Fintech 2026

PERU Trends and Developments Contributed by: Lisbeth Benavides and Antonella Tirado, Miranda & Amado

in a payment system or prominent payment agree - ment must obtain prior authorisation from the BCRP. The authorisation process requires submission of comprehensive documentation, including corporate information, business plans, financial statements, organisational structure, risk management policies, and operational details. ESPs that do not participate in payment systems or prominent payment agreements are only required to complete a registration process with the BCRP. Clarification of payment services and related concepts The new regulation provides much-needed clarity on the scope of regulated payment services. Under Article 32°, the following are expressly recognised as payment services: • execution of fund transfers; • issuance of payment instruments; • payment operation acquiring services; • execution of cross-border transfers; • fund collection services; • fund disbursement services; and • payment initiation, subject to future BCRP circu - lars. Perhaps more importantly, the regulation also clari - fies what does not constitute a payment service. Services linked to specific-use payment instruments – such as purchase cards, telephone cards, member - ship cards, public transportation cards, meal vouch - ers, and service vouchers – or those used in closed networks are excluded from the regulatory param - eter. This distinction is particularly relevant for fintech companies developing closed-loop payment solutions or limited-purpose instruments, as it allows them to operate without triggering registration or authorisa - tion requirements under the National Payment System framework. Phased implementation timeline The BCRP has established a phased implementation timeline for ESP authorisation, recognising the need for market participants to adapt to the new require - ments. ESPs participating in payment systems or prominent payment agreements are required to sub - mit their authorisation documentation according to a

schedule (ending on 31 December 2026), based on their average monthly transaction values in 2025 The regulation permits ESPs to continue their opera - tions while processing their authorisation or regis - tration applications, provided they comply with the established deadlines. The BCRP may also establish adaptation periods for ESPs that do not initially meet all requirements, subject to submission and approval of an adaptation plan with defined milestones. Cybersecurity and information security standards The new General Regulation of the National Payment System incorporates provisions on cybersecurity and information security that are essential for payments operators. The regulation expressly references the regulations applicable to the financial system regarding cyber - security and information security risk management. These standards have traditionally applied to banks and SBS-supervised entities, but ESPs and other pay - ment system participants must now comply with them as applicable. Market entrants will need to understand this highly technical regulatory framework and comply with its standards. This represents a significant chal - lenge for fintech companies and non-banking entities that may lack prior experience with prudential supervi - sion, requiring them to develop specialised capabili - ties and allocate resources to meet these compliance demands. Additionally, the BCRP recommends that regulated entities align their operations with international secu - rity standards, including ISO 27001, ISO 27002, ISO 27032, and PCI-DSS for card payments. Expansion of the Regulatory Sandbox SBS opens sandbox to non-regulated fintechs In November 2025, the SBS expanded the scope of Peru’s regulatory sandbox through Resolution SBS No 04142-2025. This resolution modifies the Regula - tion for the Temporary Conduct of Activities in Novel Models ( Reglamento para la Realización Temporal de Actividades en Modelos Novedosos ), originally approved by Resolution SBS No 2429-2021. The fun - damental innovation of this amendment is the exten - sion of sandbox participation to non-supervised legal

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