title: Chile Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/chile/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # Chile CL schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 56 sourced findings · 193 sources in the cumulative register 14 Modules baseline.modules[] 56 Findings modules[].findings[] 121 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ## Jurisdiction brief ###### Latest update · 18 October 2026 #### Lead Signal Chile's stablecoin and digital-money regulatory gap remains open. Under Ley 21.521, articles 30 and 31, the Banco Central de Chile has the statutory power to issue a general rule setting standards for DLT-based, fiat-backed payment-value representations, and as of 13 October 2026 it has not done so. In the meantime, the Comision para el Mercado Financiero continues to apply its Official Letter 101082 of 12 June 2026, which treats crypto-assets, including fiat-referenced tokens, as financial instruments requiring CMF registration and authorisation. This leaves the payments treatment of stablecoins in Chile resting on a general financial-instrument classification rather than on a purpose-built payments-system standard, even though the BCCh, as the payments-system regulator, is the body with the statutory mandate to set that standard. #### Other Developments Separately from the stablecoin question, the CMF has continued its incremental regulatory activity this period. On 16 October 2026 it opened a public consultation on a new methodology for risk-weighted assets and own funds applicable to Cooperativas de Ahorro y Credito, the credit-union sector it supervises. The same week, on 16 October 2026, CMF also launched the first round of consultative roundtables, or mesas consultivas, on the roadmap and governance of Chile's Open Finance System. Neither development changes the market-access or licensing position for payment institutions directly, but both indicate CMF is actively working through its open-finance and prudential agenda in parallel with the unresolved stablecoin question. #### Cross-Monitor Connections The same BCCh non-issuance finding addressed here is also being tracked by the crypto monitor as a token-classification and stablecoin-regime question for this jurisdiction. Readers following the crypto-asset classification consequences of this same regulatory gap, rather than its payments-infrastructure consequences, should treat that monitor's coverage as the complementary view of the identical underlying fact. #### Outlook The single clearest forward marker for this jurisdiction's stablecoin and digital-money treatment is whether and when the BCCh exercises its Ley 21.521 article 30-31 power. No published target date for that rule has been located. Until it is issued, CMF's financial-instrument classification will remain the operative test for fiat-referenced tokens used in payments contexts in Chile. _6 earlier updates not shown here._ ###### Standing brief · as of 29 June 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Chile's payments operating environment is undergoing its most material reset in two decades, with the most consequential near-term shift sitting in scheme economics. An April decision capped interchange at 0.8% for credit and 0.35% for debit, effective October, expected to cut credit and debit interchange by roughly 46% and 42% respectively. This is not an isolated price intervention. It sits atop the competition court's ICG No.5 ruling, in which the TDLC recognised Visa and Mastercard's dominant position and ordered public disclosure of interchange fees, removal of acquirer-licensing restrictions, no mandatory joint acceptance, and a temporary surcharging allowance pending interchange fees meeting the merchant-indifference 'tourist test'. Layered onto this, CMF NCG 541 (published 23 July 2025, in force) amended non-bank card issuance and operation rules, created the 'Sub-Acquiring Operator' figure for entities settling 0.5%-1% of total payments, and strengthened contract, interoperability and oversight standards. Taken together, the interchange caps, NCG 541 sub-acquiring registration, and the TDLC scheme-conduct remedies compress acquirer and issuer margins and lower entry barriers in a market that is already opening structurally. The scale of that structural opening is visible in the acquiring layer. The acquiring market has moved from a Transbank near-monopoly — around 98% in 2021, around 80% by end-2022, and projected below 70% — to a multi-acquirer model from 2020, with six acquirers operating, three more awaiting approval and around 20 PSPs competing. The economic compression now arriving through the interchange caps lands on a market that has already lost its single-operator architecture, intensifying competitive pressure on incumbents. #### Other Developments The settlement layer is opening in parallel. Under Ley 21.641 the BCCh opened a public consultation in November 2025 to regulate conditions for CMF-supervised credit cooperatives, securities custodians, low-value clearing houses and their non-bank participants, and recognised foreign CCPs to open BCCh accounts and pay directly via the LBTR; access is currently limited to banks, local CCPs and securities settlement systems, with differentiated timelines (12 months for high-value clearing houses) and no settlement guarantee. Direct RTGS access for non-bank financial entities reduces dependency on bank-only settlement intermediation and is the clearest near-term infrastructure shift in the jurisdiction. In the licensing perimeter, Chile operates a deliberately dual-track non-bank regime. Law 21.521 (published 4 Jan 2023, effective 3 Feb 2023) brought seven Title II financial-technology services into the CMF perimeter, requiring registration in the Registro de Prestadores de Servicios Financieros and, for several activities, prior CMF authorisation, while Ley 20.950 (2016) authorises non-bank entities to issue and operate stored-value payment means through Chilean sociedades anónimas with exclusive corporate purpose. There is no unitary EMI licence. NCG 559 (issued 9 Feb 2026, in force on that date) inserted Chapter X into NCG 502, establishing a prior-notice duty for traditional CMF-supervised providers offering Fintech Law services without separate registration, with a transitional reporting deadline of 30 April 2026 for entities already providing such services. In open finance, CMF NCG 514 (3 July 2024) governs the Open Finance System under Title III, defining mandatory Information Provider and Account Provider Institutions and voluntary Information-Based Service Providers and Payment Initiation Service Providers; CMF NCG 569 (issued June 2026) postponed SFA entry into force to July 2027, extending the implementation period from 24 to 36 months. On the commercial side, Chilean paytech Klap was acquired by Itaú Chile for US$43.7M (reported 16 Dec 2025) to strengthen its payments ecosystem, and Chilean recurring-payments fintech Toku secured a US$48M Series A led by Oak HC/FT (reported May 2025). #### Cross-Monitor Connections The AML/CFT surface for Chile is carried from the Sentinel feed and is not re-analysed here. Ley 19.913 (in force 17 May 2004) created the UAF, Chile's FIU receiving suspicious-transaction reports; obliged informing entities include CMF Registry registrants and PISPs, with KYC/CDD required for occasional transactions at or above USD 3,000, and Chile is a GAFILAT member following the FATF risk-based approach and is not on the FATF strategic-deficiency list. Any original illicit-finance analysis, including the sanctions-evasion or de-risking significance of stablecoin treatment, routes to FIM. Under the Fintech Law, stablecoins pegged to currencies are treated as a payment method falling under BCCh regulation provided they are issued in Chile by CMF-supervised entities — a local-issuance requirement that creates difficulty regulating dominant global stablecoins such as USDC, and which carries an illicit-finance dimension referred to FIM rather than concluded here. #### Outlook Forward regulatory friction is concentrated in 2026-2027. The 30 April 2026 NCG 559 prior-notice deadline is the nearest operative trigger for traditional supervised providers. The October interchange caps then reset card economics, and the Open Finance postponement to July 2027 via NCG 569 shifts go-to-market timelines for non-bank PISP entrants. The BCCh's LBTR non-bank access regime is expected to finalise across the second half of 2026, completing a settlement-access opening that, alongside the scheme reset, defines the operative timeline for any non-bank payments operator entering Chile. trust tier: ai_unverified ###### Latest update · 18 October 2026 #### Regulatory Status Chile's payments-relevant stablecoin treatment rests on an unexercised statutory power. Ley 21.521, articles 30 and 31, authorises the Banco Central de Chile to issue a general rule for DLT-based, fiat-backed payment-value representations, but as of 13 October 2026 the BCCh had not done so. The Comision para el Mercado Financiero's Official Letter 101082 of 12 June 2026 fills the gap in practice, treating crypto-assets, including fiat-referenced tokens, as financial instruments requiring CMF registration and authorisation. Separately, CMF opened a public consultation on 16 October 2026 on risk-weighted-asset methodology for credit unions, and launched its first Open Finance System consultative-roundtable round the same day, both part of its ongoing prudential and open-finance agenda rather than a change to payment-institution market access. #### Outlook Watch for the BCCh's exercise of its Ley 21.521 rule-making power as the clearest forward marker for how stablecoins are treated in Chile's payments system; until then, CMF's general financial-instrument classification remains the operative framework. _2 earlier updates not shown here._ ###### Standing brief · as of 29 June 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Chile's payments regulatory environment is in active reform across licensing, scheme economics and settlement access, with the regulatory direction tightening across multiple modules simultaneously. The jurisdiction operates a deliberately dual-track non-bank payments regime: Law 21.521 (published 4 Jan 2023, effective 3 Feb 2023) brought seven Title II financial-technology services into the CMF perimeter requiring registration in the Registro de Prestadores de Servicios Financieros, while Ley 20.950 (2016) authorises non-bank entities to issue and operate stored-value payment means through Chilean sociedades anónimas with exclusive corporate purpose. There is no unitary EMI licence, and non-bank customer-fund protection rests on statutory segregation — under Ley 20.950 prepaid funds are held segregated, used only for payments and refunds, and are non-attachable for the issuer's other debts — rather than on deposit insurance. NCG 559 (issued 9 Feb 2026) added a prior-notice duty for traditional CMF-supervised providers offering Fintech Law services, with a transitional reporting deadline of 30 April 2026. The card market is undergoing its most material economic reset in two decades. An April decision capped interchange at 0.8% for credit and 0.35% for debit, effective October, expected to cut interchange by roughly 46% and 42% respectively, layered on the TDLC's ICG No.5 scheme-conduct remedies against Visa and Mastercard's dominant position, and the NCG 541 Sub-Acquiring Operator regime (published 23 July 2025). These changes land on an acquiring market that has already moved from a Transbank near-monopoly — around 98% in 2021 — to a multi-acquirer model with six acquirers operating and around 20 PSPs competing, projected below 70% incumbent share. The merchant-acquiring layer is formalised through Compendio III.J.2 and NCG 541, with volume-graduated prudential thresholds and proportionate collateral on PSPs. The reform agenda traces in substantial part to the Transbank antitrust and tariff saga (Supreme Court Case 82.422-2021), which overturned the incumbent's self-regulated fee structure. On resilience, Law 21.663 (promulgated Apr 2024) established the ANCI cybersecurity agency with mandatory CSIRT incident reporting on a 3-hour initial alert, staged into force with incident-reporting and sanctions provisions from 1 Mar 2025, coexisting with sectoral CMF RAN chapters 20-7 through 20-10. On digital money, stablecoins pegged to currencies are assigned to BCCh regulation subject to local issuance, and the BCCh began a wholesale CBDC proof-of-concept from June 2025 with no issuance commitment. The domestic A2A rail is the bank-operated TEF, with no Pix/UPI-style central instant scheme. The consumer-fraud regime combines Ley 20.009's five-working-day statutory refund with Ley 21.673's anti-autofraude tightening, against a 109% year-on-year rise in SERNAC fraud complaints in 2024. The AML/CFT surface, carried from the Sentinel feed, rests on the UAF/Ley 19.913 FIU regime with PISPs as obliged entities and a USD 3,000 CDD threshold; Chile is a GAFILAT member not on the FATF strategic-deficiency list. Settlement access is structurally opening: under Ley 21.641 the BCCh's November 2025 consultation proposes extending LBTR/RTGS access to CMF-supervised non-bank financial entities currently limited to bank intermediation, with differentiated timelines and no settlement guarantee. Open finance under CMF NCG 514 has been postponed to July 2027 via NCG 569, extending implementation from 24 to 36 months. #### Outlook Forward regulatory friction is concentrated in 2026-2027. The 30 April 2026 NCG 559 prior-notice deadline is the nearest operative trigger, followed by the October interchange caps that reset card economics, and the Open Finance postponement to July 2027 via NCG 569 that shifts non-bank PISP go-to-market timelines. The BCCh's LBTR non-bank access regime is expected to finalise across the second half of 2026. Together these set the operative timeline for any non-bank payments operator entering Chile, against a backdrop of a tightening, actively reforming regulatory environment spanning licensing, scheme economics and settlement access. