PERU Trends and Developments Contributed by: Lisbeth Benavides and Antonella Tirado, Miranda & Amado
Introduction The Peruvian fintech ecosystem has experienced remarkable growth and regulatory evolution through- out 2025 and into early 2026. This period has been characterised by significant legislative developments, the modernisation of the payment system infrastruc- ture, and the adoption of forward-thinking policies aimed at fostering innovation while ensuring finan - cial stability and consumer protection. The Central Reserve Bank of Peru (BCRP) and the Superintend - ency of Banking, Insurance, and Pension Fund Man - agers (SBS) have emerged as key actors in shaping a regulatory environment that seeks to balance innova- tion with prudential oversight. Peru’s fintech market continues to attract global attention as the country positions itself regionally as a key actor in payment services innovation. According to data from OSIPTEL’s Residential Survey of Telecommunications Services, as cited in the SBS’s Open Finance Roadmap (published in February 2026), as of year-end 2024, nearly 92% of Peruvian house - holds had access to mobile internet and smartphone penetration reached 95%, creating exceptionally favorable conditions for fintech adoption. Moreover, according to the SBS’s Open Finance Roadmap, dur - ing the first half of 2025 alone, Peru registered 6.644 billion digital transactions – a 61% increase compared to the same period in the previous year – underscor- ing the accelerating transformation of the digital pay- ments sector. This context undoubtedly demonstrates that Peru is well positioned to consolidate a more competitive, innovative, and inclusive financial eco - system through the recent regulatory developments described below. Modernisation of the National Payment System One of the most significant regulatory milestones of 2025 was the issuance of Circular No 0022-2025- BCRP in December 2025, which approved the new General Regulation of the National Payment System ( Reglamento General del Sistema Nacional de Pagos ). This regulation represents a comprehensive overhaul of the payment system framework, adapting Peru’s legal infrastructure to a rapidly evolving environment characterised by new payment instruments, digital channels, and the entry of new participants within the ecosystem.
The regulation was promulgated pursuant to Legis- lative Decree No 1665, which amended the Law on Payment and Securities Settlement Systems (Law No 29440), expanding the BCRP’s regulatory and super - visory powers. Article 10° of the Payment Law attrib - utes to the BCRP the authority to issue regulations, standards, mandates, and measures to ensure that the National Payment System operates securely, effi - ciently, interoperably, transparently, and in a manner that fosters competition and innovation. Cross border provision of payment services remains largely unregulated from a financial regulatory per - spective. This new regulation represents a significant step forward in providing regulatory clarity for Payment Service Providers (PSPs), particularly for the newly recognised category of Payment Service Entities ( Enti- dades de Servicios de Pago or ESPs). By establishing a defined authorisation and registration framework, the regulation creates a predictable pathway for fin - tech companies and non-banking entities seeking to participate in the National Payment System. How - ever, this clarity comes with a corresponding regu- latory burden: the detailed requirements for capital, documentation, risk management, and compliance will require market participants to carefully analyse and internalise the new rules. For entities currently operating in this space – or those seeking to enter it – the coming months will involve a period of regulatory digestion as they assess their obligations and adapt their operations to the new framework. Introduction of ESPs A central innovation introduced by the new regulation is the formal recognition and regulatory framework for ESPs. ESPs are defined as PSPs incorporated in Peru that are not authorised to offer deposit accounts or electronic money accounts by the competent author- ity. This new category creates a clear regulatory path- way for fintech companies and other non-banking entities seeking to participate in the National Payment System. The regulation establishes, among others, specific capital and net worth requirements for ESPs. ESPs wishing to operate as direct or indirect participants
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