The platform can run the secondary market
CVM Resolution 88 lets a crowdfunding platform organise a secondary market for the securities it issued. Investors can trade with each other inside the platform instead of waiting for an exit.
Issue tokenized real estate in Brazil on your own platform
Brazil is the rare market where the rules already let a platform run its own secondary market. That is the hardest part of tokenization to get right, and here it is written into the regime. What it does not hand you is a branded platform. That’s where we come in.
Brazil already allows what most markets do not
Liquidity is the thing investors ask about and what most tokenized offerings cannot deliver easily. Brazilian rules make room for it.
That freedom has a hard edge
The secondary market has to stay inside the CVM publicity restrictions and trading limits. Cross the line and you are running an unauthorised exchange, which is a different problem entirely.
The rules are being widened right now
The CVM put a full revision of Resolution 88 on its 2026 regulatory agenda, covering raise limits, new issuers and the tokenization agenda itself. Anything you plan should assume the ground will move.
How to start
1. Tell us about the property
What you own and what you want to raise. We say plainly whether this fits, including when it does not.
2. A Brazilian lawyer joins
Our local partner sets the route: a crowdfunding offering under Resolution 88, a real estate fund, or a receivables structure. Each carries different limits on who you can raise from and how much.
The legal work and the launch run in parallel. In Brazil the pace is set by the structure your lawyer chooses and, for a crowdfunding offering, by the platform requirements under Resolution 88. Your lawyer starts that on day one.
Before you tokenize real estate in Brazil
Is real estate tokenization legal in Brazil?
What matters is the instrument. If the token carries rights of a security, the CVM rules apply, and Resolution 88 is the route most small and mid-sized raises take. The CVM has tokenization on its 2026 agenda for public consultation.
What are the limits on that secondary market?
It has to operate inside the CVM publicity restrictions and trading limits. The line to stay behind is the one that would make it an unauthorised stock exchange, and your lawyer will draw it for your case.
Can investors sell before the project ends?
Under Resolution 88 a platform may organise a secondary market for the securities it issued, so investors can trade with each other inside the platform. This is the part most tokenized offerings elsewhere cannot offer.
Are the rules about to change?
Yes. The CVM placed a full revision of Resolution 88 on its 2026 regulatory agenda, including raise limits, new categories of issuer and the tokenization agenda. Plan on the ground moving in a positive direction.
Last updated: 10-08-2026
The information on this page is for general informational purposes only and does not constitute legal, financial, investment, or tax advice.
Tokenizer.Estate provides a platform for real estate tokenization and connects you with licensed local partners, but we do not provide legal or regulatory guidance.
Please consult qualified professionals in your jurisdiction before making any investment or tokenization decisions.
Sources & References
- Resolução CVM 88, crowdfunding de investimento
- CVM. Agenda Regulatória 2026
- Resolução CVM 175, fundos de investimento, incluindo FII