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Peru's e-money regime rests on Ley 29985 (2013), reserving e-money issuance to SBS-supervised EEDEs and multi-operation banks. From 1 April 2026 BCRP Circular 0022-2025-BCRP overlays a broader PSP taxonomy including a new non-SBS-supervised 'Entidad de Servicios de Pago' (ESP) category for fintechs, with tiered registration/authorisation pathways and phased adaptation deadlines to end-2026.
The defining development of this cycle is BCRP Circular No. 0022-2025-BCRP, the new General Regulations for the National Payments System, in force from 1 April 2026 and replacing the 2010-era Circular 012-2010-BCRP under Payments Law 29440 as amended by Legislative Decree 1665. It creates a four-category PSP taxonomy -- multi-operation companies, e-money issuers, Banco de la Nacion, and money-transfer companies -- plus a new non-SBS-supervised Entidad de Servicios de Pago (ESP) category built specifically for fintechs, with registration for ordinary payment agreements now available alongside the prior BCRP-authorisation track reserved for prominent payment systems. This is the first time Peru has created a payment-fintech licence tier that sits outside direct SBS prudential supervision, and it materially lowers the market-access threshold for smaller payment-services fintechs previously operating in a regulatory grey zone.
The new regime is not access-only, however: PSPs must implement transaction controls, retain information for five years, promptly inform clients, and communicate transfer completion, with non-compliance capable of drawing fines up to 20 UIT and suspension or revocation risk. This compliance-cost overlay applies specifically to nonbank PSPs newly brought into the perimeter, distinguishing the ESP's lighter registration bar from a lighter compliance bar.
Outlook
The PSP taxonomy's phased adaptation deadlines run through the end of 2026, meaning the practical contours of ESP registration, and the extent to which it genuinely lowers barriers versus simply relocating them, will only become clear as fintechs work through adaptation over the coming two quarters. The continuing pace of new EEDE authorisations suggests the pre-existing licensed non-bank track remains an active parallel route rather than one fintechs are abandoning in favour of ESP status.
Licensing, Authorisation & Market Access
Peru's national payments-system regulatory architecture has been substantially replaced this cycle. BCRP Circular 0022-2025-BCRP approved a new General Regulation for the National Payments System, in force since 1 April 2026, wholesale-replacing the prior Circular 012-2010-BCRP that had governed the sector for a decade and a half. The regulation is issued under the authority of Payments Law 29440 as amended by Legislative Decree 1665, giving it a statutory anchor distinct from a purely discretionary circular. This is a high-confidence, high-impact development sourced to a specialised Peruvian law-firm publication (Estudio Rodrigo), and it functions as the anchor instrument for several connected licensing and market-access changes landing in the same window.
The most consequential of the connected changes is a phased authorisation requirement for Electronic Service Providers (ESPs) that do not manage deposit accounts or issue e-money — a category distinct from banks and from licensed non-bank payment institutions and e-money institutions (PI/EMI). These ESPs must submit authorisation documentation on a schedule keyed to their 2025 average monthly transaction values, with the process required to complete by 31 December 2026. Critically, the regulation allows ESPs to continue operating while their applications are processed, avoiding a market-access cliff-edge; this is a source-corroborated, high-confidence finding (Chambers and Partners practice guide).
The second connected development is SBS Resolution 01747-2026, published 3 July 2026 in El Peruano, which establishes Peru's first express Banking-as-a-Service framework. The framework governs supervised BaaS providers that enable third parties — whether themselves supervised or not — to offer financial services via regulated digital infrastructure. This is a bank-and-nonbank-spanning instrument: the BaaS provider itself sits within SBS's supervisory perimeter, but the framework is explicitly designed to let both supervised and unsupervised third parties distribute financial services through that provider's regulated rails.
The bank-versus-non-bank distinction is explicit and material throughout this cluster of reforms. Banks already operating within SBS's prudential perimeter face the new payments-system regulation and the BaaS framework as extensions of an existing supervisory relationship; non-bank PI/EMI-type providers and the newly-defined ESP category face a more consequential shift, since for many of them this cycle's regulation is the first formal authorisation touchpoint with SBS at all. This asymmetry — incremental extension for banks, first-time formalisation for many non-banks — is the analytical spine of this module's read on Peru this cycle.
