Nu Holdings filed its FY2025 Form 20-F on April 8, 2026 — its annual report equivalent for foreign private issuers. The filing validates the Q4 and full-year 2025 figures already published February 25: $16.3B managerial revenue (+37% FX-neutral), $2.87B net income (+45%), 131M customers, 33% Q4 ROE (all-time high), and 19.9% exit-quarter efficiency ratio. The 20-F is primarily a confirming document — it validates rather than re-prices the thesis. The single directional surprise: Mexico banking license progression. The filing states CNBV approved Nu's conversion from Sofipo to full bank in April 2025, systems and processes testing completed in December 2025, and final Operation Authorization is expected “in the following months.” Six of seven forecast markets moved bullish on the update.
What the 20-F Confirms
IFRS accounting revenue was $15,774.7mm; managerial adds $544.8mm in reclassifications and tax-equivalency adjustments (net-income neutral). Credit income $9.5B (+38%), Float income $4.5B (+55% on high Selic and deposit growth), Fee income $2.3B (+23%). Q4'25 alone delivered $4.86B revenue. Net income identical under both IFRS and managerial frameworks.
Brazil 113M (62% of adult population, 86% activity rate). Mexico 14M (15% adult population, leading new credit card issuer per CNBV). Colombia 4M+ with subscription credit card nearly tripling approval rates. The strongest single moat datum: per BCB data, Brazilian customer growth in 2025 outpaced the five largest incumbent banks combined. Net churn 0.1%/month (down from 0.2% in 2024) — elite for retail banking globally.
Q4'25 efficiency ratio declined to 19.9% from Q3's 20.3%. Revenue grew +37% FX-neutral while operating expenses grew only +9% YoY — textbook operating leverage. Cost to serve per active customer held at $0.8/month, unchanged from 2023 and 2024. This is the exit-quarter read before the 2026 investment-year spend begins materializing. Incumbent Brazilian peers remain in the 40-50% efficiency range.
Consolidated 15-90 NPL at 4.1% (-20bps QoQ, leading indicator). Consolidated 90+ NPL at 6.6% (-10bps QoQ, lagging indicator). Both declined sequentially into year-end despite $32.7B credit portfolio expanding 40% YoY. Management flagged a typical seasonal Q1 uptick in 15-90 NPL. The $29B unused credit limits (AI-decisioned via nuFormer) persist as a monitoring concern — untested through a full EM downturn cycle.
Total deposits +29% FX-neutral. Cost of funding 87% of interbank rates (weighted), 81% in Brazil. Interest-earning portfolio $18.5B (+47% FX-neutral). Available funding of $38.8B = 2x net credit portfolio. $3B unrestricted cash at the Holdings level. Risk- adjusted NIM 10.5% in Q4'25. Deposit stickiness is widening, not narrowing — despite rate moves across jurisdictions.
The Material Move: Mexico License Is Months Away
The single directional signal from the 20-F that was not already in the record is Mexico banking license progression. The filing provides a three-step timeline that markets had not fully priced:
Regulatory authorization to begin the Sofipo-to-full-bank conversion process. Prior to this, Nu Mexico operated under the Popular Savings and Credit Law (LACP).
Operational readiness milestone. This is the step where implementations typically stall — Nu cleared it on schedule.
The 20-F's own language. Not a committed timeline from the regulator, but the strongest directional statement Nu has been willing to make about Mexico. Our ensemble moved the Mexico banking license market from 52% to 78%.
Signal Deltas: 10 Signals, 0 Labels Change
All ten signals hold their prior labels. The 20-F is a confirming document, not a re-classification event. Evidence strengthens for several; no evidence deteriorates. The following four signals received supporting data points:
Brazil customer growth outpacing the five largest incumbents combined is the strongest moat datum in the record. Net churn at 0.1%/month confirms switching-cost moat. 100+ new products launched in 2025 (Nubank+ tier, NuTravel, NuCel, Ultravioleta metal card, under-18 credit card, private payroll loans). “Country- agnostic, reusable infrastructure” language in the 2026 strategy adds credibility to the horizontal-platform investment thesis.