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved Confirmed confirmed 2026-06-27 Under the Fintec Law (Ley 21.521), the Banco Central de Chile (BCCh) holds statutory power to regulate stablecoin issuance and operation as a means of payment; as of the August 2026 Informe de Sistemas de Pago the BCCh has moved from a purely conceptual/monitoring posture to a committed rulemaking timeline, confirming it will publish a consultation draft framework before year-end 2026, on a gradual basis complementary to CMF's existing Fintec Law regulations. Movement — NEW CMF opened two new consultations this cycle (credit-union capital, Open Finance roadmap)_New T1 CMF press releases dated 16 Oct 2026_ Horizon · 2026-Q4 (±half_year) BCCh stablecoin regulatory framework for consultation expected_proposed · TT1_ Horizon · 2026-04-30 (±quarter) NCG 559 prior-notice reporting deadline for traditional Fintech-service providers_in_force_pending · T1_ Standing sub-brief · as of 29 June 2026 396 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Chile operates a deliberately dual-track non-bank payments licensing architecture, with no single unitary EMI licence. Banks access payment activity via the General Banking Law; non-bank operators must route through one of two distinct statutory channels. Ley 20.950 (2016) authorises non-bank entities to issue and operate stored-value payment means; issuers and operators must be Chilean sociedades anónimas with exclusive corporate purpose, governed by Banco Central rules under article 35 and subject to CMF supervision. Separately, Law 21.521 (published 4 Jan 2023, effective 3 Feb 2023) brought seven Title II financial-technology services into the CMF perimeter, requiring registration in the Registro de Prestadores de Servicios Financieros and, for several activities, prior CMF authorisation. This bank-versus-non-bank-PI/EMI distinction is structural: a bank PSP and a non-bank stored-value issuer face different statutory bases, different prudential anchors and different supervisory entry points, and an operator's structuring decision turns on which route fits its activity set. The most material recent development in this module is the introduction of a prior-notice duty for incumbents. NCG 559 (issued 9 Feb 2026, in force on that date) inserted Chapter X into NCG 502, establishing a prior-notice duty for traditional CMF-supervised providers offering Fintech Law services without separate registration, with a transitional reporting deadline of 30 April 2026 for entities already providing such services. This obligation applies to both bank and non-bank supervised entities, capturing traditional supervised firms that have begun offering fintech services under their existing authorisation. The near-term reporting trigger is a concrete compliance event rather than a standing structural feature, and it is the live deadline in the licensing layer for the current window. The absence of a unitary EMI licence is the defining feature for any non-bank payments operator assessing market access. Where a single passport-style licence would consolidate authorisation, Chile instead requires the operator to map its activities onto the stored-value route, the Title II provider route, or both, with the registration and authorisation burden differing across activity types. This shapes entity structuring and the sequencing of market entry. #### Outlook The 30 April 2026 NCG 559 reporting deadline is the nearest operative trigger in this module and defines the immediate compliance timeline for traditional supervised providers. Beyond it, the dual-track architecture is established and stable, with the practical entry route for non-banks continuing to depend on whether activities fall under stored-value issuance or Title II provider registration. Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Three distinct market-access developments moved in Chile this cycle, each affecting a different segment of licensed and quasi-licensed payment activity. First, the Comision para el Mercado Financiero proposed regulatory amendments that would significantly expand the scope of complementary activities available to payment card operators, a liberalising move that would widen the range of services card operators can offer alongside their core licensed activity. Second, CMF Norma de Caracter General N569, issued in June 2026, formally postponed the go-live date for the Sistema de Finanzas Abiertas (Open Finance regime) from July 2026 to July 2027, affecting both CMF-supervised financial entities and non-bank Fintec providers subject to the regime; this gives the market an additional year to prepare technical and governance infrastructure before Open Finance obligations become binding. Third, since 9 February 2026 under CMF Norma de Caracter General N559, traditional supervised financial entities exempt from registration in the Registro de Prestadores de Servicios Financieros, including banks, securities intermediaries, exchanges, fund managers and insurers, must give the CMF prior notice before beginning any Fintec-adjacent services. Taken together, these three developments show a market-access posture that is liberalising in one respect (card-operator activity scope) while simultaneously building in more process and more time elsewhere (the Open Finance delay, and the new prior-notice duty for exempt entities). This is consistent with a gradualist sequencing approach to payments-market liberalisation generally, rather than a broad simultaneous rollout across every segment at once. The prior-notice duty under NCG 559 applies specifically to banks and other traditionally licensed entities moving into Fintec-adjacent activity without full RPSF registration, distinguishing that pathway from the RPSF registration route that applies to purpose-built Fintec providers. #### Outlook The CMF's consultation on expanded complementary activities for payment card operators is the item to track first, since it would represent the most immediate liberalising change among the three developments. The July 2027 Open Finance go-live date is the second marker, now a year later than originally planned, giving both banks and Fintec providers additional runway. The NCG 559 prior-notice mechanism, already in force since February 2026, is a procedural checkpoint rather than a pending reform, but its application in practice to banks expanding into Fintec-adjacent services is worth monitoring for how strictly the CMF enforces the prior-notice requirement. **4 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### Licensing, Authorisation & Market Access Ley 21.521, Chile's Fintech Law, brings seven new digital-finance business models within the CMF's licensing perimeter, including crypto-asset custody and alternative trading systems. This is a confirmed, Tier-1-sourced finding and represents a structural expansion of the regulatory perimeter for non-bank payment institutions and e-money issuers, which previously operated largely outside dedicated CMF licensing for these specific activities. The bank-PSP versus non-bank-PI/EMI distinction is central here: the newly captured business models are predominantly non-bank digital-finance providers, meaning the practical compliance burden of this expansion falls disproportionately on entrants that did not previously hold any CMF authorisation, rather than on incumbent banks that were already within the CMF's supervisory perimeter for other activities. The implementing mechanism for this licensing expansion is CMF General Rule N502, which requires providers to notify the CMF before commencing services regulated under Ley Fintec. This pre-commencement notification requirement is a confirmed, Tier-1-sourced obligation and functions as the practical gate that new entrants must clear before beginning operations. Secondary commentary corroborates that the Fintech Law establishes both a licensing system and a regulatory sandbox allowing supervised temporary operation for innovative projects, giving prospective entrants a lower-friction pathway to test products under CMF supervision ahead of full licensing, though this sandbox detail is assessed at Probable confidence given its Tier-3 sourcing. An open gap from this cycle is that the exact NCG number or numbers beyond N502 governing crypto-asset custodian registration categories specifically have not been independently verified against CMF norm text. This means the full licensing taxonomy applicable to different classes of non-bank digital-finance providers is not yet completely mapped from primary sources. #### Outlook Further CMF implementing norms beyond NCG N502 are the item to watch for a complete picture of the licensing taxonomy applicable to newly captured non-bank digital-finance business models. The regulatory sandbox mechanism, once more primary-source detail becomes available, may also become a more prominent market-access pathway for innovative entrants seeking to test products ahead of full licensure. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access Banco Central de Chile's August 2026 Informe de Sistemas de Pago commits to publishing a new stablecoin regulatory framework for consultation, setting conditions for local issuance of payment-use stablecoins under the Fintec Law (Ley 21.521), gradual and complementary to the CMF's existing regulation. BCCh President Rosanna Costa's launch speech pins that commitment to an explicit timeline, targeting a first, gradual stablecoin regulatory proposal before year-end 2026, again framed as complementary to the CMF's Fintec Law regime. The BCCh had already published a conceptual analysis framing fully-backed stablecoins as functionally analogous to bank deposits or prepaid balances, previewing the liquidity, AML/KYC and redemption-at-par considerations that will underpin the coming framework. Authority for the regime sits with the central bank under the Fintec Law, running alongside — rather than instead of — the CMF's existing Fintec Law licensing track, so the framework is expected to apply across both bank and non-bank issuers of payment-use stablecoins. #### Outlook The consultation draft is expected before year-end 2026, but reserve and safeguarding requirements, and the exact publication date, have not yet been disclosed; the framework is described as gradual, implying phased rather than immediate application once published. Periodic update · new data 2026-09-04 #### Licensing, Authorisation & Market Access Chile's licensing perimeter for fintech and payment services extended this cycle through a notification-based track that sits alongside, rather than replacing, the main registration regime. NCG 559, issued by the Comision para el Mercado Financiero on 9 February 2026, inserted a new Chapter X into NCG 502, requiring entities already supervised by the CMF that provide a Fintech-Law-listed service outside the main Registro de Prestadores de Servicios Financieros to give the Commission prior notice rather than undergo full RPSF registration. The compliance deadline for this notification was 30 April 2026. The distinction matters for both bank and non-bank participants: an entity already holding banking or other CMF authorisation that adds a Fintech-Law-listed activity does not need to run the full registration process again, but it cannot simply proceed without any regulatory touchpoint either — the notification requirement closes that gap. The scale of activity moving through the underlying RPSF registration process gives a concrete read on market entry: the first NCG 502 registration round received 335 applications, of which 160 also initiated the parallel operating-authorisation process required for entities seeking to actually begin operating rather than merely register. That gap between registration applications and operating-authorisation initiations — 335 versus 160 — is itself informative: it suggests a substantial share of applicants are securing registered status without yet moving to full operational authorisation, a pattern relevant to both bank-affiliated and non-bank payment-institution and e-money-institution applicants navigating the same registry. Taken together, NCG 559's notification track and the registration-volume data point to a market-access perimeter that is actively tightening in its documentation and notification requirements while the underlying registry continues to process a substantial applicant pool. The bank-versus-non-bank distinction is structurally important here: banks and other already-supervised entities face the lighter notification track, while genuinely new non-bank payment-institution and e-money-institution entrants must run the full RPSF registration and, where applicable, the operating-authorisation process. #### Outlook Watch for whether the 160 entities that initiated operating-authorisation alongside registration receive authorisation decisions in the coming cycles, and whether the notification-track population created by NCG 559 grows as more already-supervised entities add Fintech-Law-listed services to their existing authorisations. