Structured Operation Certificates (COEs) have ceased to be a niche product and have gained space in the portfolios of Brazilian investors . In April, traditional retail and high-net-worth individuals together invested R$ 100.2 billion in this asset class, more than triple the volume recorded by Anbima in 2021 and 29% above all investments made by this category in equity funds. There are 710,000 accounts with positions in COEs, more than double the approximately 300,000 accounts that held this asset in their portfolios in 2021.
Despite the significant growth of the product in recent years, the latest data shows that this market is beginning to slow down. A survey conducted by NeoFeed , based on public data from B3, shows that the financial volume of COEs registered between January and May 2026 fell 21.4% compared to the same period last year, to R$ 14.2 billion.
Asset managers interviewed by NeoFeed say that the lower volume of issuances is related to a series of factors, ranging from changes in product suitability to negative campaigns on social media. But one of the turning points was the unexpected losses related to credit-based COEs (Certificates of Deposit). "Last year, we had the Ambipar event, which was the most dramatic COE event in Brazil," says Rodrigo Franchini of Monte Bravo.
In this type of structure, the investor accessed, through the COE (Certificate of Deposit), the credit risk of Ambipar's debt abroad, which offered a higher premium than the company's bonds in the local market. However, with Ambipar's filing for judicial reorganization , some investors realized that capital protection did not apply to those operations.
“Many people thought they had protected capital, but in credit COEs, the investor is buying credit risk. This has generated a breakdown in confidence in the product,” says Franchini.
The episode involving Ambipar occurred in conjunction with changes to the suitability rules for credit COEs (Certificates of Deposit). In May 2025, months before the Ambipar crisis worsened, Anbima published specific rules for the risk classification of these products. The higher the risk of the structure, the more restricted the audience to which the product can be recommended tends to be.
As a result, the platforms themselves have started to adopt stricter restrictions for product distribution, taking into account factors such as risk profile, age, structure's timeframe, and maximum percentage of exposure in the portfolio.
“If the client says they intend to invest 15% at once, the system literally won't allow it. There are also age restrictions, as it's a long-term product,” says a source interviewed by NeoFeed . “Before, you could have a client with 50% in COE. Today that would never happen. You need to have the right client, with aligned age, profile, and allocation percentage.”
The changes helped correct past excesses, after the product had been sold on an "almost industrial" scale and "with little alignment with the investor profile."
An alternative to fixed income.
The appeal of COEs (Certificates of Deposit) gained momentum starting in 2018 and 2019, in an environment of lower interest rates, when investors began to seek alternatives to traditional fixed income.
Many of the structures sold during that period were tied to the performance of international stock markets, commodities, currencies, or specific sectors, and had long terms that could reach seven years.
Some of these products offered protection of nominal capital at maturity, but the return depended on specific performance conditions of the underlying assets. In some cases, even when capital was preserved, the result fell short of what could have been captured in fixed-income products.
“You have a fixed income paying dearly, products yielding 7% or 8% per year plus IPCA (Brazilian inflation index) and a fixed rate of around 14%. All of this ends up redirecting capital away from these products. So, people started to understand that there is also a large carrying cost, as these are operations with longer maturity periods,” says Ronaldo Guimarães, partner and advisor at KAT Investimentos.
Part of the frustration stemmed from trades tied to assets that the client didn't fully understand or that didn't perform as expected. But that's not the only thing that helps explain the decline.
The increased adoption of the fixed- fee remuneration model in investment advisory firms has also impacted the COE (Certificate of Deposit) market. This product used to offer relatively high commissions to distributors, which increased the commercial incentive for its sale.
With the rise of fixed fees , this logic changes: the commission ceases to be the main incentive for the advisor and can be converted into better conditions for the client, either through a larger bonus in the structure or cashback .
“All the premium that would be for distribution, for the cost of the product, goes into the product. So, it really has to make a lot of sense for the customer,” says Franchini, from Monte Bravo.
Market maturation
This combination of factors has resulted in a more selective offering that better aligns with the client's profile. This trend is reflected in the data collected by NeoFeed itself. Although the financial volume of registered COEs fell by 21.4% from January to May, the number of contracts grew by 8.2% in the same period, from 80,280 to 86,837.
The result was a reduction in the average transaction value. In the first five months of 2025, each registered contract was equivalent, on average, to approximately R$ 225,000. In the same period this year, the value fell to approximately R$ 164,000.
“The market is being more selective and allocating less. Today, I see it as a more mature product,” says Franchini. “Every product needs a natural evolution from its inception. Sometimes this evolution is traumatic, but I think it's on that path.”
Data by segment shows that the slowdown is strongest precisely in the income brackets where COEs (Certificates of Deposit) gained scale in recent years. In the high-income segment, which concentrates the largest share of the product's stock, growth has slowed significantly. Between December and April of this year, the stock in this segment increased by R$ 3.7 billion, compared to R$ 8.6 billion in the same period of 2025.
In traditional retail, the market has remained virtually stable since the beginning of 2025. Inventory, which was R$ 12.8 billion in December 2024, stood at R$ 13.7 billion in April of this year.
Private banking, on the other hand, maintained the same nominal growth rate, with an increase of R$ 1.2 billion in the stock of investments in COEs (Certificates of Deposit) in the first four months of 2025 and 2026. In 2026, however, private banking accounted for 22% of the total growth in COE stocks, compared to 13% in the same period of 2025.
