Introduction

The Peruvian fintech ecosystem has experienced remarkable growth and regulatory evolution throughout 2025 and into early 2026. This period has been characterised by significant legislative developments, the modernisation of the payment system infrastructure, and the adoption of forward-thinking policies aimed at fostering innovation while ensuring financial stability and consumer protection. The Central Reserve Bank of Peru (BCRP) and the Superintendency of Banking, Insurance, and Pension Fund Managers (SBS) have emerged as key actors in shaping a regulatory environment that seeks to balance innovation with prudential oversight. Peru's fintech market continues to attract global attention as the country positions itself regionally as a key actor in payment services innovation.

According to data from OSIPTEL's Residential Survey of Telecommunications Services, as cited in the SBS's Open Finance Roadmap (published in February 2026), as of year-end 2024, nearly 92% of Peruvian households had access to mobile internet and smartphone penetration reached 95%, creating exceptionally favorable conditions for fintech adoption. Moreover, according to the SBS's Open Finance Roadmap, during the first half of 2025 alone, Peru registered 6.644 billion digital transactions – a 61% increase compared to the same period in the previous year – underscoring the accelerating transformation of the digital payments sector. This context undoubtedly demonstrates that Peru is well positioned to consolidate a more competitive, innovative, and inclusive financial ecosystem through the recent regulatory developments described below.

Modernisation of the National Payment System

One of the most significant regulatory milestones of 2025 was the issuance of Circular No 0022-2025-BCRP in December 2025, which approved the new General Regulation of the National Payment System (Reglamento General del Sistema Nacional de Pagos). This regulation represents a comprehensive overhaul of the payment system framework, adapting Peru's legal infrastructure to a rapidly evolving environment characterised by new payment instruments, digital channels, and the entry of new participants within the ecosystem.

The regulation was promulgated pursuant to Legislative Decree No 1665, which amended the Law on Payment and Securities Settlement Systems (Law No 29440), expanding the BCRP's regulatory and supervisory powers. Article 10° of the Payment Law attributes to the BCRP the authority to issue regulations, standards, mandates, and measures to ensure that the National Payment System operates securely, efficiently, interoperably, transparently, and in a manner that fosters competition and innovation.

Cross border provision of payment services remains largely unregulated from a financial regulatory perspective.

This new regulation represents a significant step forward in providing regulatory clarity for Payment Service Providers (PSPs), particularly for the newly recognised category of Payment Service Entities (Entidades de Servicios de Pago or ESPs). By establishing a defined authorisation and registration framework, the regulation creates a predictable pathway for fintech companies and non-banking entities seeking to participate in the National Payment System. However, this clarity comes with a corresponding regulatory burden: the detailed requirements for capital, documentation, risk management, and compliance will require market participants to carefully analyse and internalise the new rules. For entities currently operating in this space – or those seeking to enter it – the coming months will involve a period of regulatory digestion as they assess their obligations and adapt their operations to the new framework.

Introduction of ESPs

A central innovation introduced by the new regulation is the formal recognition and regulatory framework for ESPs. ESPs are defined as PSPs incorporated in Peru that are not authorised to offer deposit accounts or electronic money accounts by the competent authority. This new category creates a clear regulatory pathway for fintech companies and other non-banking entities seeking to participate in the National Payment System.

The regulation establishes, among others, specific capital and net worth requirements for ESPs. ESPs wishing to operate as direct or indirect participants in a payment system or prominent payment agreement must obtain prior authorisation from the BCRP. The authorisation process requires submission of comprehensive documentation, including corporate information, business plans, financial statements, organisational structure, risk management policies, and operational details. ESPs that do not participate in payment systems or prominent payment agreements are only required to complete a registration process with the BCRP.

Clarification of payment services and related concepts

The new regulation provides much-needed clarity on the scope of regulated payment services. Under Article 32°, the following are expressly recognised as payment services:

• execution of fund transfers;
• issuance of payment instruments;
• payment operation acquiring services;
• execution of cross-border transfers;
• fund collection services;
• fund disbursement services; and
• payment initiation, subject to future BCRP circulars.

Perhaps more importantly, the regulation also clarifies what does not constitute a payment service. Services linked to specific-use payment instruments – such as purchase cards, telephone cards, membership cards, public transportation cards, meal vouchers, and service vouchers – or those used in closed networks are excluded from the regulatory parameter. This distinction is particularly relevant for fintech companies developing closed-loop payment solutions or limited-purpose instruments, as it allows them to operate without triggering registration or authorisation requirements under the National Payment System framework.

