SBS Resolution No. 1747-2026: Regulation for Banking as a Service (BaaS) Model

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000 Lima, July 1, 2026 SBS RESOLUTION No. 01747-2026

The Superintendent of Banks, Insurance, and Private Pension Fund Administrators CONSIDERING:
That, in accordance with the provisions of Article 87 of the Political Constitution of Peru, as well as Articles 347 and 349 of Law No. 26702, General Law of the Financial System and Insurance System and Organic Law of the Superintendence of Banks and Insurance, hereinafter the General Law, it corresponds to the Superintendence of Banks, Insurance, and AFP (SBS or Superintendence) to regulate and supervise the companies of the financial system, the insurance system, and others subject to its legal control, safeguarding the solidity, stability, and proper functioning of said systems, as well as the protection of the public's interests; That the aforementioned General Law establishes that companies authorized by the SBS may only carry out the operations and services expressly permitted, being liable to their clients and to the Superintendence for the activities they develop, even when for the execution of certain functions they use third parties; That, within the framework of the digital transformation of the financial system and the development of new business models based on the intensive use of digital technologies, the proliferation of the model known as Banking as a Service (BaaS) has been identified, through which companies of the financial system and others subject to the Superintendence's legal control, acting as BaaS service providers, provide financial services to their clients through legal entities that may or may not be supervised by the Superintendence, acting as BaaS service receivers; That, although said model may contribute to promoting innovation, competition, and financial inclusion, its implementation poses new operational, technological, market conduct, financial consumer protection risks, as well as money laundering and terrorist financing risks, which must be adequately managed by companies authorized by the Superintendence; That it is necessary to establish a specific regulatory framework that regulates the provision of financial services under the BaaS model, specifying the conditions under which companies of the financial system and others subject to the Superintendence's legal control may offer said services, the permitted services, the responsibilities of the intervening parties, as well as the minimum requirements for contracting, control, and transparency, ensuring at all times that liability towards clients and the Superintendence rests with the authorized company; That, in line with regulatory precedents issued by this Superintendence for models of intermediation and commercialization through third parties not authorized, it is pertinent to apply a regulatory approach based on the comprehensive responsibility of the supervised entity, without prejudice to the possibility of delegating the execution of certain operational functions to third parties, under clearly defined conditions and subject to control; That it is necessary to establish communication and inventory mechanisms with the Superintendence, as well as
public information obligations that allow adequate exercise of the supervisory function and guarantee transparency regarding the entities participating in the provision of services under the BaaS model; That, within the framework of the provision of financial services under the BaaS model, it is necessary to safeguard the adequate identification of the responsible service provider to the client, as well as to avoid schemes that may generate confusion regarding assumed responsibilities, transaction traceability, risk management, and supervision by the Superintendence; That, likewise, it is necessary to ensure that BaaS service receivers do not use trade names, expressions, formats, or communications that may mislead the public regarding their legal status, making them believe they carry out operations reserved for authorized entities or that they are under direct supervision of this Superintendence, if they are not; That, in exercise of the powers conferred by the General Law and with the object of safeguarding the public's interests, promoting the orderly development of the financial system, and guaranteeing the adequate management of risks associated with new models of financial service provision, it corresponds to approve the Regulation that regulates the provision of services under the BaaS model; That, for the purpose of collecting public opinions regarding the draft regulation, through SBS Resolution No. 1371-2026, the prepublication of the draft resolution was ordered on this Superintendence's electronic portal, under the provisions of the Thirty-Second Final and Complementary Provision of the General Law and Supreme Decree No. 009-2024-JUS and its modifying norms; With the approval of the Adjunct Superintendencies of Banking and Microfinance, Insurance, and Regulation and Legal Affairs, and of the Risk Management, Market Conduct, and Financial Inclusion Directorates, and the Open Finance Department; and, In use of the attributions conferred in numerals 7, 9, and 13 of Article 349 of the General Law; RESOLVES:
Article First.- Approve the Regulation for the Provision of Services under the Banking as a Service - BaaS Model, according to the following text:

Los Laureles No. 214 - Lima 27 - Peru Tel.: (511) 6309000

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