A recent operational event has brought a question back into focus that goes beyond system availability: the Brazilian market's ability to maintain its essential functions when critical infrastructure is temporarily offline.

This is a debate that deserves to be conducted in a technical, calm, and objective manner.

Critical infrastructures are extremely complex systems. Their operation depends on technology, processes, physical infrastructure, telecommunications, vendors, and, ultimately, people. All of this must function in a coordinated manner. Even with high standards of governance, continuous investment in technology, and rigorous regulatory requirements, no market is completely immune to adverse events. Operational disruptions have already occurred in some of the world's major financial infrastructures. Brazil, naturally, is not exempt from this reality.

It is precisely because this reality is recognized that the Principles for Financial Market Infrastructures (PFMI) have become one of the primary international benchmarks for managing risks in Financial Market Infrastructures. The PFMI are established under the CPMI (Committee on Payments and Market Infrastructures) and IOSCO (International Organization of Securities Commissions). These principles guide the identification, monitoring, and mitigation of risks, and establish requirements to limit the impact of adverse events and enable the timely recovery of critical services.

In Brazil, the Central Bank and the CVM, within their respective spheres of authority, establish requirements for governance, risk management, business continuity, technological redundancy, and operational recovery. These are high and necessary standards, consistent with the importance of these infrastructures to the functioning of the market.

However, the individual resilience of an infrastructure is not synonymous with market resilience.

Up to this point, the logic has been to make each infrastructure capable of resisting, responding to, and recovering from adverse events. But there is an additional question: what happens to the market during that interval? When a disruption occurs despite all controls, the issue is no longer just how long it will take for an infrastructure to recover, but how to preserve the functioning of the market while that happens.

When different critical functions are concentrated in the same operational structure or depend on common components, the effects of a disruption can reach different stages of the chain. Trading, clearing, registration, risk management, and settlement are distinct activities, yet they are operationally and economically interdependent. A localized event, therefore, can produce effects far beyond the system in which it originated.

The economic impact also spreads. Intermediaries stop executing part of their activities, investors temporarily lose the ability to implement strategies and manage positions, market makers stop providing liquidity, asset managers stop rebalancing portfolios, and service providers have their activities affected.

In other words, a localized disruption can affect a production chain much larger than the affected infrastructure itself.

It is at this point that a market composed of multiple infrastructures gains a dimension that goes beyond competition.

Even so, it would be simplistic to conclude that the existence of different environments automatically makes the market resilient. In the event of a disruption, it is not enough to simply redirect orders.

In organized markets, the execution of an order is just one step in a much more complex process. To trade, participants must be connected and authorized for the environment, with investors and accounts properly registered, in addition to risk controls prepared to support the activity. After execution, the trade enters the post-trade chain, where it must be submitted to and accepted by the central counterparty, incorporated into the management of positions and risk exposures, subjected to collateral management mechanisms, and subsequently settled with the transfer of financial resources and the delivery of the corresponding assets.

It is this entire chain that must be considered when thinking about a market with multiple infrastructures. Redirecting an order is just the starting point. Market resilience depends on the ability of activity to redistribute itself across different environments without compromising the continuity of trading, risk management, and settlement.

There is also an important distinction to be made. Multiple infrastructures do not exist solely for contingency situations. In competitive markets, they are part of daily operations, competing for order flow, offering services, and providing liquidity. It is this permanent utilization—rather than improvisation in the face of a crisis—that can create the conditions for activity to be redistributed more efficiently when an adverse event occurs.

This discussion does not allow for simplifications or a single answer. It involves market design, risk allocation, costs, economic incentives, and operational capacity. Therefore, any discussion regarding the evolution of this architecture must be built in a coordinated manner between regulators and participants, based on concrete scenarios and an objective assessment of risks, costs, and benefits. It is not about advocating for mandatory contingency mechanisms, but about recognizing that market continuity is a systemic issue and must be treated as such.

It is a structural discussion that requires time, coordination, and technical depth.

But it needs to start.

Over the decades, Brazil has built a sophisticated financial market, supported by a solid regulatory framework, technology, and robust infrastructures. The evolution of this framework has also created conditions for the entry of new infrastructures and for greater competition.

From this stage of development, there is an additional question that deserves to be placed at the center of the debate: the resilience of the Brazilian market architecture as a whole, rather than just that of each infrastructure in isolation.

Operational events will continue to be part of the reality of complex systems. The challenge is not to completely eliminate the possibility of these events, but to reduce the risk that a localized event turns into a widespread disruption capable of affecting a significant portion of the country's economic activity.

When an infrastructure stops, recovery time matters. But it also matters how much of Brazil can continue to function while it recovers.