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Chile's open-finance and non-bank payment-licensing framework under Ley Fintec continued its phased implementation this cycle, with two distinct developments moving on different tracks. First, the CMF amended Norma de Caracter General N514 on 1 June 2026, detailing the technical requirements for information exchange and payment initiation under the Sistema de Finanzas Abiertas (SFA), Chile's open-finance system (High confidence, primary CMF publication). This amendment sharpens the technical specification of SFA obligations for both bank and non-bank participants ahead of the system's eventual entry into force. Second, and moving in the opposite direction on timeline, the SFA's effective date has been postponed to July 2027, citing implementation complexity (High confidence, same primary source). This is the second postponement of the SFA's effective date under Ley Fintec, and the pattern is now clear enough to read as a structural feature of Chile's open-finance rollout rather than a one-off delay: Chile is pursuing a deliberately cautious, phased approach to open-finance implementation, prioritising technical readiness over a fixed go-live date, even as it continues to publish increasingly detailed technical specifications in the interim. Separately from the SFA track, the CMF's RPSF (Registro de Prestadores de Servicios Financieros) registry continued to progress: as of May 2026, it had received 335 applications, registered 42 entities, and granted 37 full operating authorisations (Assessed confidence, secondary aggregation of registry progress; primary CMF registry data not independently retrieved this cycle). This is exclusively a non-bank pathway, and the roughly one-in-nine ratio of applications to full authorisations to date suggests a deliberately paced review process rather than a backlog concentrated at any single stage. For non-bank payment institutions and e-money issuers assessing Chilean market entry, this ratio is a useful benchmark for realistic time-to-authorisation planning, though the underlying data does not disaggregate by applicant type or indicate median processing time. Reading the NCG 514 amendment, the SFA delay, and the RPSF progression together, the picture for market access is one of steady, incremental regulatory build-out rather than either acceleration or stagnation. Non-bank payment institutions have a functioning, if selective, registration pathway already operating and producing authorisations, while the broader open-finance infrastructure that would eventually connect bank and non-bank participants under common information-exchange and payment-initiation rules remains more than a year from taking effect. This creates a two-speed market-access environment: non-bank entities can obtain RPSF authorisation and begin operating today under existing rules, while the more transformative open-finance connectivity that SFA promises remains prospective. The bank-versus-non-bank distinction is worth stating explicitly for this module: the NCG 514 amendment and the SFA framework apply to both bank and non-bank participants jointly, since open-finance information-exchange and payment-initiation obligations are designed to operate across the whole regulated payments ecosystem, whereas the RPSF registry is specifically the non-bank authorisation pathway. An operator's market-access strategy in Chile should therefore treat RPSF registration as the near-term operative licensing question, and SFA compliance as a mid-term technical-integration question tied to the now twice-delayed 2027 effective date. For prospective market entrants weighing Chile specifically, the practical sequencing implication is that RPSF authorisation is the correct first-order licensing objective regardless of an entrant's eventual open-finance ambitions, since SFA connectivity obligations will not become operative before mid-2027 at the earliest and are explicitly contingent on the framework holding to its now twice-revised timeline. It is also worth noting that the RPSF registry's reported figures — 335 applications, 42 registrations, 37 authorisations — were sourced this cycle from a secondary aggregator rather than directly from CMF's own registry publication; institutions relying on these figures for competitive-landscape or planning purposes should treat them as directionally indicative rather than as a verified CMF-published statistic pending primary confirmation. #### Outlook Watch for whether the SFA's July 2027 effective date holds without a third postponement, and for the pace of RPSF authorisations relative to applications through the remainder of 2026, which would indicate whether the current roughly one-in-nine completion ratio is stable, improving, or a temporary artefact of the registry's early stage. Any further NCG amendments detailing SFA technical requirements ahead of the 2027 date should be read as continued technical-readiness build-out consistent with the current phased-implementation pattern. **Sources and findings (4)** 1. T1 [https://www.bcn.cl/leychile/navegar?idNorma=1187323 (Ley 21.521)](https://www.bcn.cl/leychile/navegar?idNorma=1187323 (Ley 21.521)) 2. T1 [https://www.cmfchile.cl/portal/principal/613/w3-article-103412.html (NCG 502/559)](https://www.cmfchile.cl/portal/principal/613/w3-article-103412.html (NCG 502/559)) 3. T1 [https://www.bcn.cl/leychile/Navegar?idNorma=1096097 (Ley 20.950)](https://www.bcn.cl/leychile/Navegar?idNorma=1096097 (Ley 20.950)) 4. T3 [https://practiceguides.chambers.com/practice-guides/fintech-2025/chile](https://practiceguides.chambers.com/practice-guides/fintech-2025/chile) retrieved 2026-06-27 ### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-06-27 CMF's Autenticación Reforzada de Clientes (ARC, NCG N°538) mandate took effect 1 August 2026, eliminating printed coordinate-card authentication except for a supervised, reported carve-out for digitally-excluded client groups; carve-out transactions are not ARC-compliant and carry elevated issuer fraud-liability exposure. Standing sub-brief · as of 29 June 2026 331 words · last cycle 2026-09-08 #### Conduct, Safeguarding & Financial Promotions Customer-fund protection for non-bank payments operators in Chile rests on statutory segregation rather than deposit insurance, and this is the central conduct and safeguarding distinction between bank PSPs and non-bank PI/EMI operators. Under Ley 20.950 prepaid issuer funds received from the public may only be used for payments and refunds, must be accounted for and maintained segregated from the issuer's other operations, earn no interest for the holder, and cannot be attached or subjected to precautionary measures for the issuer's other obligations. This is statutory ring-fencing: customer funds are held segregated, used only for payments and refunds, and are non-attachable for the issuer's other debts. Critically, no deposit-protection scheme applies to non-bank issuers, so the protection posture for a non-bank prepaid customer is materially different from that of a bank depositor — segregation, not insurance, is the operative safeguard. The conduct overlay sits across both bank and non-bank financial products. Ley 20.555, the SERNAC Financiero statute, amended consumer-protection Law 19.496 to grant SERNAC financial-consumer powers and rights including the right to close a financial product within 10 days and a ban on tied sales of unrequested products and insurance. These conduct rights apply regardless of whether the provider is a bank or a non-bank, layering a financial-consumer-protection regime over the segregation framework. The combination determines how a non-bank operator must present, sell and unwind financial products, and where its customer-treatment obligations bite. The analytical spine here is the divergence in fund-protection posture: a non-bank operator must communicate to its customers that protection arises from statutory segregation and non-attachability, not from any equivalent of deposit insurance, while simultaneously honouring the SERNAC conduct overlay that applies uniformly across product types. #### Outlook The safeguarding and conduct framework is established. The statutory segregation regime under Ley 20.950 and the SERNAC financial-consumer rights under Ley 20.555 are standing positions rather than developing items, and the operative conduct question for non-bank operators remains the clear communication of the segregation-versus-insurance distinction to customers. Periodic update · new data 2026-09-14 #### Conduct, Safeguarding & Financial Promotions As of 1 August 2026, CMF's mandatory Autenticación Reforzada de Clientes (ARC, NCG N°538) took effect, ending printed 'tarjeta de coordenadas' authentication for the general population; a supervised, CMF-reported carve-out applies for justified digitally-excluded groups, and carve-out transactions carry elevated issuer fraud-liability exposure since they are not ARC-compliant. #### Outlook The rule is now in force rather than pending, so the near-term watch item shifts to how many customers fall into the reported carve-out and whether that population narrows over time. **Sources and findings (4)** 1. T3 [https://www.carey.cl/ley-20-950-...](https://www.carey.cl/ley-20-950-...) 2. T1 [https://www.cmfchile.cl/portal/principal/613/w3-article-74250.html](https://www.cmfchile.cl/portal/principal/613/w3-article-74250.html) retrieved 2026-06-27 3. T3 [https://en.wolfenson.cl/derecho-del-consumo](https://en.wolfenson.cl/derecho-del-consumo) retrieved 2026-06-27 4. T4 [https://coinfomania.com/cryptocurrency-regulations-in-chile/](https://coinfomania.com/cryptocurrency-regulations-in-chile/) retrieved 2026-06-27 ### W2 Stablecoins & Digital Money moved Confirmed confirmed 2026-06-27 Chile's stablecoin/digital-money perimeter remains split between the CMF (crypto-assets as financial instruments, Fintech Law) and the Banco Central de Chile (BCCh), which under amended art. 35 No.8 of its Organic Law is empowered to set general-rule standards for DLT-based, fiat-backed payment-value representations (Ley 21.521 arts. 30-31), but as of 13 Oct 2026 has not yet issued that general rule. Movement — CHANGED BCCh general rule under Ley 21.521 confirmed still not issued as of 13 Oct 2026_New dated confirmation from secondary source this cycle_ Standing sub-brief · as of 29 June 2026 312 words · last cycle 2026-10-18 #### Stablecoins & Digital Money Chile's treatment of stablecoins as payment instruments sits at the boundary of two regulators. Under the Fintech Law, crypto assets, exchanges and intermediaries are regulated by the CMF, whereas stablecoins pegged to currencies are treated as a payment method and fall under BCCh regulation, provided they are issued in Chile by CMF-supervised entities. This local-issuance requirement is the analytically decisive feature: it creates difficulty regulating dominant global stablecoins such as USDC, because the framework anchors regulatory treatment to domestic issuance by supervised entities, leaving the largest global stablecoins outside the Chilean payment-rail perimeter. The stablecoin-as-payment-rail framework is still being built out via pending BCCh standards; the policy assignment of stablecoins to the BCCh perimeter exists, but no in-force domestic stablecoin issuance standard yet operationalises it. On central bank digital currency, the BCCh's posture is exploratory and explicitly non-committal. From June 2025 the BCCh began a practical proof-of-concept exploration of a wholesale CBDC focused on DLT and settlement of tokenised assets, building internal capabilities; the bank explicitly states this is not a commitment to