.

Under the new wording, Article 36 regulates more comprehensively the partnerships between Open Finance participants and non-participant entities. The provision clarifies that “data derived from the processing, analysis, or modeling of data shared via Open Finance” are subject to the scope of these partnerships.

Accordingly, since October 22, 2026, institutions providing data aggregation services to third parties are expressly required to enter into Open Finance partnership agreements before sharing with third parties aggregated data produced from Open Finance – such as credit scores.

From a practical standpoint, however, the amendment directly affects business models based on the aggregation and processing of Open Finance data. Data aggregators and ecosystem participants will need to revisit their contractual, operational, and governance structures to adapt to the new regulation.

Next Steps

Institutions with existing agreements involving data sharing with third parties must inform the BCB, by December 1, 2026, of the partner entities with which they maintain such agreements. They must also provide information on the adaptation of those agreements to the new regulation, in accordance with the timetable and any additional technical requirements to be established by the BCB.

Machado Meyer monitors Open Finance regulation and is available to assist interested institutions in assessing the contractual, operational, and governance structures of their partnerships considering the new rules. Follow our publications on the Inteligência Jurídica portal and contact our team for more information.

Keywords: Open Finance; Central Bank of Brazil; CMN; Joint Resolution 21/26; Joint Resolution 1/20; non-redirect journey; JSR; data sharing; data aggregation; partnerships; financial regulation.

Meta description: Joint Resolution 21/26 extends the JSR to Open Finance data sharing and strengthens rules for partnerships and aggregators.