On October 30, 2024, the Central Bank of Brazil (BCB) launched a public consultation regarding the regulation of Banking as a Service (BaaS), aiming to organize and standardize this innovative business model within the Brazilian financial sector. In a context of growing interest in integrated financial services on digital platforms, this consultation represents a strategic step for foreign players potentially interested in entering the Brazilian market. The proposed regulation includes rules for financial and payment institutions to offer their services through partnerships with companies in other sectors, such as technology, retail, or services, thereby expanding consumers’ access to financial products in a secure and practical manner.
For investors and global companies, this regulation provides a clearer and more reliable framework for BaaS operations in Brazil. Among the highlights, the proposal includes strict requirements for transparency and governance, such as complete identification of ultimate beneficiaries and the implementation of robust mechanisms for quality control and risk management. These requirements aim to ensure that operations adhere to international compliance standards, preventing fraud and money laundering. This regulated environment offers security and stability, allowing foreign companies to establish local partnerships and expand their BaaS operations with confidence that Brazilian regulations are strong and aligned with global practices.
Furthermore, the scope of services authorized under the proposed regulation may attract interest from international companies specializing in specific niches, such as post-paid payment accounts, payment processing, or international remittances (eFX). The Brazilian proposal emphasizes the importance of specialization and encourages different institutions to provide distinct services, creating opportunities for global players to bring their expertise to the Brazilian market and address specific demands.
The public consultation, open for contributions until January 31, 2025, also allows foreign companies to participate directly in the regulatory process, suggesting adjustments that may benefit both the local market and international operations. This involvement offers companies a strategic view of future operational and partnership opportunities in Brazil.
This regulation, therefore, reflects Brazil’s commitment to promoting a more competitive and secure business environment for foreign investors in the financial sector. For those interested in exploring BaaS opportunities in Brazil, the BCB’s public consultation is a positive indication that the market is evolving with clarity and legal security, creating favorable conditions for new business ventures in the country.
Banking Law Practice of Franco Advogados