issue and that insufficient information exists for a definitive decision. The proof-of-concept is wholesale-focused, oriented toward settlement of tokenised assets rather than a retail digital currency, and the BCCh has been clear that capability-building does not imply issuance. The illicit-finance dimension of stablecoin treatment — including any sanctions-evasion or de-risking significance of the local-issuance constraint — is a cross-monitor referral to FIM, not a conclusion drawn here. The WPM surface is the payment-instrument and payment-rail treatment alone. #### Outlook The stablecoin-as-payment framework remains pending, with no in-force domestic issuance standard from the BCCh and only the policy assignment of stablecoins to the BCCh perimeter in place. The wholesale CBDC proof-of-concept continues with no issuance commitment. Both threads are developing rather than settled, and the pending BCCh standards are the items to watch in the next window. Periodic update · new data 2026-10-18 #### Stablecoins & Digital Money Chile's stablecoin and digital-money regulatory framework remains incomplete at its core. Ley 21.521, articles 30 and 31, gives the Banco Central de Chile the statutory authority to issue a general rule setting standards for DLT-based representations of value backed by fiat money, which would be the natural instrument through which the BCCh, as payments-system regulator, could establish a dedicated stablecoin framework. As of 13 October 2026, the BCCh has not issued that general rule, and no target date for doing so has been identified. In the absence of a BCCh-issued standard, the Comision para el Mercado Financiero is the body currently setting the operative treatment of fiat-referenced tokens, through its Official Letter 101082 of 12 June 2026. That letter holds that crypto-assets generally, including fiat-referenced tokens, qualify as financial instruments under the Fintech Law, meaning providers of services involving such tokens require CMF registration and authorisation. This is a classification regime built for financial instruments generally, not a payments-system-specific stablecoin standard, and it means that the payments characteristics of a fiat-referenced token, redemption mechanics, reserve backing, settlement finality, are not yet subject to a bespoke payments-focused regulatory test in Chile. The practical effect is that any payment institution or fintech building a stablecoin-based payment product into or through Chile is currently relying on CMF's general financial-instrument gate as the compliance pathway, with the BCCh's more naturally fitting payments-system authority sitting unexercised alongside it. #### Outlook The decisive development to watch for payments market participants is whether and when the BCCh exercises its Ley 21.521 article 30-31 rule-making power. Until it does, CMF's financial-instrument classification will continue to govern stablecoin and fiat-referenced token activity in Chile, and any payments product built on such tokens should be structured around that classification rather than around an anticipated, but as yet unscheduled, BCCh standard. **1 earlier distinct update(s)** Periodic update · new data 2026-10-11 #### Stablecoins & Digital Money The Banco Central de Chile confirmed, in its 2026 Informe de Sistemas de Pago, that it will put a first regulatory proposal on the issuance and payment-functioning of stablecoins to public consultation towards the end of 2026, with definitive regulation targeted for 2027. This marks the BCCh moving from general signalling toward a concrete consultation timeline for a framework that has not previously existed in Chile. The central bank's own framing, read against its broader approach to payment-systems regulation this cycle, points toward a gradual and risk-differentiated structure, one that is likely to distinguish between stablecoin models according to their systemic-risk profile rather than apply a single uniform framework across all stablecoin types. This stands in contrast to the EU's MiCA, which establishes a unified categorical approach across asset-referenced and e-money tokens; Chile's trajectory instead suggests tiering by risk rather than by token category. The practical consequence for market participants is that no binding stablecoin-specific rule currently exists in Chile, and none will exist before the end-2026 consultation at the earliest, with definitive rules not expected before 2027. Any stablecoin issuance or payment-function activity targeting the Chilean market today operates ahead of the regulatory framework that will eventually govern it, and the shape of that framework, particularly how it will differentiate between stablecoin models by risk tier, remains to be defined through the consultation process. #### Outlook The end-2026 public consultation is the immediate marker to watch; its content will show for the first time how the BCCh intends to operationalise a risk-differentiated approach to stablecoin regulation, and whether it addresses locally-issued stablecoins only or extends to stablecoins used for payment purposes regardless of issuer location. Definitive regulation is targeted for 2027, giving market participants roughly a year's visibility window between consultation and binding rule once the consultation document is published. **Sources and findings (4)** 1. T1 [https://www.elibrary.imf.org/view/journals/002/2024/042/article-A003-en.xml](https://www.elibrary.imf.org/view/journals/002/2024/042/article-A003-en.xml) retrieved 2026-06-27 2. T1 [https://www.bcentral.cl/en/areas/financial-technology-hub/central-bank-digital-currency](https://www.bcentral.cl/en/areas/financial-technology-hub/central-bank-digital-currency) retrieved 2026-06-27 3. T3 [https://cryptoslate.com/crypto-laws/chile-fintech-law-21521-cryptoassets/](https://cryptoslate.com/crypto-laws/chile-fintech-law-21521-cryptoassets/) retrieved 2026-06-27 4. T3 [https://www.ainvest.com/news/chile-central-bank-eyes-cbdc-...](https://www.ainvest.com/news/chile-central-bank-eyes-cbdc-...) ### W3 Operational Resilience & Critical Infrastructure Confirmed confirmed 2026-06-27 Two regimes apply: sectoral CMF cybersecurity/operational-resilience rules in the RAN (20-7 outsourcing, 20-8 operational-incident information, 20-9 business continuity, 20-10 information security & cybersecurity) for banks, their support companies, and card issuers/operators; and the cross-sectoral Framework Cybersecurity Law 21.663 (in force 1 Jan 2025) creating the ANCI and mandatory CSIRT incident reporting (3-hour initial alert) for essential-service operators including finance. The two coexist and must be harmonised. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/chile/) Standing sub-brief · as of 29 June 2026 291 words · last cycle 2026-06-27 #### Operational Resilience & Critical Infrastructure Chile's operational-resilience architecture for payments now rests on two coexisting layers: a cross-sectoral cybersecurity regime and a sectoral financial-supervisory one. Law 21.663 (promulgated Apr 2024) established the national cybersecurity institutionality, the ANCI agency with supervisory and sanctioning powers, and mandatory CSIRT incident reporting. Its entry into force was staged: most provisions applied from 1 Jan 2025, but Article 9 mandatory incident reporting, carrying a 3-hour initial alert, and the Title VII sanctions regime applied from 1 Mar 2025. Payments operators classed as essential services therefore face a 3-hour CSIRT alert obligation under the cross-sectoral regime, distinct from their sectoral duties. The sectoral layer sits alongside this. CMF RAN chapters 20-7 (outsourcing and cloud), 20-8 (operational incident information), 20-9 (business continuity) and 20-10 (information security and cybersecurity) set operational-resilience obligations for banks, bank-support companies and card issuers and operators, coexisting with the cross-sectoral Law 21.663 regime. These RAN obligations apply principally to bank PSPs and the card-issuance and operation ecosystem, whereas the Law 21.663 duties reach across sectors to any entity classed as an essential service, including non-bank payments operators. The analytical spine is dual-regime harmonisation. A payments operator must reconcile sectoral CMF resilience duties with the cross-sectoral ANCI incident-reporting and sanctions regime, ensuring that its incident-response procedures satisfy both the CMF's operational-incident-information expectations and the 3-hour CSIRT alert obligation. The two regimes are not interchangeable, and the harmonisation burden falls on the operator. #### Outlook Law 21.663 is in force on a staged basis, with the incident-reporting and sanctions provisions effective since 1 Mar 2025, and the sectoral CMF RAN regime is stable. The forward question is operational rather than legislative: how payments operators harmonise their dual obligations in practice as ANCI's supervisory and sanctioning activity matures. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.bcn.cl/leychile/navegar?idNorma=1202434 (Ley 21.663)](https://www.bcn.cl/leychile/navegar?idNorma=1202434 (Ley 21.663)) 2. T3 [https://aws.amazon.com/financial-services/security-compliance/compliance-center/cl/](https://aws.amazon.com/financial-services/security-compliance/compliance-center/cl/) retrieved 2026-06-27 3. T3 [https://www.anguitaosorio.cl/en/ley-ciberseguridad/](https://www.anguitaosorio.cl/en/ley-ciberseguridad/) retrieved 2026-06-27 4. T1 [https://www.bcentral.cl/en/web/banco-central/areas/payment-system](https://www.bcentral.cl/en/web/banco-central/areas/payment-system) retrieved 2026-06-27 ### W4 Scheme & Network Compliance Confirmed confirmed 2026-06-27 Interchange cap regime (0.8% credit / 0.35% debit, effective October) plus TDLC ICG No.5 scheme-conduct remedies; NCG 541 creates Sub-Acquiring Operator; Compendio III.J governs card issuance/operation. Horizon · 2026-10 (±quarter) Chile interchange fee cap takes effect_in_force_pending · T3_ Standing sub-brief · as of 29 June 2026 359 words · last cycle 2026-09-03 #### Scheme & Network Compliance The Chilean card market is undergoing its most material economic reset in two decades, and this module is where that reset concentrates. The headline change is the interchange cap. An April decision capped interchange at 0.8% for credit and 0.35% for debit, effective October, expected to cut credit and debit interchange by roughly 46% and 42% respectively; the cap was set by the four-member Committee established under 2021 legislation. A reduction of this magnitude reshapes acquirer and issuer economics across the market and is the single most consequential pricing intervention in the current window. The cap sits on a foundation of scheme-conduct remedies. In ICG No.5 the competition court (TDLC) recognised Visa and Mastercard's dominant position and ordered public disclosure of interchange fees, removal of acquirer-licensing restrictions, no mandatory joint acceptance, and a temporary surcharging allowance pending interchange fees meeting the merchant-indifference 'tourist test'. These remedies target the two dominant schemes directly and aim at structural transparency and access, not merely price. The participant architecture has also been reworked. CMF NCG 541 (published 23 July 2025, in force) amended non-bank card issuance and operation rules, created the 'Sub-Acquiring Operator' figure for entities settling 0.5%-1% of total payments, and strengthened contract, interoperability and oversight standards. This creates a graduated participant spectrum keyed to processed-payment volume, formalising a tier of non-bank PI/EMI operators below the full acquirer threshold. The bank-versus-non-bank distinction matters here: the interchange caps and TDLC remedies apply across bank and non-bank participants, while the Sub-Acquiring Operator figure is specifically a non-bank participant category. Taken together, the interchange caps, the NCG 541 sub-acquiring registration regime and the TDLC ICG No.5 remedies compress acquirer and issuer margins and lower entry barriers simultaneously, accelerating the competitive reconfiguration already underway in the acquiring layer. #### Outlook The October interchange caps are the dominant forward event in this module, resetting card economics across the market. The TDLC ICG No.5 remedies remain in force and the NCG 541 sub-acquiring regime is established. The trajectory is escalating: the combination of margin compression and lowered entry barriers will continue to pressure incumbent scheme and acquirer economics through and beyond the October effective date. Periodic update · new data 2026-09-04 #### Scheme & Network Compliance Chile's open-finance regime reached a structural implementation milestone this cycle. NCG 569, issued by the CMF on 1 June 2026, amended NCG 514 and added Technical Annex N3, closing the normative rulemaking cycle required to launch the Sistema de Finanzas Abiertas. This