Costa Rica

Licensing, Authorisation & Market Access

Costa Rica's non-bank payments-licensing environment is advancing this cycle through administrative and regulatory clarification rather than primary legislation. BCCR created Resource Administration Accounts, CAR accounts, for non-bank payment service providers following resolution PGR-C-196-2024, giving non-bank PSPs a route to hold funds directly at the central bank in a manner distinct from the bank-account access that bank-affiliated PSPs already enjoy. This is a meaningful market-access development for the non-bank PI/EMI segment specifically, since it narrows part of the structural asymmetry between bank-affiliated and non-bank payment providers without requiring a change to the underlying statutory framework.

The more comprehensive vehicle for closing that asymmetry, the standalone Fintech Framework Bill, file 24.429, remains stalled. Introduced in July 2024 and unanimously approved by a legislative committee in April 2025, the bill has sat without further reported floor progress for more than fourteen months as of early 2026. This creates a structural gap: the bill would establish a comprehensive licensing and authorisation framework for the fintech sector, but in its absence, market access for non-bank PSPs continues to be built piecemeal through administrative measures like the CAR account mechanism rather than through a unified statutory regime.

The practical consequence for market entrants is that Costa Rica currently offers a workable, if incomplete, non-bank account-access route via CAR accounts, but lacks the comprehensive fintech licensing framework that the stalled bill would have provided. An operator assessing market access should treat the CAR account mechanism as the current operative pathway while treating the Fintech Framework Bill's eventual passage as a distinct, currently uncertain, horizon event rather than an imminent one.

Outlook

The key marker to watch is whether the Fintech Framework Bill breaks its fourteen-month floor stall in the second half of 2026. Absent that, expect continued incremental administrative measures in the CAR-account mould rather than a comprehensive statutory overhaul.

Stablecoins & Digital Money

Costa Rica has no dedicated stablecoin or digital-money regulatory framework. The central bank, BCCR, continues to treat crypto-assets and stablecoins as outside the scope of legal tender, with the colón remaining the sole official currency. Against that backdrop, the only concrete regulatory movement touching virtual assets this cycle is CONASSIF's public consultation on an implementing regulation for Ley 10961, the statute that inserted article 15 quater into the base AML law Ley 7786. This consultation is an AML-registration development, not a stablecoin issuance, reserve, or redemption framework: the reported draft would require virtual-asset service providers to register with SUGEF, apply client-identification measures above a reported USD 1,000 threshold for occasional transactions, and prohibit anonymous or fictitious-name accounts. None of this creates a stablecoin-specific legal category, reserve requirement, or redemption right.

For firms assessing Costa Rica as a market for stablecoin-linked products, the relevant takeaway is a negative one: there is no product-specific authorisation pathway to pursue beyond the general AML registration now attaching to virtual-asset activity broadly. A firm operating a stablecoin product in Costa Rica would need to register as a virtual-asset service provider with SUGEF once the implementing regulation is finalised, but this registration addresses money-laundering risk only and carries no implication for reserve adequacy, redemption guarantees, or consumer-facing product disclosures, none of which currently exist in Costa Rican law for stablecoin products specifically.

Outlook

The CONASSIF implementing regulation is anticipated within the fourth quarter of 2026 as scheduled, subject to a quarter-wide uncertainty band given that the timeline rests on secondary press reporting rather than a confirmed CONASSIF publication schedule. No dedicated stablecoin framework is signalled as under development; any future CONASSIF or BCCR move toward stablecoin-specific regulation would represent a distinct development from the current AML-registration consultation.

Payment Corridor Dynamics

SINPE Móvil, Costa Rica's instant-transfer system, has become the dominant domestic payments corridor, with adoption reaching over seventy-six percent of active adults by the end of 2024, up sharply from fifty-two percent just two years earlier. The system now spans forty-four participating entities, including nine non-bank payment service providers, reflecting a corridor that has broadened beyond the traditional banking sector to incorporate the non-bank PSP segment directly into the country's core instant-payments infrastructure.