Phased implementation timeline

The BCRP has established a phased implementation timeline for ESP authorisation, recognising the need for market participants to adapt to the new requirements. ESPs participating in payment systems or prominent payment agreements are required to submit their authorisation documentation according to a schedule (ending on 31 December 2026), based on their average monthly transaction values in 2025

The regulation permits ESPs to continue their operations while processing their authorisation or registration applications, provided they comply with the established deadlines. The BCRP may also establish adaptation periods for ESPs that do not initially meet all requirements, subject to submission and approval of an adaptation plan with defined milestones.

Cybersecurity and information security standards

The new General Regulation of the National Payment System incorporates provisions on cybersecurity and information security that are essential for payments operators.

The regulation expressly references the regulations applicable to the financial system regarding cybersecurity and information security risk management. These standards have traditionally applied to banks and SBS-supervised entities, but ESPs and other payment system participants must now comply with them as applicable. Market entrants will need to understand this highly technical regulatory framework and comply with its standards. This represents a significant challenge for fintech companies and non-banking entities that may lack prior experience with prudential supervision, requiring them to develop specialised capabilities and allocate resources to meet these compliance demands.

Additionally, the BCRP recommends that regulated entities align their operations with international security standards, including ISO 27001, ISO 27002, ISO 27032, and PCI-DSS for card payments.

Expansion of the Regulatory Sandbox

SBS opens sandbox to non-regulated fintechs

In November 2025, the SBS expanded the scope of Peru's regulatory sandbox through Resolution SBS No 04142-2025. This resolution modifies the Regulation for the Temporary Conduct of Activities in Novel Models (Reglamento para la Realización Temporal de Actividades en Modelos Novedosos), originally approved by Resolution SBS No 2429-2021. The fundamental innovation of this amendment is the extension of sandbox participation to non-supervised legal entities, that is, companies not currently under SBS supervision but proposing to develop innovative business models with potential application in the supervised financial systems.

This expansion aims to incentivise the participation of new actors in the financial innovation ecosystem, promote competition, and strengthen financial inclusion through solutions that may eventually be incorporated into the existing regulatory and operational framework following appropriate evaluation and validation. Under the modified regulation, “non-supervised companies” are defined as legal entities incorporated in Peru, or foreign legal entities with legal representation in the country, that are not within the SBS's supervisory scope but develop or propose to develop business models, products, or services with potential application in SBS-supervised systems.

The amended sandbox regulation establishes comprehensive procedures for non-supervised companies wishing to participate in pilot tests. Key features include:

• Duration: Pilot tests may last up to 18 months, with the possibility of a 12-month extension upon duly substantiated request, for a maximum total duration of 30 months.
• Authorisation Process: Non-supervised companies must submit comprehensive documentation, including corporate documentation, evidence of the moral suitability of directors and officers, demonstration of sufficient human, material, technological, and financial resources, detailed information about the proposed pilot, and a declaration to submit to the pilot's rules and SBS supervision.
• Consumer Protection: Each pilot test must incorporate consumer protection measures, and participating companies must implement risk management policies and anti-money laundering/counter-terrorism financing procedures.
• Exit Planning: Companies must present exit plans contemplating controlled wind-down procedures, including timelines, activity schedules, account closures, fund refunds, and payment of commitments to participants.

Furthermore, the SBS has empowered itself to directly convene or participate in pilot tests of innovative business models that respond to identified public interests. The SBS may issue open or direct invitations to supervised and non-supervised companies to participate in such pilots and may itself participate when such intervention contributes to fulfilling regulatory objectives. These pilots may include sharing public information or user data with prior consent, validating technical capabilities, security, or information exchange between systems, and exploring the use of emerging technologies. This active regulatory engagement represents a significant evolution in Peru's approach to fintech innovation.

While this expansion of the regulatory sandbox to represents a significant advancement in terms of financial innovation by providing a controlled space for conducting pilot tests of new activities, the considerable regulatory burden associated with authorisation requirements could disincentivise the participation and success of fintech companies, particularly those in early stages of development.