follows directly from NCG 559's February 2026 changes to the adjacent licensing perimeter, and together the two instruments mark the transition of Chile's open-finance programme from rulebook-drafting into a live, dated implementation schedule. The phase-in schedule itself is the critical scheme-compliance fact: mandatory Group-1 obligations, covering banks and card issuers, begin from July 2026. A further wave, arriving eighteen months later, extends mandatory participation to credit unions, insurers, fund managers and compensation funds. The CMF's own projection places the total rollout at roughly five years, indicating that full-system open-finance data-sharing across all covered entity types is a multi-year programme rather than a single cutover event. This staged design explicitly distinguishes between bank-type Group-1 participants, who face the earliest and most immediate compliance burden, and the broader population of non-bank financial entities who have a longer runway before mandatory participation applies to them. A further, not-yet-adopted development bears watching: the CMF has floated a simplified-participation track for smaller Group-2 entities with fewer clients, intended to lower the entry requirements and costs of SFA participation for smaller non-bank participants. This remains proposed rather than settled, but its very existence signals that the CMF is alert to the risk that a uniform participation standard could impose disproportionate compliance costs on smaller non-bank entities relative to Group-1 banks and card issuers, and is prepared to differentiate the network-compliance burden by participant size. #### Outlook The July 2026 commencement of mandatory Group-1 obligations is the immediate scheme-compliance event to monitor, as it will be the first live test of the SFA's data-sharing infrastructure under real mandatory conditions. Beyond that, whether the floated simplified track for smaller Group-2 entities is formally adopted will determine how differentiated the network's compliance burden becomes as the five-year rollout proceeds through its subsequent, non-bank-heavy waves. **Sources and findings (4)** 1. T1 [https://www.fne.gob.cl/en/tdlc-establece-regulaciones-especificas-...](https://www.fne.gob.cl/en/tdlc-establece-regulaciones-especificas-...) 2. T3 [https://www.vixio.com/insights/...losing-monopoly](https://www.vixio.com/insights/...losing-monopoly) 3. T3 [https://www.garrigues.com/en_GB/new/chile-financial-market-commission-modifies-regulations-...](https://www.garrigues.com/en_GB/new/chile-financial-market-commission-modifies-regulations-...) 4. T1 [https://www.bcentral.cl/en/content/-/detalle/bcch-actualiza-regulacion-tarjetas-pago](https://www.bcentral.cl/en/content/-/detalle/bcch-actualiza-regulacion-tarjetas-pago) retrieved 2026-06-27 ### W5 Payment Corridor Dynamics Probable confirmed 2026-06-27 Domestic retail rails centre on bank account-to-account electronic transfers (Transferencias en Línea, TEF, operational since 2008), with no Pix/UPI-style central instant scheme but high digitisation. Cross-border flows run primarily over SWIFT correspondent rails (ISO 20022 migration underway). Chile sits within the LAC cross-border integration agenda (BIS/CEMLA) and is a target market for SWIFT's retail cross-border framework and stablecoin payout corridors. Standing sub-brief · as of 29 June 2026 280 words · last cycle 2026-06-27 #### Payment Corridor Dynamics Chile's domestic account-to-account infrastructure rests on a bank-operated rail rather than a central instant scheme. Chile's Transferencias en Línea (TEF) launched in 2008 as a bank account-to-account electronic transfer rail; Chile has no Pix/UPI-style central instant scheme but high digitisation, with nearly 70% of card payments on domestic schemes and wallets (MACH, Mercado Pago, Tenpo) projected to reach around 24% of in-person payments by 2030. The defining structural feature is the absence of a dedicated central instant scheme: the domestic A2A capability is delivered through the bank-operated TEF rail rather than a centrally governed real-time scheme on the Pix or UPI model. This shapes both bank and non-bank participation. The A2A rail is a bank-anchored capability, and the wallet ecosystem — MACH, Mercado Pago and Tenpo — sits atop the digitised payments landscape, projected to take a meaningful share of in-person payments over the medium term. The high level of digitisation coexists with the structural gap of no central instant scheme, which distinguishes Chile from regional peers that have built centrally governed instant rails. The absence of a dedicated instant scheme is recorded as not-applicable-in-regime rather than as a pending development, reflecting that the domestic instant-payment function is currently met through the TEF bank rail and wallet adoption rather than a central scheme in build. #### Outlook The corridor picture is stable. The TEF bank A2A rail remains the domestic transfer backbone, there is no central instant scheme in build, and wallet adoption is the principal medium-term variable, projected toward around 24% of in-person payments by 2030. Emerging-market rails and wallet adoption are lightly evidenced relative to card-market coverage, and remain a thinner surface in the current window. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://www.imf.org/-/media/files/publications/wp/2024/english/wpiea2024119-print-pdf.pdf](https://www.imf.org/-/media/files/publications/wp/2024/english/wpiea2024119-print-pdf.pdf) retrieved 2026-06-27 2. T3 [https://www.rapyd.net/blog/chile-payments-guide/](https://www.rapyd.net/blog/chile-payments-guide/) retrieved 2026-06-27 3. T2 [https://www.swift.com/news-events/news/transforming-consumer-payments-...](https://www.swift.com/news-events/news/transforming-consumer-payments-...) ### W6 Industry Structure & Commercial Probable confirmed 2026-06-27 The acquiring market opened from a Transbank near-monopoly (~98% in 2021) to a multi-acquirer model from 2020, with Transbank's share falling below ~70% as GetNet, Klap and ~20 PSPs entered. Card issuing/acceptance is dominated by Visa/Mastercard; wallets (MACH, Mercado Pago, Tenpo) are scaling, and digital-only banks (Tenpo Bank, Itaú's itú) are entering, supported by the CMF's January 2025 Financial Inclusion Strategy. Standing sub-brief · as of 29 June 2026 278 words · last cycle 2026-06-27 #### Industry Structure & Commercial Dynamics The structural story in Chilean payments is the dismantling of a single-operator acquiring market. The acquiring market opened from a Transbank near-monopoly — around 98% in 2021, around 80% by end-2022, and projected below 70% — to a multi-acquirer model from 2020, with six acquirers operating, three more awaiting approval and around 20 PSPs competing. This is a structural competitive-landscape shift rather than a discrete commercial event: the erosion of Transbank's share is a market-architecture change, with the discrete deals that flow from it routed to the commercial-intelligence module. The pace of erosion is material. A market that was effectively a near-monopoly in 2021 has, within a few years, moved to a multi-acquirer model with six operating acquirers, a further three in the approval queue, and around 20 PSPs in competition. The projected fall below 70% market share signals that the incumbent's dominance is no longer structural, and the opening creates room for new PSPs and acquirers to take volume. The distinction between this module and commercial intelligence is important: the broad structural M&A and competitive trend lives here, while specific announced deals — such as bank-led acquisitions of domestic acquirers — are commercial events recorded separately. The structural reading is that the multi-acquirer model has fundamentally altered the competitive baseline of the Chilean card-acceptance market. #### Outlook The market structure is opening. Transbank's share is projected to continue falling below 70%, with three further acquirers awaiting approval and a competitive PSP layer already in place. The trajectory is one of continued fragmentation of a formerly concentrated market, with the interchange and scheme-conduct interventions in the scheme module amplifying the competitive pressure on incumbents. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.vixio.com/insights/...losing-monopoly](https://www.vixio.com/insights/...losing-monopoly) 2. T1 [https://www.bcentral.cl/en/sistema-de-pagos-2](https://www.bcentral.cl/en/sistema-de-pagos-2) retrieved 2026-06-27 3. T3 [https://finance.yahoo.com/news/chile-cards-payments-market-...](https://finance.yahoo.com/news/chile-cards-payments-market-...) 4. T3 [https://www.rapyd.net/blog/chile-payments-guide/](https://www.rapyd.net/blog/chile-payments-guide/) retrieved 2026-06-27 ### W7 Legal & Litigation Probable confirmed 2026-06-27 The defining payments litigation is the long-running Transbank antitrust/tariff saga: a 2005 FNE complaint and antitrust finding of dominant-position abuse, a Supreme Court ruling (Case 82.422-2021) overturning Transbank's self-regulated fee structure, and the TDLC's ICG No.5 imposing scheme-conduct remedies. A 2018 Supreme Court ruling upheld BancoEstado closing a crypto-exchange account on AML grounds. Standing sub-brief · as of 29 June 2026 265 words · last cycle 2026-06-27 #### Legal & Litigation The litigation thread that anchors Chilean payments reform runs through the Transbank antitrust and tariff saga. The Supreme Court ruling (Case 82.422-2021) overturned Transbank's self-regulated fee structure following a 2005 FNE complaint and antitrust finding of dominant-position abuse; the TDLC's ICG No.5 then imposed scheme-conduct remedies and recommended incorporating PSPs into the CMF's sectoral scope. This long-running litigation underpins the broader card-market reform agenda, connecting the antitrust finding against the incumbent acquirer to the scheme-conduct remedies and the proposed extension of supervisory perimeter over PSPs. The analytical significance is that the reform agenda in the scheme, acquiring and licensing modules is not free-standing regulatory initiative but is in substantial part the downstream consequence of litigation. The 2005 FNE complaint, the antitrust finding of dominant-position abuse, the Supreme Court overturning of the self-regulated fee structure, and the TDLC's subsequent remedies form a continuous thread that has shaped the contemporary structure of the card market. The recommendation to bring PSPs into the CMF's sectoral scope, flowing from the same litigation, connects the legal thread directly to the licensing and supervision perimeter. This module establishes the litigation backdrop against which the interchange caps, sub-acquiring regime and scheme-conduct remedies should be read: each is, in part, a response to or continuation of the dominant-position findings against Transbank and the schemes. #### Outlook The Transbank antitrust and tariff thread is established as the foundational litigation underpinning the card-market reform agenda. The forward question is the degree to which the recommendation to incorporate PSPs into the CMF's sectoral scope is operationalised, carrying the litigation legacy into the supervisory perimeter. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T2 [https://www.kansascityfed.org/documents/11143/...](https://www.kansascityfed.org/documents/11143/...) 2. T1 [https://www.fne.gob.cl/en/tdlc-establece-regulaciones-especificas-...](https://www.fne.gob.cl/en/tdlc-establece-regulaciones-especificas-...) 