That scale of adoption has a direct downside: SINPE Móvil is now the dominant vector for instant-transfer fraud in Costa Rica. The corridor's rapid growth has outpaced the development of a corresponding consumer-protection and liability framework, a dynamic explored further under Consumer Protection & APP Fraud. From a corridor-dynamics perspective, the participation of nine non-bank PSPs alongside banks within the same instant-payments rail is itself a structural feature worth tracking, since it means fraud-prevention and liability standards need to function consistently across both bank and non-bank participants rather than being calibrated to a bank-only rail.

Outlook

With adoption already above three-quarters of active adults, further corridor growth is likely to be incremental rather than transformative. The more material development to track is whether BCCR or another regulator introduces corridor-level fraud-control or liability standards specifically calibrated to SINPE Móvil's now-dominant role, particularly given its mixed bank/non-bank participant base.

Product Innovation & Market Development

SINPE Movil, the Banco Central de Costa Rica's instant-payment rail, is the dominant product-innovation story in Costa Rica's payments market, and its scale is now large enough to generate its own distinct risk profile. Over eighty percent of Costa Ricans aged fifteen and older are active users, and the rail processes more than sixty-five million transactions a month on 2025 data (wpm-2026-W32-005). This is not a new-product-launch story so much as a maturity story: an account-to-account instant-payment scheme that has moved from innovation to default national payment behaviour, correlating, per the underlying research, with reduced cash withdrawals and lower bank non-interest expense.

That scale has produced a fraud-typology surface commensurate with the rail's reach. SIM-recycling schemes locally described as comando PASE and WhatsApp verification-code takeover scams are reported to have driven 25,498 fraud complaints between 1 January 2025 and 30 March 2026, with instant-transfer fraud losses reported near three billion Costa Rican colones (wpm-2026-W32-006). This figure carries a Low-confidence rating in the underlying research and rests on a single Tier-4 aggregator source; no Tier-1 central-bank or supervisory publication of these statistics has been located this cycle, and the figures should be treated as indicative rather than confirmed pending independent verification.

The product-innovation and fraud dimensions are connected rather than separate stories: an instant-payment rail's core value proposition, speed and near-universal reach, is also what SIM-recycling and verification-code takeover typologies exploit, since both attack vectors depend on intercepting or redirecting the authentication step that authorises an instant, largely irreversible transfer. A rail's adoption success and its fraud-typology exposure tend to scale together, and SINPE Movil's trajectory this cycle illustrates that dynamic directly.

The specific mechanics reported, SIM-card recycling that allows a fraudster to regain control of a victim's mobile number, combined with WhatsApp verification-code interception, target the two-factor and device-binding assumptions that instant-payment authentication typically relies on. If accurate, the reported complaint volume implies an average of roughly nineteen complaints a day over the fifteen-month window covered, though this arithmetic derives from the aggregator figure rather than from any independently confirmed periodisation, and should be read with the same low-confidence caveat as the underlying statistic.

For a payments entrant assessing Costa Rica, SINPE Movil's ubiquity functions as both an opportunity and a constraint: any account-to-account or wallet-based product entering the market must interoperate with, or compete directly against, a rail that already reaches the overwhelming majority of the adult population, and adoption economics for a new instant-payment product in Costa Rica should be modelled against that existing baseline rather than against a green-field payments landscape. No new product launch, open-banking initiative, or BNPL-adjacent development was identified for Costa Rica this cycle; the product-innovation signal is confined to the fraud-typology growth layered onto SINPE Movil's existing, already-mature adoption base. This module's overall read for the cycle is therefore one of a mature, dominant product facing a scaling fraud challenge rather than a market awaiting its next payments-innovation launch.

Outlook

The central open question for this module is whether Tier-1 verification of the SINPE Movil fraud-loss and complaint figures becomes available, since the current Tier-4 sourcing significantly limits confidence in the scale of the problem. Watch also for any Banco Central de Costa Rica response, authentication-hardening measures, liability-allocation rules, or public-awareness campaigns, targeting the SIM-recycling and verification-code takeover typologies specifically, given the rail's near-universal reach makes any systemic control failure correspondingly consequential.