SMV's sandbox initiative

The capital markets regulator, the Superintendency of the Securities Market (Superintendencia del Mercado de Valoresor SMV), has also indicated its intention to explore sandbox mechanisms. In its Early Agenda 2026–2027 (Agenda Temprana 2026–2027), published in January 2026, the SMV identified the evaluation of a regulatory sandbox as a priority initiative.

The SMV recognises that financial innovation and the development of new business models linked to the securities market are advancing and generating challenges for traditional regulatory frameworks. Financial technology, process digitalisation, new investment vehicles, and alternative financing models present relevant opportunities but also regulatory risks that require careful assessment before broader adoption. The SMV's analysis will draw upon both local and international experience in sandbox implementation, with the aim of creating a tool for controlled and supervised evaluation of innovative models without compromising market stability or investor protection.

Central Bank Digital Currency Pilot

The BCRP has been actively advancing its exploration of central bank digital currency (CBDC) through the Digital Money Innovation Pilot (Piloto de Innovación con Dinero Digital). The new General Regulation of the National Payment System explicitly provides that entities participating in such pilots are governed by specific circulars and subscription agreements rather than the general regulatory framework, providing flexibility for experimental initiatives.

The pilot programme signals Peru's commitment to exploring digital currencies issued by the central bank as a complement to existing payment instruments. This initiative aligns with global trends as central banks worldwide examine the potential of CBDCs to enhance payment system efficiency, promote financial inclusion, and maintain monetary sovereignty in an increasingly digital economy.

Open Finance Roadmap: A Strategic Shift

The SBS's vision for open finance

In February 2026, the SBS published its Open Finance Roadmap (Hoja de Ruta Finanzas Abiertas), establishing a strategic framework for implementing an open finance system in Peru. The roadmap recognises that in the digital economy, data has consolidated as a strategic asset for the development of more efficient, innovative, and user-centered financial services.

Open finance is defined as a model that enables users to share their financial information – securely, in a standardised manner, and with their express consent – among different participants in the system, including financial companies, insurance companies, and pension fund managers. This approach expands upon the concept of open banking, placing the users at the center of the system by granting them control over the use and access of their data. The SBS's stated vision is to consolidate an inclusive, competitive, innovative, and secure financial system based on the responsible exchange of users' financial data, promoting user’s empowerment in the use and management of their financial information.

The objectives of Peru's open finance system include:

• fostering competition and innovation;
• promoting financial inclusion; and
• empowering users in the use and management of their data.

The SBS has defined a gradual implementation approach through four phases:

• Phase 1 (Diagnosis and baseline definition): This initial phase focuses on comprehensive analysis of the current regulatory framework, technological and operational capacity of entities, and market readiness for adopting a data-sharing model.
• Phase 2 (Development of regulatory framework and technical specifications): This phase centers on defining the regulatory framework, governance scheme, and technical specifications necessary for system operation, including elaboration of Banking as a Service (BaaS) regulation.
• Phase 3 (Gradual implementation of open banking): Beginning with adaptation to BaaS regulations, this phase focuses on developing capabilities for secure, consented information sharing. Implementation will follow a progressive approach, starting with entities with greater market participation. The first group of data is expected to be enabled by late 2027 and the second by mid-2028.
• Phase 4 (Consolidation of the Peruvian open finance model): This final phase marks the transition from open banking to a broader open finance scheme, progressively expanding both the universe of participants and the scope of data subject to exchange.

Implications for fintechs and non-regulated actors

The open finance framework explicitly recognises the fundamental role that third-party providers, including fintechs, play within an open finance system. However, the SBS acknowledges that these actors are not yet within its regulatory perimeter. During Phase 2, the SBS will evaluate the most appropriate mechanism to incorporate them in an orderly and gradual manner, ensuring they comply with required security and interoperability standards. This recognition represents a significant acknowledgment of the importance of collaboration between regulated financial institutions and innovative fintech players.

Market Entry and Cross-Border Services

Entry of new fintech actors

The Peruvian fintech market continues to attract significant interest from international PSPs and technology companies. The Open Finance Roadmap explicitly recognises that fintech companies represent a driving force for fostering innovation and providing users with greater control and value in the use of their information. This trend is evidenced by the increasing number of international payment platforms, cryptocurrency exchanges, digital wallets, and acquiring service providers that have explored or implemented payment services in the Peruvian market in recent years, reflecting the growing appeal of Peru's fintech ecosystem.

