backThe Central Bank’s proposal for regulating the Banking as a Service (BaaS) model, introduced in Public Consultation No. 108/2024, has raised concerns within the financial sector. A study by the Brazilian BaaS Association (ABBaaS), in partnership with consultancy Distrito, warns that certain provisions — such as the prohibition of multitier contracting (i.e., obliging fintechs to select only one BaaS provider) — may encourage market concentration, hinder competition and innovation, and increase operational costs. Additional burdens identified include mandatory independent audits, periodic certifications, and public disclosure of BaaS providers’ client portfolios.
Moreover, limitations on sub-acquirers — key intermediaries that facilitate digital payments in underserved areas — could impair financial inclusion of small merchants. The sector acknowledges that formalizing BaaS regulation provides greater legal clarity and security, but emphasizes the importance of designing the rules to preserve innovation and avoid concentration in favor of large financial players.
share