Outlook
The 31 December 2026 ESP authorisation deadline is the clearest near-term checkpoint: it will reveal how many previously informal or lightly-regulated electronic service providers complete formal authorisation, and conversely how many exit the market rather than complete the process. The BaaS framework is too new to have generated a first wave of registered providers within this cycle's evidence base; the next material checkpoint is the first cohort of SBS-supervised BaaS providers and clarity on how SBS intends to supervise, or disclaim responsibility for, the unsupervised third parties such providers may enable.
1 earlier distinct update(s)
Licensing, Authorisation & Market Access
Peru's core payments-regulatory framework was restructured this cycle by BCRP's new General Payments Regulation, issued under Circular Nº 0022-2025-BCRP and effective 1 April 2026, which replaces the central bank's 2010-era rulebook in its entirety. The most consequential structural change is the extension of BCRP authorisation to non-bank payment service providers performing acquiring, fund-disbursement, collection, and payment-initiation activities — functions that, prior to this cycle, operated in a comparatively unregulated or legally ambiguous space relative to bank-channel payment activity. The regulation applies a staggered compliance timeline: in-scope PSPs must complete authorisation by deadlines tiered according to monthly transaction volume, with the full compliance window running through the end of 2026. The finding is high-confidence, directly corroborated by a BCRP primary publication (the Reporte del Sistema Nacional de Pagos, March 2026) and independently corroborated by secondary industry and legal commentary describing the same instrument and effective date.
The bank-versus-non-bank distinction is the analytical spine of this development. Banks and other BCRP-supervised financial entities already operated within an existing prudential-authorisation perimeter; the substantive change this cycle is squarely on the non-bank side, where payment fintechs performing acquiring, disbursement, collection, or initiation functions move from an unregulated or ambiguously regulated position into a formal BCRP authorisation requirement — a status the evidence describes as ending the sector's prior legal-grey-area position. This is a market-access-defining change: any new non-bank entrant must now plan around BCRP authorisation as a gating requirement rather than a voluntary or informal registration, and existing non-bank PSPs must sequence their authorisation applications against the volume-tiered deadline structure to remain in continuous legal operation through the transition.
For market-access purposes, the practical effect is twofold. First, market entry for a new non-bank payment provider now runs through a defined BCRP authorisation process rather than through incorporation and informal market operation alone, raising the compliance bar for entry. Second, existing non-bank PSPs operating at higher monthly transaction volumes face nearer-term deadlines than smaller players, creating a de facto phased consolidation pressure across the non-bank segment.
Outlook
The compliance runway to monitor is the volume-tiered deadline structure itself: providers with higher monthly transaction volumes face nearer-term deadlines, and the full compliance window closes at the end of 2026. Confirmation of the primary full text of Circular Nº 0022-2025-BCRP — relied on this cycle through the BCRP's own periodic payments-system report and secondary legal commentary rather than direct retrieval of the circular itself — would strengthen confidence in the precise deadline tiers and any transitional provisions for PSPs already operating at the point the regulation took effect.
Sources and findings (6)
- T1https://www.bcrp.gob.pe/docs/Transparencia/Normas-Legales/ley-29985.pdfretrieved
- T3https://ally-law.com/fintech-regulation-guide-peru/retrieved
- T2https://www.estudiorodrigo.com/en/publications/fintech-alert-december-2025retrieved
- T3https://iupana.com/2026/02/09/psp-peru-nuevo-actor-regulado-carga-responsabilidades-alinearse-estandar-financiero/retrieved
- T2https://www.estudiorodrigo.com/en/publications/fintech-alert-december-2025retrieved
- T3https://hazlodigital.pe/dinero-electronico-que-son-las-eede-y-quien-lidera-este-ecosistema-de-pagos-digitales/retrieved