Real Estate Tokenization in Brazil: A Guide for Foreign Investors (2026)

Brazil has one of the largest real estate markets in the emerging world, and for decades it carried the same problem investors face everywhere: capital locked in illiquid assets, slow transactions, and access restricted to those who can commit large sums at once. Real estate tokenization emerged as a response — and in 2026, the Brazilian market took a decisive step toward institutional maturity.

In August 2025, Brazil's Federal Council of Real Estate Brokers (Cofeci) published Resolution 1,551, the country's first regulatory framework dedicated specifically to real estate tokenization. For US, European, and other foreign investors evaluating exposure to Brazilian real estate, understanding this framework is the starting point.

This guide explains how real estate tokenization works in Brazil, what Cofeci Resolution 1,551 created, the legal barrier that still remains, and how foreign investors can access the market.

What Real Estate Tokenization Is

Real estate tokenization is the process of representing rights tied to a property through digital tokens recorded on a blockchain. Those rights can be economic in nature — receiving rent, participating in a development's profits — or contractual, such as the right to purchase a future unit.

The token is not the property itself. It is a digital instrument that represents a right over it. This distinction is legally significant and has been at the center of Brazil's regulatory debate.

Blockchain serves as the registration infrastructure: each token has a unique identifier, is transferable between digital wallets, and carries — programmatically — the rules for income distribution, voting, and transfer defined in the smart contract that governs it.

Cofeci Resolution 1,551: The First Dedicated Framework

On August 14, 2025, the Federal Council of Real Estate Brokers published Cofeci Resolution 1,551, which took effect 60 days later and created a dedicated system for digital real estate transactions in Brazil.

The resolution established three new legal structures:

• TID (Digital Real Estate Token): the fractional digital representation of rights related to a property, recorded on a blockchain. Holding the TID gives the holder the legal standing to exercise the corresponding tokenized real estate rights.
• PITD (Real Estate Platform for Digital Transactions): the platforms responsible for issuing, distributing, trading, and custodying tokens. To operate legally, they must be accredited with the Cofeci-Creci System, demonstrating technical, financial, and governance capacity, including information security, anti-money-laundering, and data protection compliance.
• ACGI (Real Estate Custody and Guarantee Agent): the entity responsible for ensuring that tokens genuinely represent real rights over the underlying properties, potentially holding registry title or a real guarantee on behalf of TID holders.

A technical point that matters for foreign investors: Cofeci Resolution 1,551 explicitly does not apply to operations classified as securities (regulated by Brazil's securities commission, the CVM) or to virtual asset services (under Central Bank oversight). These three regulatory spheres are distinct, and correctly identifying which one a given operation falls under is decisive for compliance.

The Legal Barrier That Still Remains

The regulatory advance does not eliminate a structural limitation that Brazil's legal community has made explicit: the token, on its own, does not replace the property's registration at the real estate registry.

Although Cofeci Resolution 1,551 is an important milestone, it was issued by a council of real estate brokers, which has no legal authority over the public property registry. Property registration in Brazil falls under the registry offices (cartórios), governed by the Civil Code. The Brazilian Real Estate Registry Institute (IRIB) addressed exactly this point: the transfer of real estate ownership still depends on registration in the property's registry record.

For the foreign investor, this means a fundamental distinction: most real estate tokenization operations in Brazil represent economic rights over the property (income, profit participation) or a fraction of a legal vehicle that owns the property — not direct ownership of the asset. Well-structured operations make this distinction clear in their documentation. Tokens marketed as conferring full legal ownership without the corresponding registry record create expectations the structure cannot deliver.

What Can Be Tokenized in Brazil's Real Estate Market

The most common models in Brazil are:

They are also commonly tokenized:

• Commercial properties and logistics facilities: income-generating properties with long-term lease contracts, tokenized to let investors participate in returns without acquiring the asset outright. Functionally similar to a real estate investment fund, but with greater operational flexibility.
• Real estate credit: financial institutions and securitization firms structure real estate credit instruments in tokenized form, with blockchain settlement and automated income distribution.

Why Brazil Attracts Foreign Real Estate Capital

Brazil combines factors that make it attractive to international real estate investors:

• Market scale and depth. Brazil's real estate market is among the largest in the emerging world, with a diversity of asset classes few emerging markets offer.
• A consolidating regulatory framework. With Cofeci Resolution 1,551 and the CVM's oversight of operations classified as securities, Brazil now has more regulatory clarity for real estate tokenization than most emerging markets.
• Attractive yields. Brazil's interest rate environment means income-generating real estate instruments offer yields that are competitive against developed-market equivalents.
• Secondary market liquidity. Tokenization opens the possibility of trading real estate fractions on digital platforms — liquidity that traditional real estate investment does not offer.

How Foreign Investors Access the Market

Several structures allow a foreign investor to access Brazil's tokenized real estate market:

• Fractions via accredited PITD. Under Cofeci Resolution 1,551, accredited platforms can issue and trade TIDs. A properly identified and registered foreign investor can hold tokens.
• Real estate and receivables funds. Investing through regulated vehicles that hold tokenized real estate assets offers an entry point where the vehicle manages regulatory compliance.
• Cross-border structures. For larger investments, structures connecting the investor's home jurisdiction with the Brazilian operation require analysis of tax treaties and reciprocal KYC/AML compliance.

The key point: each structure carries specific regulatory requirements based on the investor's profile and jurisdiction of origin. Defining the right structure precedes any investment decision.

How Avalon Works

Avalon works with foreign investors, funds, and companies seeking access to Brazil's tokenized real estate market with legal certainty.

The work covers three areas:

Brazil is the only market we serve. That focus means we are reading every regulatory development — like Cofeci Resolution 1,551 — as it happens, and advising clients on the implications immediately.

Frequently Asked Questions