Consumer Protection & APP Fraud

SINPE Móvil fraud has escalated sharply in Costa Rica, with complaints totalling 25,498 between January 2025 and March 2026 and losses approaching three billion colones, an increase of roughly eighty-eight percent year over year. This volume of complaint growth sits against a consumer-protection framework that, on the evidence reviewed this cycle, includes no identified mandatory-reimbursement regime for authorised-push-payment-style fraud victims. Where a victim seeks redress through the courts rather than a regulatory or scheme-level reimbursement mechanism, the judiciary's average case timeline runs to roughly four years, a duration that functions as a practical barrier to recourse regardless of the merits of any individual claim.

The combination of rapid instant-payments adoption, documented under Payment Corridor Dynamics, and the absence of a fast, non-judicial reimbursement pathway is the structural consumer-protection gap this cycle's evidence surfaces most clearly. This is not a story of regulatory inaction in the licensing space, where BCCR has been administratively active via CAR accounts, but rather a gap specifically in the consumer-facing liability and redress framework that has not kept pace with the growth of the underlying payment rail.

Outlook

The clearest marker of regulatory response would be the introduction of a mandatory-reimbursement or fast-track dispute-resolution mechanism specifically for instant-transfer fraud. Given the scale and growth rate of complaints, continued absence of such a mechanism into the next cycle would itself be a notable finding, consistent with the enablement-as-signal principle: the absence of a consumer-protection response to a documented and escalating harm is itself informative.

Correspondent Banking, Settlement & Access

Costa Rica's settlement-access environment for virtual asset service providers tightened this cycle through a provision built directly into Law 7786, the country's foundational AML/CFT statute, as amended by Law 10961. The statute, retrieved directly from La Gaceta, Alcance N.246 78, published 19 June 2026, now bars SUGEF-regulated banks and financial intermediaries from maintaining commercial relationships with persons required to register under Articles 15, 15 bis, 15 ter or 15 quater of Law 7786 who have not duly registered with SUGEF. For VASPs specifically -- the population newly brought into scope by Article 15 quater -- this means that account access at any SUGEF-regulated bank is now contingent on SUGEF registration status, independent of any bank's own AML risk assessment of that counterparty.

This is a de-risking lever built into statute rather than a discretionary bank policy, which has a distinct practical effect: it removes individual-bank discretion over whether to maintain the relationship once non-registration is established, converting what might otherwise be a bank-by-bank risk decision into a uniform statutory bar. For PSP models operating in or into Costa Rica that rely on local banking relationships for settlement, the registration status of any VASP counterparty becomes a direct determinant of continued banking access, separate from the counterparty's substantive AML compliance history.

Outlook

The practical scope of this bar will sharpen once CONASSIF publishes its implementing regulation for the underlying VASP registration regime, expected around the fourth quarter of 2026. Until then, banks applying the bar do so against the bare statutory registration requirement, without further technical detail on thresholds or exclusions that might narrow or widen who falls within its reach.

Commercial Intelligence & Fintech

Jeeves, a stablecoin-card platform provider, announced a $110 million funding round alongside an expansion of its service footprint from twenty-five to thirty-five countries, naming Costa Rica among the new markets together with Argentina, the Dominican Republic, Guatemala, Panama, Peru, Paraguay and Uruguay. The announcement did not disclose a Costa Rica-specific allocation of the raised capital, nor any Costa Rica-specific commercial terms, partnership structure, or expected transaction volume. The event is recorded as announced rather than closed or operational, and should be read as an indication of market-entry intent and investor confidence in the broader Central/South American expansion strategy rather than as evidence of an operational Costa Rica product launch at this stage.

The entry is notable primarily for its timing relative to Costa Rica's regulatory environment: it proceeds without reliance on, or apparent dependency on, the CONASSIF AML-registration consultation currently underway for virtual-asset service providers. This suggests that commercial market-entry decisions for stablecoin-adjacent products in Costa Rica are not currently gated by the country's evolving VASP-AML perimeter, consistent with that perimeter being an AML/CFT compliance requirement rather than a market-access licence.

Outlook

Further disclosure of Costa Rica-specific terms, launch timing, or transaction volume for Jeeves' expansion has not surfaced. Any subsequent SUGEF registration by Jeeves or a Costa Rica-specific operating entity, once the CONASSIF implementing regulation is finalised, would be a distinct and separately trackable development from this commercial announcement.