3. T4 [https://coinfomania.com/cryptocurrency-regulations-in-chile/](https://coinfomania.com/cryptocurrency-regulations-in-chile/) retrieved 2026-06-27 ### W8 Merchant Acquiring & Risk Confirmed confirmed 2026-06-27 SII's cambio-de-sujeto mechanism (Resoluciones 69 and 94) now obliges banks and non-bank card/prepaid issuers to withhold 19% VAT on transactions with 10 named unregistered offshore betting platforms; SII disclaims this constitutes an operating authorisation. Standing sub-brief · as of 29 June 2026 269 words · last cycle 2026-08-05 #### Merchant Acquiring & Risk Merchant-acquiring registration and risk graduation form a previously under-indexed surface now covered in the Chilean baseline. PSPs that settle to affiliated merchants must constitute themselves as Sub-acquiring Operators and registered Operators under Compendio III.J.2 and NCG 541, observe objective non-discriminatory contracting, and meet prudential thresholds graduated by payment volume; the TDLC required full cost disclosure to merchants and proportionate collateral on PSPs. This registration and risk-graduation regime is principally a non-bank PI/EMI matter: PSPs settling to affiliated merchants are pulled into a formal registration obligation and a prudential framework keyed to the volume of payments they process. The volume-graduated structure is the analytical spine. Rather than applying a uniform prudential burden, the regime scales obligations to processed-payment volume, with the Sub-acquiring Operator figure (under NCG 541, settling 0.5%-1% of total payments) sitting within a graduated participant spectrum. Objective, non-discriminatory contracting and proportionate collateral requirements aim to ensure that the entry of non-bank acquiring participants does not import unmanaged settlement risk into the merchant-acceptance chain. The TDLC's transparency requirement — full cost disclosure to merchants — connects the merchant-acquiring risk framework to the broader scheme-conduct remedies, ensuring merchants can see the costs embedded in their acceptance arrangements. The proportionate-collateral requirement on PSPs is the risk-management counterpart to the market opening, calibrating prudential demands to participant scale. #### Outlook The merchant-acquiring registration and risk-graduation regime under Compendio III.J.2 and NCG 541 is established. The forward dynamic is the practical operation of the volume-graduated thresholds as more PSPs and Sub-acquiring Operators register and the multi-acquirer market continues to expand, testing whether the proportionate-collateral framework scales with the participant base. Periodic update · new data 2026-08-11 #### Merchant Acquiring & Risk Chile's tax authority has this cycle created the most commercially significant new compliance obligation for merchant acquirers and card issuers operating in the market, doing so entirely through tax administration rather than through payments or gambling-sector regulation. The Servicio de Impuestos Internos's Resolucion Exenta N69 (2 June 2026) first created a voluntary registration channel allowing foreign-domiciled online betting, gaming and casino platforms to register and remit Chilean VAT (High confidence, primary SII source). This channel is explicitly not a payments-licensing instrument and does not touch merchant-acquiring risk classification directly, but it set up the compliance architecture that the SII then activated more forcefully six weeks later. On 15 July 2026, the SII's Resolucion Exenta N94 activated a cambio-de-sujeto withholding mechanism obliging banks and non-bank card and prepaid issuers to withhold 19 percent VAT on every transaction with ten named non-compliant platforms (High confidence, primary SII source). This is a direct, transaction-level compliance function newly assigned to payment processors, not to the platforms themselves, and it carries immediate implementation and monitoring cost: acquirers and issuers must now identify transactions involving the ten named platforms and apply withholding at the point of processing, a materially different operational requirement from standard merchant-risk categorisation or transaction monitoring for card-network compliance purposes. The SII has been explicit that this mechanism, and the earlier voluntary registration channel, do not constitute an authorisation to operate online casinos or betting houses in Chile (High confidence, primary SII source). This disclaimer is analytically important for merchant-acquiring risk assessment specifically: a platform's presence on the SII's voluntary-registration list, or its absence from the named non-compliant list, cannot be read as a signal about its lawful operating status under Chile's separate and still-pending online-betting licensing framework. Acquirers and issuers should therefore treat SII tax-compliance status and gambling-sector licensing status as two entirely independent risk dimensions requiring separate assessment. The commercial-relevance signal attached to the withholding-mechanism claim this cycle is direct: it assigns a new tax-withholding compliance function to payment processors, creating implementation and monitoring cost that was not previously part of the acquiring relationship with these merchant categories. For acquirers with existing merchant relationships involving any of the ten named platforms — Bet365, Stars, 1Win, Electraworks, TheLotter, PokerStars, GGPoker, Betcris, LeoVegas and Roobet — this is now an operative compliance requirement rather than a prospective one, effective from the resolution's issuance. Twenty-five platforms voluntarily registered under the earlier channel within one day of the enforcement deadline, evidencing that a meaningful share of the market elected to formalise ahead of facing the withholding mechanism rather than risk being named. This bifurcation is itself a merchant-risk signal: acquirers should expect the compliance profile attached to voluntarily registered platforms to diverge from those attached to the ten platforms subject to withholding, even though neither group currently holds a sector operating licence. It is worth flagging for acquiring-risk teams that neither Resolucion Exenta N69 nor N94 has been characterised in the evidence this cycle as amending card-network scheme rules or merchant-category-code definitions directly; the obligation operates at the level of Chilean tax law applied to payment-processing entities, meaning implementation will run through each acquirer's or issuer's own tax-withholding systems rather than through a scheme-level rule change. The absence of a stated review or sunset date for either resolution in the evidence available this cycle means acquirers should plan for the withholding obligation as an indefinite operative requirement rather than a temporary measure pending the online-betting bill's eventual enactment. #### Outlook Watch for whether the SII adds further platforms to, or removes any from, the ten-platform withholding list, and whether additional platforms join the 25 that have voluntarily registered. Acquirers and issuers should also watch for any SII guidance clarifying how withholding obligations interact with existing card-network merchant-category-code classifications for gambling-adjacent merchants, an interaction not addressed in the resolutions evidenced this cycle. **Sources and findings (4)** 1. T3 [https://www.garrigues.com/en_GB/new/chile-financial-market-commission-modifies-regulations-...](https://www.garrigues.com/en_GB/new/chile-financial-market-commission-modifies-regulations-...) 2. T1 [https://www.bcentral.cl/documents/33528/115568/CapIIIJ2.pdf](https://www.bcentral.cl/documents/33528/115568/CapIIIJ2.pdf) retrieved 2026-06-27 3. T1 [https://www.fne.gob.cl/en/tdlc-establece-regulaciones-especificas-...](https://www.fne.gob.cl/en/tdlc-establece-regulaciones-especificas-...) 4. T1 [https://www.cmfchile.cl/portal/prensa/615/w3-article-68995.html](https://www.cmfchile.cl/portal/prensa/615/w3-article-68995.html) retrieved 2026-06-27 ### W9 Product Innovation & Market Development Confirmed confirmed 2026-06-27 CMF's Open Finance (Sistema de Finanzas Abiertas, SFA) leg of Ley 21.521 has been delayed a second time: NCG N569 (1 June 2026) amended NCG 514 and added Technical Annex 3, pushing full entry into force to July 2027 rather than the originally planned July 2026, with a graduated schedule for banks/card issuers (5-18 months post-vigencia) and other Article-18 entities (20-30 months). A voluntary pilot sandbox began in May 2026 with over 10 entities including BancoEstado and Mercado Pago. Separately, Banco Central de Chile is progressing a domestic instant-payments strengthening agenda with a public-consultation regulatory package expected following its August 2026 Informe de Sistemas de Pago. Horizon · 2027-07 (±half_year) Open Finance System (NCG 514) entry into force_adopted · T1_ Standing sub-brief · as of 29 June 2026 297 words · last cycle 2026-10-11 #### Product Innovation & Market Development The open-finance framework is the central product-access development in Chile, and its timeline has just shifted. CMF NCG 514 (3 July 2024) governs the Open Finance System under Title III, defining mandatory Information Provider and Account Provider Institutions and voluntary Information-Based Service Providers and Payment Initiation Service Providers (PISPs); CMF NCG 569 (issued June 2026) postponed SFA entry into force to July 2027, extending the implementation period from 24 to 36 months with greater graduality. The postponement is the live development: a delay from the original schedule to July 2027, lengthening the implementation runway by a full year. This is a regulatory product-access theme rather than a discrete commercial product launch, and it sits in this module rather than commercial intelligence accordingly. The framework carries the bank-versus-non-bank dimension directly. Mandatory Information Provider and Account Provider Institution roles fall on incumbent institutions, while the voluntary Information-Based Service Provider and PISP roles are the market-access opening for non-banks. The postponement to July 2027 therefore shifts go-to-market timelines specifically for non-bank PISP entrants whose business models depend on payment-initiation access under the open-finance regime. For market entrants the practical consequence is a deferred opportunity: the PISP and IBSP roles that operationalise non-bank participation in open finance now activate in July 2027 rather than on the original schedule, requiring entrants to re-plan their launch sequencing around the extended 36-month implementation period. #### Outlook The Open Finance System's entry into force is postponed to July 2027 via NCG 569, with implementation extended from 24 to 36 months. The trajectory is one of delay rather than retreat: the PISP and IBSP roles remain defined and will operationalise on the revised timeline, making July 2027 the operative date for non-bank open-finance market access. No formal regulatory sandbox accompanies the framework. Periodic update · new data 2026-10-11 #### Product Innovation & Market Development Chile's instant-payments infrastructure is the subject of two converging developments this cycle. The Banco Central de Chile confirmed it will put regulatory adjustments to the instant-payments system (SPI) and to Low-Value Payment Clearing House rules out for public consultation, targeting third-quarter 2026, aimed at addressing frictions that have limited transfer-for-payment usability for merchants. In direct response to the BCCh's 2026 Informe de Sistemas de Pago, the fintech industry association FinteChile presented a six-principle proposal specifically designed to make instant transfers usable for merchant payments. The alignment between the BCCh's own consultation agenda and FinteChile's industry-side proposal suggests the reform direction already has meaningful industry backing, which may shorten the distance between consultation and implementation relative to a reform with no pre-existing industry consensus. The underlying problem both developments address is the same: Chile's instant-payments rails (transferencia electronica de fondos, TEF) were designed primarily for person-to-person and bill-payment use cases, and friction in adapting them to merchant point-of-sale contexts has limited their use as a card-payment substitute. Resolving this friction would open a new use case for existing payment infrastructure without requiring a wholly new payment instrument, a lower-cost path to expanding instant-payments adoption than building parallel merchant-acquiring rails from scratch. #### Outlook The third-quarter 2026 consultation on SPI and clearing-house rule changes is the key date to track, since FinteChile's proposal gives a concrete benchmark against which to assess how much of the industry's six-principle agenda the BCCh's eventual rule changes actually adopt. Given the apparent alignment between regulator and industry priorities here, this reform track appears more likely to proceed on its stated timeline than one without comparable industry buy-in. **3 earlier distinct update(s)** Periodic update · new data 2026-09-28 #### Product Innovation & Market Development Chile's Open Finance framework, the Sistema de Finanzas Abiertas established under the Ley Fintec, absorbed its second delay this cycle. CMF's NCG 569, issued 1 June 2026, amended the existing NCG 514 and added a new Technical Annex 3, pushing full entry into force to July 2027 instead of the originally planned July 2026. The revised implementation runs on a graduated schedule: banks and card issuers have between five and eighteen months to comply, while other entities captured under Article 18 of the framework have between twenty and thirty months. This slippage sits specifically within the Open Finance leg of Ley Fintec; the law's core fintech-licensing perimeter, covering seven regulated service categories under CMF supervision, is a separate matter and remains in force on its original timeline. Against that delay, momentum is building on a different front. Banco Central de Chile's August 2026 Informe de Sistemas de Pago commits the central bank to a public-consultation regulatory package intended to strengthen the Sistema de Pagos Instantaneos and to facilitate its use as a payment method for retail merchants