For international companies seeking to establish operations in Peru, a comprehensive regulatory analysis is essential to determine the appropriate corporate structure and licensing or registration requirements, if applicable. The process typically involves:

• evaluating the business model;
• assessing whether the entity requires authorisation or merely registration before a regulator in Peru; and
• ensuring compliance with the applicable regulatory framework, including consumer protection, data protection, and anti-money laundering requirements.

Ensuring regulatory compliance

For new fintech actors entering the Peruvian market, understanding the regulatory environment is essential, particularly as the sector is undergoing significant transformation without yet having a fully defined modular regulatory framework. Unlike jurisdictions with consolidated fintech-specific legislation, Peru's approach involves multiple regulatory bodies and overlapping frameworks that continue to evolve, including the new payment system regulations, sandbox mechanisms, open finance initiatives, and forthcoming developments.

In this dynamic context, companies must proactively evaluate the applicability of various regulatory regimes to their specific business models to mitigate compliance risks.

Key areas requiring assessment include:

• consumer protection regulations;
• personal data protection requirements;
• payment services regulations under the BCRP framework; and
• anti-money laundering and counter-terrorism financing (AML/CTF) obligations.

Cryptocurrency and stablecoins

The cryptocurrency and stablecoin market in Peru has experienced significant growth in recent years, driven by increasing consumer adoption and growing interest from participants. While the SBS has incorporated Virtual Asset Service Providers (VASPs) incorporated in Peru as obligated subjects under anti-money laundering and counter-terrorism regulations, broader aspects of the digital asset ecosystem remain without comprehensive regulation. As the market continues to gain ground and becomes more integrated, it is increasingly likely that Peruvian regulators will evaluate expanding the regulatory framework to address additional concerns such as investor protection and market integrity.

Financial Inclusion Impact

Peru's fintech regulatory developments are linked to the country's financial inclusion agenda. According to the SBS's Open Finance Roadmap (February 2026), despite significant advances – with the percentage of adults holding an account or digital wallet increasing from 41% to 67% between 2019 and 2024 – gaps remain in access to financial products. Only 33% of adults maintain credit in the financial system, and only 28% of MSMEs access formal credit, according to data from the Ministry of Production.

The rapid adoption of digital wallets further illustrates the potential for fintech-driven inclusion. Digital wallets have emerged as transformative instruments in Peru's financial ecosystem, fundamentally changing how consumers interact with financial services. The accessibility and ease of use of digital wallets have made them particularly attractive to segments that previously had limited engagement with formal financial services. Furthermore, digital wallets serve as a gateway to broader financial participation, as users who begin with simple transfers often progress to more sophisticated financial behaviours such as savings. The interoperability between digital wallets and other payment systems, facilitated by regulatory frameworks such as the new National Payment System regulations, enhances their utility and reinforces their role for financial inclusion.

The fintech market is well placed to help close these gaps. Digital payment solutions, mobile wallets, and alternative lending platforms can serve populations that don’t currently have access to traditional banks. The rapid growth in digital transactions shows that Peruvians are ready to adopt fintech-based financial services.

The convergence of fintech innovation with the modernisation of the National Payment System and the Open Finance Roadmap creates a powerful ecosystem for advancing financial inclusion. The new ESP framework enables non-bank actors – including fintech companies offering cross-border transfers, fund collection and disbursement services, and payment initiation – to formally participate in the payment ecosystem, fostering competition and reducing transaction costs for end users. Meanwhile, open finance's data-sharing model will enable fintechs to leverage transactional information from digital wallets and payment platforms for credit evaluation, for example, allowing creditworthiness assessments based on actual financial behavior rather than traditional requirements.

Conclusion

Peru's fintech regulatory landscape has undergone transformative changes in 2025 and early 2026. The new General Regulation of the National Payment System provides a comprehensive framework for PSPs, the expanded regulatory sandbox opens doors for fintech innovation, and the Open Finance Roadmap charts an ambitious path toward a more competitive and inclusive financial system.

Looking forward, market participants can expect continued regulatory development as the BCRP issues specific circulars on payment services, the SBS advances its Open Finance implementation with the first data exchange expected by late 2027, and the SMV potentially introduces its own sandbox mechanisms. The entry of new actors – both domestic and international – will likely accelerate, driven by clear regulatory pathways and Peru's favorable digital infrastructure. The coming years will be decisive in shaping the contours of Peru's open finance ecosystem and determining the opportunities available to fintech companies operating in this dynamic market.