- Nu Holdings (Nubank) plans to apply for a full Brazilian banking license by 2026 to comply with Joint Resolution No. 17 restricting use of “bank” branding by non-banks.
- Nubank says its app experience and day-to-day operations should stay largely unchanged because it already holds key payments, credit, and brokerage licenses.
- A full license could deepen deposit access, expand product scope, and reduce branding/regulatory risk, but it also brings heavier compliance and potentially higher taxes and capital requirements.
- Markets have viewed the move favorably alongside strong Q3 2025 growth and higher analyst targets, though macro, valuation, and regulatory-execution risks remain.
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The announcement that Nubank will seek a full banking license in Brazil in 2026 marks a regulatory inflection point, repositioning its investment narrative from fintech disrupter to a licensed bank adapting to formal banking regulation. Under Brazil’s Joint Resolution No. 17, non-bank entities using the term “bank” must hold a full banking license. Nubank, which currently operates under various permits (payments, credit, securities brokerage), lacks that dashboard-license but must align its brand identity legally.,, This move accelerates regulatory alignment, reducing brand risk and clearing latent exposure to regulatory penalties or forced rebranding.
From an operational-financial angle, Nubank emphasizes that obtaining the license will not materially change capital or liquidity requirements or disrupt daily operations., Nonetheless, converting into a fully licensed bank will likely require enhancing risk governance and compliance, impacting cost structures. The larger asset-liability profile may increase regulatory buffers, potentially widen risk‐weighted assets and require adjustments in net interest margin (NIM), particularly if deposit funding is priced differently. Tax burdens may increase—as bank status usually attracts higher rates for societal contributions and mandatory services. Local commentary points to higher CSLL (social contribution on net income), more rigid PIS/COFINS regimes, and essential services obligations, which could reduce margins if not properly managed.
Strategically, the banking license opens opportunities. First, accepting deposits becomes explicit rather than mediated via non-bank entities; this improves funding mix, lowers cost of funding relative to wholesale or other liabilities. Second, full license allows expanded product offerings (e.g. savings, checking, mortgages, regulated deposits), increasing cross-sell and customer lifetime value. Third, by normalizing its status among banks, Nubank may avoid competitive disadvantages versus incumbents in regulatory perception. This could help in Brazil and improve credibility in its expansion to Mexico, Colombia, or via the US charter.,
On valuation, the market is treating the pivot as additive rather than disruptive. Nubank delivered ~39 % year-over-year revenue and net income growth in Q3 2025, reaching ~US$4.2 billion in revenue and US$783 million net income. Analyst price targets have moved upward, e.g. Santander targeting US$22, suggesting a 25-30% uplift from recent trading levels. However, risks remain: macroeconomic instability in Brazil (inflation, interest rates), foreign exchange volatility, margin compression if regulated banking liabilities yield constraints, and the operational drag of full banking regulation.
Open questions include: Exactly how much additional capital reserves will be required under Brazilian banking regulations? What will the funding cost differential be between Nubank’s current funding sources versus deposit funding? How will tax changes affect net profit margins once Nubank transitions to full bank status? What regulatory oversight and reporting obligations will be imposed, and at what cost? The timing and pace of adopting the license—by what quarter in 2026, whether via acquisition or in-house build—are also material.
Supporting Notes
- Nubank plans to obtain a banking license in Brazil by 2026, per its December 3, 2025 announcement, to comply with Brazil’s Joint Resolution No. 17, which standardizes brand usage among financial institutions.,,
- The company claims its brand identity, visual branding, customer experience, and existing operational licenses (payment, credit, securities brokerage etc.) will remain unchanged.,,
- Nu reports it has more than 110 million customers in Brazil and has helped bring 28 million individuals into the financial system since its founding 12 years ago.,
- Strong financial performance in Q3 2025: ~US$4.2 billion revenue, ~US$783 million net income (~39 % YoY growth), and ~127 million customers globally with ~4.3 million net new customers in the quarter.,,
- Analyst price targets have been raised post announcement: e.g. Banco Santander set a US$22 target for NU, implying ~26 % upside from recent trading levels.,
- Estimated tax impacts: becoming a licensed bank exposes Nubank to higher rates for Social Contribution on Net Income (CSLL), more stringent PIS/COFINS (tax on turnover), and mandatory essential banking services free of fees.