Aggregate ELEVATED holds — five-jurisdiction complexity persists (BCB, CNBV, SFC, OCC/FDIC/Fed, Cayman CIMA). Within the aggregate: Mexico vector moves materially lower on the Operation Authorization timeline; US OCC vector neutral (2026 is “operational groundwork”); Brazil fintech tax (40% → 45%) in effect as expected; no new fiscal shocks. No new material risk factors disclosed in the 20-F.
FY ARPAC $13.3 / Q4 exit $15, +27% FX-neutral. Cost to serve $0.8/month (flat). ARPAC-to-cost ratio widening. 33% Q4 ROE all- time high. Float income's rate sensitivity is the one caveat: ~28% of revenue depends on Selic elevation. Through-cycle ROE likely 25-30% once rates normalize — still peer-leading.
Three concerns persist. (1) Managerial P&L framework continues with KPMG limited assurance (not reasonable assurance) — full IFRS reconciliation is provided but the dual-framework complexity remains. (2) Brazil-only NPL series permanently dropped — only consolidated 90+/15-90 figures reported, without a quantified bridge to pre-2025 Brazil- only reporting. (3) $29B unused credit limits receive no new quantified stress-scenario disclosure. These are monitoring needs, not proven problems.
Forecast Update (0 Resolved, 7 Refreshed)
No markets resolved — all seven have resolution dates in Q2 2026 or later, and FY2025 data cannot resolve forward-looking quarterly or full-year 2026 markets. All seven received updated probabilities based on 20-F evidence. Six moved bullish; one (OCC charter) moved modestly bearish on timing realism.
| Market | Before | After | Shift |
|---|---|---|---|
| Mexico banking license by end-2026? | 52% | 78% | +26pp |
| Q2'26 consolidated 90+ NPL > 8%? | 16% | 13% | −3pp |
| FY2026 efficiency stays < 25%? | 79% | 83% | +4pp |
| Q1 2026 revenue > $5B? | 57% | 62% | +5pp |
| Q2'26 ARPAC growth > 15% YoY? | 78% | 84% | +6pp |
| OCC charter satisfied + US bank open by mid-2027? | 62% | 58% | −4pp |
| H1 2026 customer adds ≥ 5M? | 82% | 86% | +4pp |
The +26 point Mexico shift is the largest single move in an NU forecast market in the history of our coverage. The OCC charter move is directionally negative but small — the 20-F's “operational groundwork” framing for 2026 tightens the path to a mid-2027 opening, but does not deteriorate the conditional- approval status. The Q1 revenue move from 57% to 62% reflects Q4's $4.86B base plus 100+ product launches and a 4M Q4 customer add, offset partly by BRL depreciation risk and seasonal Q1 softness.
What's Next
Management explicitly flagged a typical Q1 seasonal uptick in the 15-90 NPL ratio. A benign Q1 print within the normal range would be the strongest evidence to date that the AI-driven credit decisioning is durable. A sharp Q1 NPL spike would be the first real test of the $29B unused-limits concern — and would likely compress the multiple materially.
The 20-F expects this “in the following months.” If granted within Q2 or Q3, the Mexico banking market likely resolves YES well ahead of the December 31 deadline. Elevated watch priority for CNBV announcements.
Q4'25 exit at 19.9% gives 500+ bps cushion to the 25% market threshold. The 2026 investment year is expected to add RTO, AI, and US expansion spend. Holding the sub-25% line through Q1-Q4 is the test of whether the structural cost advantage is genuinely structural.
Float income (+55% YoY, ~28% of revenue) is rate-sensitive. No BCB pivot signals in the 20-F. A rate-cut cycle would compress this revenue line materially and stress-test the through-cycle ROE.
See the full NU analysis for the 8-lens committee detail, and the NU forecasts page for all seven active markets with refreshed probabilities.