PERU Trends and Developments Contributed by: Lisbeth Benavides and Antonella Tirado, Miranda & Amado
entities, that is, companies not currently under SBS supervision but proposing to develop innovative busi - ness models with potential application in the super - vised financial systems. This expansion aims to incentivise the participation of new actors in the financial innovation ecosystem, pro - mote competition, and strengthen financial inclusion through solutions that may eventually be incorporated into the existing regulatory and operational framework following appropriate evaluation and validation. Under the modified regulation, “non-supervised companies” are defined as legal entities incorporated in Peru, or foreign legal entities with legal representation in the country, that are not within the SBS’s supervisory scope but develop or propose to develop business models, products, or services with potential applica - tion in SBS-supervised systems. The amended sandbox regulation establishes com - prehensive procedures for non-supervised compa - nies wishing to participate in pilot tests. Key features include: • Duration: Pilot tests may last up to 18 months, with the possibility of a 12-month extension upon duly substantiated request, for a maximum total dura - tion of 30 months. • Authorisation Process: Non-supervised compa - nies must submit comprehensive documentation, including corporate documentation, evidence of the moral suitability of directors and officers, dem - onstration of sufficient human, material, techno - logical, and financial resources, detailed informa - tion about the proposed pilot, and a declaration to submit to the pilot’s rules and SBS supervision. • Consumer Protection: Each pilot test must incor - porate consumer protection measures, and participating companies must implement risk management policies and anti-money laundering/ counter-terrorism financing procedures. • Exit Planning: Companies must present exit plans contemplating controlled wind-down procedures, including timelines, activity schedules, account clo - sures, fund refunds, and payment of commitments to participants.
Furthermore, the SBS has empowered itself to direct - ly convene or participate in pilot tests of innovative business models that respond to identified public interests. The SBS may issue open or direct invita - tions to supervised and non-supervised companies to participate in such pilots and may itself participate when such intervention contributes to fulfilling regu - latory objectives. These pilots may include sharing public information or user data with prior consent, validating technical capabilities, security, or informa - tion exchange between systems, and exploring the use of emerging technologies. This active regulato - ry engagement represents a significant evolution in Peru’s approach to fintech innovation. While this expansion of the regulatory sandbox to rep - resents a significant advancement in terms of finan - cial innovation by providing a controlled space for conducting pilot tests of new activities, the consider - able regulatory burden associated with authorisation requirements could disincentivise the participation and success of fintech companies, particularly those in early stages of development. SMV’s sandbox initiative The capital markets regulator, the Superintendency of the Securities Market ( Superintendencia del Mercado de Valores or SMV), has also indicated its intention to explore sandbox mechanisms. In its Early Agenda 2026–2027 ( Agenda Temprana 2026–2027 ), published in January 2026, the SMV identified the evaluation of a regulatory sandbox as a priority initiative. The SMV recognises that financial innovation and the development of new business models linked to the securities market are advancing and generating chal - lenges for traditional regulatory frameworks. Financial technology, process digitalisation, new investment vehicles, and alternative financing models present relevant opportunities but also regulatory risks that require careful assessment before broader adop - tion. The SMV’s analysis will draw upon both local and international experience in sandbox implementa - tion, with the aim of creating a tool for controlled and supervised evaluation of innovative models without compromising market stability or investor protection.
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