Three scenarios employing national ABS regimes to regulate DSI use and description bilaterally are assessed against a set of desirable characteristics of an ABS system (based on Sirakaya 2020). The advantages and disadvantages of each scenario are analyzed from the perspectives of providers, users, and databanks, delineating potential limits of bilateral DSI regulation. Scenario 1 assumes that there is no ABS regulation in place in the country of origin of the genetic resource (GR) from which the DSI was described. All terms and conditions, rights and duties are negotiated case-by-case using private contract law. In Scenario 2, established ABS legislation in the country of origin requires PIC and MAT for the description, deposit and use of DSI, and prescribes third-party users’ obligations. Countries that are Party to the Nagoya Protocol are obliged to monitor and enforce users’ compliance with providers’ legislation. Scenario 3 provides open access to GR and DSI, under terms and conditions. This regime aims to control results rather than processes. No PIC is required for access to GR, or for the description, deposit and use of DSI. Instead, the outcomes of R&D (e.g. a publication, an IPR, or a product) have to be reported in an ABS online registration system in the country of origin of the resource. Monetary benefit sharing obligations arise only when a final product from DSI use is being commercialized. The current Brazilian ABS system is akin to scenario 3.