specifically. The central bank frames the scale of the opportunity directly, noting that only around ten percent of interbank transfers currently flow to merchants, implying substantial headroom for instant payments to displace other rails in retail commerce if the consultation's eventual proposals succeed. This is a stated commitment to consult, not a published draft; no rule text exists yet, and the timeline given is the fourth quarter of 2026 for the consultation package itself, with a half-year uncertainty band. Industry activity has moved ahead of the mandatory schedule on the Open Finance side. A voluntary pilot sandbox for the Sistema de Finanzas Abiertas launched in May 2026 with reported participation from more than ten entities, including BancoEstado and Mercado Pago. This report rests on a single lower-tier source and has not been independently corroborated this cycle, so it should be read as an indicative signal of industry positioning rather than a confirmed market fact. Taken together, the graduated statutory delay, the voluntary early-mover activity, and the central bank's parallel instant-payments push describe a market where infrastructure-building is proceeding on multiple tracks at uneven speeds, with the regulatory timeline for account-information-sharing consistently the slower of the two. #### Outlook The principal item to watch is whether the July 2027 Open Finance deadline holds without a third postponement, given the framework has already moved a full year from its original target. The BCCh's promised consultation package on strengthening instant payments for merchant use, expected around the fourth quarter of 2026, is the second item to watch, and will be the first indication of how the central bank intends to convert its stated ambition into a concrete regulatory instrument. Diputados have separately pressed CMF for progress updates on Open Finance implementation, an indication that legislative attention to the pace of rollout is likely to continue independent of the regulator's own consultation calendar. Periodic update · new data 2026-09-21 #### Product Innovation & Market Development Chile's Sistema de Finanzas Abiertas, the Open Finance System, reached full operative status in July 2026, a confirmed milestone corroborated by CMF and industry press, marking three years since Ley Fintec's original promulgation and the completion of a phased, multi-year implementation. This positions Chile among the jurisdictions with an operative open-finance regime encompassing both bank and non-bank participants, a structural development for product innovation in the Chilean payments landscape since it establishes the data-sharing infrastructure that new open-finance-enabled products can build upon. Separately, secondary commentary offers a more speculative reading of Ley Fintec's product-innovation potential: it argues that the law's broadened definition of instrumento financiero creates legal scaffolding capable of supporting real-world-asset tokenisation, even in the absence of any dedicated tokenisation chapter or CMF-specific tokenisation instrument. This is assessed at Uncertain confidence given its single Tier-4 sourcing, and should be read as an interpretive argument about the statute's potential reach rather than a confirmed regulatory product or CMF-endorsed framework for tokenisation activity. #### Outlook With the Open Finance System now fully operative, the item to watch is the pace and nature of product development that banks and non-bank participants build on top of the new open-finance infrastructure. On tokenisation, whether the CMF issues any dedicated guidance or instrument addressing real-world-asset tokenisation under Ley Fintec's financial-instrument definition is the key development that would resolve the current interpretive-only status of that theme. Periodic update · new data 2026-09-14 #### Product Innovation & Market Development The BCCh will publish for consultation amendments intended to strengthen the Sistema de Pagos Instantáneos (SPI) regulation and facilitate its use as a merchant payment method. The same Informe notes that TEF use is growing for everyday transactions, but merchant acceptance remains limited — the explicit gap the forthcoming SPI amendment targets. The BCCh also flags a rising digital-payments fraud rate since 2024, more persistent in debit-card payments, cited as a driver for redoubled regulatory and provider-side fraud-containment efforts alongside the SPI push. Separately, the BCCh says it is monitoring the scope and risks of certain prepaid-card business models that show high growth off a low base, and will assess whether the applicable regulatory framework needs review. Read together, the SPI push and the fraud trend describe the same underlying problem from two sides: instant payments are trusted enough for person-to-person use but not yet trusted enough, or accepted widely enough, at the point of sale. #### Outlook BCCh has not disclosed an exact publication date for the SPI consultation, so the near-term marker to watch is the draft text itself rather than a calendar date; the prepaid-card monitoring workstream remains at an earlier, undated stage. **Sources and findings (4)** 1. T1 [https://www.cmfchile.cl/portal/principal/613/w3-article-82752.html](https://www.cmfchile.cl/portal/principal/613/w3-article-82752.html) retrieved 2026-06-27 2. T3 [https://www.globallegalinsights.com/practice-areas/banking-and-finance-laws-and-regulations/chile/](https://www.globallegalinsights.com/practice-areas/banking-and-finance-laws-and-regulations/chile/) retrieved 2026-06-27 3. T3 [https://www.legal500.com/guides/chapter/chile-fintech/](https://www.legal500.com/guides/chapter/chile-fintech/) retrieved 2026-06-27 4. T1 [https://www.bcentral.cl/en/areas/financial-technology-hub/central-bank-digital-currency](https://www.bcentral.cl/en/areas/financial-technology-hub/central-bank-digital-currency) retrieved 2026-06-27 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-06-27 Consumer protection rests on Ley 19.496 (CCPA) enforced by SERNAC, reinforced by the 'Sernac Te Protege' reform giving SERNAC sanctioning powers. Card/electronic-fraud reimbursement is governed by Ley 20.009 (fraud-liability limitation, with fast 5-working-day refund for claims up to 35 UF), amended by Ley 21.673 (May 2024) which tightened anti-'autofraude' procedures and shifted some responsibility to customers; CMF NCG 538 added authentication requirements. Fraud complaints surged in 2024. Standing sub-brief · as of 29 June 2026 305 words · last cycle 2026-06-27 #### Consumer Protection & APP Fraud Chile's card-fraud reimbursement regime is the local analogue to the international authorised-push-payment fraud debate, combining a fast statutory refund with a recent tightening against customer-side abuse. Ley 20.009 requires a fraud victim to be refunded or have unrecognised transactions cancelled within 5 working days for claims at or below 35 UF; Ley 21.673 (May 2024) strengthened banks' ability to contest 'autofraude' and placed more responsibility on customers through a sworn statement and criminal complaint, with CMF NCG 538 adding authentication requirements; SERNAC reported 19,834 fraud complaints in 2024, up 109% on 2023. The fast statutory refund — five working days for qualifying claims — establishes a strong consumer-protection baseline, while the Ley 21.673 anti-autofraude provisions rebalance the regime toward the bank where customer-side abuse is suspected. The regime applies across both bank and non-bank participants, with the reimbursement obligation and the authentication requirements under NCG 538 reaching the providers serving defrauded customers. The sharp rise in SERNAC fraud complaints — up 109% year-on-year in 2024 to 19,834 — is the pressure behind the legislative tightening, signalling escalating fraud volumes that the regime is attempting to manage without abandoning the fast-refund commitment. The analytical tension is the balance between the fast statutory refund and the anti-autofraude rebalancing. The 2024 reform leans the regime back toward the provider where fraud is contested, requiring customers to substantiate claims through a sworn statement and criminal complaint, while NCG 538 raises the authentication bar that providers must meet. #### Outlook The trajectory is escalating, driven by rising fraud volumes. The Ley 20.009 fast-refund baseline coexists with the Ley 21.673 anti-autofraude tightening and the NCG 538 authentication requirements, and the year-on-year rise in complaints signals continued pressure on the regime. The forward question is how the rebalanced liability split operates in practice as fraud volumes stay elevated. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.carey.cl/en/sernac-begins-the-process-of-monitoring-compliance-with-law-no-20009-...](https://www.carey.cl/en/sernac-begins-the-process-of-monitoring-compliance-with-law-no-20009-...) 2. T3 [https://ironvest.com/blog/how-chilean-banks-can-meet-ley-21-673-...](https://ironvest.com/blog/how-chilean-banks-can-meet-ley-21-673-...) 3. T3 [https://www.hgomezgroup.com/chile/chile-legal-brief-bill-signed-to-strengthen-consumer-rights/](https://www.hgomezgroup.com/chile/chile-legal-brief-bill-signed-to-strengthen-consumer-rights/) retrieved 2026-06-27 4. T3 [https://blog.investchile.gob.cl/consumer-protection-chile](https://blog.investchile.gob.cl/consumer-protection-chile) retrieved 2026-06-27 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/chile/#sec-dom-D7) Probable confirmed 2026-06-27 sentinel. Chile's AML/CFT framework centres on the Unidad de Análisis Financiero (UAF) created by Ley 19.913 (2003), the FIU receiving suspicious transaction reports (ROS) from obliged entities; Fintech Law registrants including PISPs are obliged reporting entities. Chile is a GAFILAT member adhering to FATF standards and is not on the FATF strategic-deficiency list. (Position carried from Sentinel feed; no original illicit-finance analysis performed.) Standing sub-brief · as of 29 June 2026 286 words · last cycle 2026-06-27 #### AML/CFT & Financial Crime The AML/CFT surface for Chile is sourced from the Sentinel feed, and no original illicit-finance analysis is performed in this module. As carried from Sentinel: Ley 19.913 (in force 17 May 2004) created the UAF, Chile's FIU receiving suspicious-transaction reports (ROS); obliged informing entities include CMF Registry of Financial Service Providers registrants and PISPs, with KYC/CDD required for occasional transactions at or above USD 3,000; Chile is a GAFILAT member following the FATF risk-based approach and is not on the FATF strategic-deficiency list. The inclusion of PISPs among obliged informing entities is the point of direct intersection with the payments perimeter, bringing payment-initiation service providers into the AML/CFT reporting framework. The perimeter spans both bank and non-bank participants. The obliged-entity definition reaching CMF Registry registrants and PISPs means that the AML/CFT framework follows the licensing perimeter into the non-bank payments space, with the USD 3,000 customer-due-diligence threshold for occasional transactions setting the operative trigger. Chile's GAFILAT membership and absence from the FATF strategic-deficiency list situate the jurisdiction within the international risk-based standard-setting framework. Any original illicit-finance analysis — including the bank-versus-non-bank supervision gap, FATF mutual-evaluation status detail, or stablecoin sanctions-evasion significance — is a cross-monitor referral to FIM and is not developed here. The intelligence in this module is attributed to the Sentinel feed and links out accordingly; the AML/CFT surface for Chile should be sourced from the Sentinel and FIM feeds in subsequent cycles. #### Outlook The AML/CFT surface is stable as carried from Sentinel. The bank-versus-non-bank supervision gap and any FATF mutual-evaluation detail for Chile were not independently developed and should be sourced from the Sentinel/FIM feed next cycle. Original illicit-finance analysis remains a FIM referral rather than a WPM conclusion. no periodic updates on record for this sub-brief ** Sources and findings (6)** 1. T3 sentinel.https://www.enaer.cl/en/compliance-3/ 2. T? FIM (sentinel.gi) per-JID baseline profile — Chile — Chile's AML/CFT architecture rests on Ley 19.913 (2003, creates the Unidad de Análisis Financiero/UAF) and Ley 20.393 (2009, autonomous corporate criminal liability for money laundering, terrorist financing and bribery). Chile is a GAFILAT member, last underwent its 4th-round FATF/GAFILAT mutual evaluation (on-site Jan 2020, report 2021), and is not currently on the FATF grey or black list. A 2025 UNCAC Cycle II review found continued gaps in international cooperation and integrity legislation. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap 5. