Fintech 2026

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

Central Bank Digital Currency Pilot The BCRP has been actively advancing its exploration of central bank digital currency (CBDC) through the Digital Money Innovation Pilot ( Piloto de Innovación con Dinero Digital ). The new General Regulation of the National Payment System explicitly provides that entities participating in such pilots are governed by specific circulars and subscription agreements rather than the general regulatory framework, providing flex - ibility for experimental initiatives. The pilot programme signals Peru’s commitment to exploring digital currencies issued by the central bank as a complement to existing payment instruments. This initiative aligns with global trends as central banks worldwide examine the potential of CBDCs to enhance payment system efficiency, promote financial inclusion, and maintain monetary sovereignty in an increasingly digital economy. Open Finance Roadmap: A Strategic Shift The SBS’s vision for open finance In February 2026, the SBS published its Open Finance Roadmap ( Hoja de Ruta Finanzas Abiertas ), establish - ing a strategic framework for implementing an open finance system in Peru. The roadmap recognises that in the digital economy, data has consolidated as a strategic asset for the development of more efficient, innovative, and user-centered financial services. Open finance is defined as a model that enables users to share their financial information – securely, in a standardised manner, and with their express consent – among different participants in the system, includ - ing financial companies, insurance companies, and pension fund managers. This approach expands upon the concept of open banking, placing the users at the center of the system by granting them control over the use and access of their data. The SBS’s stated vision is to consolidate an inclusive, competitive, innovative, and secure financial system based on the responsible exchange of users’ financial data, promoting user’s empowerment in the use and management of their financial information. The objectives of Peru’s open finance system include: • fostering competition and innovation;

• promoting financial inclusion; and • empowering users in the use and management of their data. The SBS has defined a gradual implementation approach through four phases: • Phase 1 (Diagnosis and baseline definition): This initial phase focuses on comprehensive analysis of the current regulatory framework, technological and operational capacity of entities, and market readiness for adopting a data-sharing model. • Phase 2 (Development of regulatory framework and technical specifications): This phase centers on defining the regulatory framework, governance scheme, and technical specifications necessary for system operation, including elaboration of Banking as a Service (BaaS) regulation. • Phase 3 (Gradual implementation of open banking): Beginning with adaptation to BaaS regulations, this phase focuses on developing capabilities for secure, consented information sharing. Implemen - tation will follow a progressive approach, starting with entities with greater market participation. The first group of data is expected to be enabled by late 2027 and the second by mid-2028. • Phase 4 (Consolidation of the Peruvian open finance model): This final phase marks the transi - tion from open banking to a broader open finance scheme, progressively expanding both the universe of participants and the scope of data subject to exchange. Implications for fintechs and non-regulated actors The open finance framework explicitly recognises the fundamental role that third-party providers, including fintechs, play within an open finance system. How - ever, the SBS acknowledges that these actors are not yet within its regulatory perimeter. During Phase 2, the SBS will evaluate the most appropriate mechanism to incorporate them in an orderly and gradual man - ner, ensuring they comply with required security and interoperability standards. This recognition represents a significant acknowledgment of the importance of collaboration between regulated financial institutions and innovative fintech players.

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