> For the complete documentation index, see [llms.txt](https://www.opensourcelaw.com.br/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://www.opensourcelaw.com.br/en/regulation/3.-federal-revenue-service/3.2.-cosit-consultation-solution-no.-218-2023.md).

# 3.2. COSIT Consultation Solution No. 218/2023

Ancillary obligations for exchanges.

{% hint style="warning" %}
**OUTDATED.** This Consultation Solution was issued while Normative Instruction RFB No. 1,888/2019 was in force, revoked effective from 01/07/2026. The obligation to provide information now follows the [3.5. RFB Normative Instruction No. 2,291/2025 (DeCripto)](/en/regulation/3.-federal-revenue-service/3.5.-instrucao-normativa-rfb-no-2.291-2025-decripto.md). *Updated on 28/10/2026.*
{% endhint %}

This Consultation Solution demonstrates the Federal Revenue Service's understanding of digital platforms that enable their users to carry out peer-to-peer transactions involving utility tokens. According to the agency, such platforms fall within the definition of an exchange, and are therefore required to provide information about their own transactions and those of their users.

The information must be provided through the electronic system National Collection, available on the [Virtual Service Center (e-CAC)](https://cav.receita.fazenda.gov.br/eCAC/publico/login.aspx?sistema=10007) of the RFB. Once in the e-CAC Portal, select “Collection and Inspection”; then “Ancillary Obligation – Online Forms and Data File”.

{% hint style="warning" %}
A legal entity, even if non-financial, that only provides an environment for buying and selling transactions between its own customers is included in the concept of exchange.
{% endhint %}

Thus, the legal entity classified as an exchange must provide information both about cryptoasset transactions carried out directly by it (for example, the issuance of utility tokens) and about transactions carried out by its users through the environment made available by it, including peer-to-peer transactions carried out on its digital platform.

## Definitions:

* Utility tokens: are utility tokens, used to access specific services, such as online games, for example, characterized as a type of cryptoasset, according to the answer to the [question No. 457](/en/regulation/3.-federal-revenue-service/3.3.-questao-no-457-perguntas-e-respostas-irpf-2023.md) of the “IRPF 2023 Questions and Answers”.