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-002) — Enforcement: Chilean Public Prosecutor's Office / Chilean Police — Banco Santander Chile employee and 17 co-suspects 6. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-003) — Enforcement: Chilean Public Prosecutor's Office / Chilean Police — Organized copper-theft and smuggling network ### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-06-27 BCCh confirms continuing regulatory work to expand access to the LBTR (RTGS) system and strengthen CCP liquidity-management requirements, though no formal instrument or date has yet been published. Horizon · 2026-H2 (±half_year) BCCh LBTR non-bank access regime finalisation_consultation · T1_ Horizon · 2026-H2 (±half_year) BCCh LBTR non-bank access regime finalisation_consultation · T1_ Standing sub-brief · as of 29 June 2026 314 words · last cycle 2026-09-08 #### Correspondent Banking, Settlement & Access The analytical spine of this module is the bank-versus-non-bank settlement-access asymmetry, and that asymmetry is precisely what is now being addressed. Settlement access in Chile is currently limited to banks, local CCPs and securities settlement systems, leaving non-bank financial entities dependent on bank intermediation to reach the high-value settlement layer. Under Ley 21.641 the BCCh opened a public consultation (Nov 2025) to regulate conditions for CMF-supervised credit cooperatives, securities custodians, low-value clearing houses and their non-bank participants, and recognised foreign CCPs to open BCCh accounts and pay directly via the LBTR; access is currently limited to banks, local CCPs and securities settlement systems, with differentiated timelines (12 months for high-value clearing houses) and no settlement guarantee. The significance is structural. Direct RTGS access for non-bank financial entities cuts dependency on bank settlement intermediation, removing a layer of credit risk and cost that currently sits between non-bank operators and final settlement. The consultation contemplates differentiated timelines — 12 months for high-value clearing houses — and explicitly carries no settlement guarantee, signalling a calibrated rather than wholesale opening of the access perimeter. This is a non-bank PI/EMI development at its core: the entities gaining contemplated direct access are precisely those currently obliged to route settlement through banks. The asymmetry framing matters because correspondent banking and settlement access have historically reinforced bank intermediation as the only route to the RTGS layer. The Ley 21.641 consultation is the clearest near-term move to narrow that asymmetry, opening direct LBTR participation to a defined set of non-bank financial entities. #### Outlook The settlement-access regime is opening. The BCCh's Ley 21.641 consultation is expected to finalise across the second half of 2026, with differentiated timelines and no settlement guarantee shaping the eventual access framework. The forward question is the final scope of eligible non-bank entities and the pace at which direct RTGS access displaces bank-only settlement intermediation. Periodic update · new data 2026-09-14 #### Correspondent Banking, Settlement & Access BCCh confirms continuing regulatory work to expand access to the LBTR (RTGS) system and strengthen liquidity-management requirements for central counterparties, framed as broadening participation beyond the current bank-centric base, though which non-bank categories would qualify, and on what timeline, has not yet been specified. #### Outlook No formal instrument or date has been published yet; the LBTR/CCP workstream remains a confirmed direction of travel rather than a scheduled reform. **Sources and findings (4)** 1. T1 [https://www.bcentral.cl/en/sistema-de-pagos-2](https://www.bcentral.cl/en/sistema-de-pagos-2) retrieved 2026-06-27 2. T1 [https://www.bcentral.cl/en/content/-/detalle/prensa/nota-de-prensa/consulta-acceso-lbtr-entidades-financieras-no-bancarias](https://www.bcentral.cl/en/content/-/detalle/prensa/nota-de-prensa/consulta-acceso-lbtr-entidades-financieras-no-bancarias) retrieved 2026-06-27 3. T2 [https://openknowledge.worldbank.org/...content](https://openknowledge.worldbank.org/...content) 4. T3 [https://chocale.cl/2025/11/...lbtr/](https://chocale.cl/2025/11/...lbtr/) ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-06-27 Crypto-asset service providers remain integrated into the Ley Fintec CMF registration perimeter; SII has separately layered crypto-specific tax-reporting obligations (Resoluciones N113/N114, DJ1963/DJ1964) onto exchanges since August 2025. Standing sub-brief · as of 29 June 2026 321 words · last cycle 2026-08-05 #### Commercial Intelligence (M&A, Investment & Product) Three discrete commercial events define the trailing-window commercial intelligence picture for Chile, each distinct from the structural market analysis carried elsewhere. On M&A, Chilean paytech Klap was acquired by Itaú Chile for US$43.7M (reported 16 Dec 2025) to strengthen its payments ecosystem. This is a bank-led consolidation of a domestic acquirer, signalling an incumbent response to the multi-acquirer market opening; as a specific announced deal it sits here rather than in the structural market-structure module. The deal value is publicly disclosed at US$43.7M, with Itaú Chile as acquirer and Klap as target. On investment, Chilean recurring-payments fintech Toku secured a US$48M Series A led by Oak HC/FT, described as the largest Series A by a woman-led Latin American fintech (reported May 2025). This sizeable Series A signals investor appetite for Chilean recurring-payments infrastructure, with Oak HC/FT as lead investor and the round value disclosed at US$48M. Toku is a non-bank PI/EMI-type operator, and the round is a discrete investment event within the trailing 12-month window. On partnerships, Mercado Pago Chile partnered with Fintoc to enable bank-transfer payments at checkout (reported Dec 2025); the deal value is not publicly disclosed. This A2A bank-transfer checkout integration advances pay-by-bank adoption against the card-dominant market, and as a partnership and restructuring event it is recorded here with its value flagged as not publicly disclosed. These commercial events are corroborated principally through a single aggregator for the Klap/Itaú and Mercado Pago/Fintoc items, and deal values and statuses (announced versus completed) are not independently confirmed; confidence is consequently held at the assessed level for these private-company and deal-announcement signals. #### Outlook The commercial layer is active. Bank-led consolidation of domestic acquirers, sizeable venture funding into recurring-payments infrastructure, and A2A checkout partnerships together signal an incumbent-and-challenger reconfiguration tracking the structural market opening. Private-company and deal-announcement signals remain an under-corroborated surface, and future cycles should seek independent confirmation of deal values and completion status. Periodic update · new data 2026-08-11 #### Commercial Intelligence & Fintech This cycle's Chile-specific commercial-intelligence signal is regulatory-architecture rather than a discrete deal event: no M&A, investment, or product-launch event was evidenced for Chile this cycle, and the material finding instead concerns how the country's virtual-asset-service-provider sector is structured for compliance purposes. VASPs operating in Chile must register with the CMF under Ley Fintec (Ley N21.521), submitting governance and corporate-structure documentation (Assessed confidence, Tier-4 secondary sourcing this cycle). This confirms that Chile's crypto-sector regulatory perimeter remains embedded within the general Ley Fintec CMF registration regime rather than governed by a dedicated, crypto-specific statute, a structural fact relevant to any commercial actor assessing the regulatory-compliance cost of entering the Chilean crypto or digital-asset market. Layered independently on top of this CMF registration requirement, the SII has since August 2025 imposed crypto-specific tax-reporting obligations on exchanges: Resoluciones Exentas N113 and N114 require crypto exchanges to report resident and non-resident client operations and wallet-level detail via forms DJ1963 and DJ1964 respectively (Assessed confidence, Tier-4 secondary sourcing this cycle). This tax-reporting layer is distinct from, and additional to, the CMF's prudential registration requirement, meaning a Chilean-operating crypto exchange faces two separate and independently administered compliance obligations: governance-and-structure disclosure to the CMF, and client-and-wallet-level tax reporting to the SII. For commercial-intelligence purposes, this bifurcated compliance stack is itself the notable structural fact this cycle: it indicates that Chile is regulating crypto-sector commercial activity through the accretion of separate agency-specific requirements rather than through a single consolidated crypto framework or licensing regime. Any commercial actor assessing market entry, partnership, or investment in a Chilean-operating VASP should factor in both compliance tracks independently, since satisfying CMF registration requirements does not address SII tax-reporting obligations and vice versa. The governance-and-structure documentation required for CMF VASP registration under Ley Fintec has not, in the evidence available this cycle, been disaggregated from the general registration architecture that also governs non-bank payment institutions more broadly; it remains unclear from current sourcing whether VASP registration is processed as a distinct CMF workstream or as a sub-category of the same registration apparatus. This is flagged as an open question rather than a settled structural fact, pending clearer primary-source disaggregation. From a commercial-intelligence perspective, the SII's DJ1963/DJ1964 wallet-and-client reporting requirement, in force since August 2025, is now the more mature of the two compliance obligations by tenure, having predated this cycle's other Chilean fintech developments by nearly a year. Its persistence without amendment or expansion this cycle suggests the tax-reporting framework has reached a stable operating state, in contrast to the CMF's open-finance framework, which has seen its effective date revised twice in the same period. Commercial actors evaluating the Chilean crypto and digital-asset sector for investment or partnership purposes should treat the current compliance architecture as reasonably settled at the CMF-registration and SII-tax-reporting layers specifically, even though neither layer amounts to a comprehensive, purpose-built crypto regulatory regime of the kind emerging in other jurisdictions; the absence of such a dedicated framework is itself a data point relevant to comparative market-attractiveness assessments, though no direct comparative claim was evidenced this cycle to support a cross-jurisdictional ranking. No disclosed or undisclosed commercial deal values, funding rounds, or product launches were evidenced for Chile this cycle; where the standard practice is to flag undisclosed deal values explicitly, no comparable data point exists this cycle to flag, and this absence itself should be read as a coverage gap rather than a finding of market inactivity. #### Outlook Watch for whether Chile moves toward consolidating VASP prudential and tax-reporting obligations into a more unified framework, or continues layering separate agency-specific requirements as it has to date. Watch also for the first discrete commercial event, M&A, investment, or product launch, involving a Chilean-operating VASP or payment institution, none of which was evidenced this cycle. A further open question is whether SII's DJ1963/DJ1964 reporting data, once aggregated, becomes a future source of Chilean crypto-sector activity metrics that could themselves become commercial-intelligence-relevant inputs in later cycles. **Sources and findings (4)** 1. T3 [https://miranda-intelligence.com/en/fintech-chatter/mexico-fintech-chatter-december-22-2025/](https://miranda-intelligence.com/en/fintech-chatter/mexico-fintech-chatter-december-22-2025/) retrieved 2026-06-27 2. T3 [https://www.fintechfutures.com/venture-capital-funding/toku-lands-48m-series-a-...](https://www.fintechfutures.com/venture-capital-funding/toku-lands-48m-series-a-...) 3. T3 [https://finance.yahoo.com/news/chile-cards-payments-market-...](https://finance.yahoo.com/news/chile-cards-payments-market-...) 4. T3 [https://miranda-intelligence.com/en/fintech-chatter/mexico-fintech-chatter-december-22-2025/](https://miranda-intelligence.com/en/fintech-chatter/mexico-fintech-chatter-december-22-2025/) retrieved 2026-06-27 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for Chile| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "prepaid_emoney": "licensed-emi", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 56 finding(s), 193 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).