Chile

The most material recent development in this module is the introduction of a prior-notice duty for incumbents. NCG 559 (issued 9 Feb 2026, in force on that date) inserted Chapter X into NCG 502, establishing a prior-notice duty for traditional CMF-supervised providers offering Fintech Law services without separate registration, with a transitional reporting deadline of 30 April 2026 for entities already providing such services. This obligation applies to both bank and non-bank supervised entities, capturing traditional supervised firms that have begun offering fintech services under their existing authorisation. The near-term reporting trigger is a concrete compliance event rather than a standing structural feature, and it is the live deadline in the licensing layer for the current window.

The absence of a unitary EMI licence is the defining feature for any non-bank payments operator assessing market access. Where a single passport-style licence would consolidate authorisation, Chile instead requires the operator to map its activities onto the stored-value route, the Title II provider route, or both, with the registration and authorisation burden differing across activity types. This shapes entity structuring and the sequencing of market entry.

Outlook

The 30 April 2026 NCG 559 reporting deadline is the nearest operative trigger in this module and defines the immediate compliance timeline for traditional supervised providers. Beyond it, the dual-track architecture is established and stable, with the practical entry route for non-banks continuing to depend on whether activities fall under stored-value issuance or Title II provider registration.

The conduct overlay sits across both bank and non-bank financial products. Ley 20.555, the SERNAC Financiero statute, amended consumer-protection Law 19.496 to grant SERNAC financial-consumer powers and rights including the right to close a financial product within 10 days and a ban on tied sales of unrequested products and insurance. These conduct rights apply regardless of whether the provider is a bank or a non-bank, layering a financial-consumer-protection regime over the segregation framework. The combination determines how a non-bank operator must present, sell and unwind financial products, and where its customer-treatment obligations bite.

The analytical spine here is the divergence in fund-protection posture: a non-bank operator must communicate to its customers that protection arises from statutory segregation and non-attachability, not from any equivalent of deposit insurance, while simultaneously honouring the SERNAC conduct overlay that applies uniformly across product types.

Outlook

The safeguarding and conduct framework is established. The statutory segregation regime under Ley 20.950 and the SERNAC financial-consumer rights under Ley 20.555 are standing positions rather than developing items, and the operative conduct question for non-bank operators remains the clear communication of the segregation-versus-insurance distinction to customers.

On central bank digital currency, the BCCh's posture is exploratory and explicitly non-committal. From June 2025 the BCCh began a practical proof-of-concept exploration of a wholesale CBDC focused on DLT and settlement of tokenised assets, building internal capabilities; the bank explicitly states this is not a commitment to issue and that insufficient information exists for a definitive decision. The proof-of-concept is wholesale-focused, oriented toward settlement of tokenised assets rather than a retail digital currency, and the BCCh has been clear that capability-building does not imply issuance.

The illicit-finance dimension of stablecoin treatment — including any sanctions-evasion or de-risking significance of the local-issuance constraint — is a cross-monitor referral to FIM, not a conclusion drawn here. The WPM surface is the payment-instrument and payment-rail treatment alone.

Outlook

The stablecoin-as-payment framework remains pending, with no in-force domestic issuance standard from the BCCh and only the policy assignment of stablecoins to the BCCh perimeter in place. The wholesale CBDC proof-of-concept continues with no issuance commitment. Both threads are developing rather than settled, and the pending BCCh standards are the items to watch in the next window.

The sectoral layer sits alongside this. CMF RAN chapters 20-7 (outsourcing and cloud), 20-8 (operational incident information), 20-9 (business continuity) and 20-10 (information security and cybersecurity) set operational-resilience obligations for banks, bank-support companies and card issuers and operators, coexisting with the cross-sectoral Law 21.663 regime. These RAN obligations apply principally to bank PSPs and the card-issuance and operation ecosystem, whereas the Law 21.663 duties reach across sectors to any entity classed as an essential service, including non-bank payments operators.

The analytical spine is dual-regime harmonisation. A payments operator must reconcile sectoral CMF resilience duties with the cross-sectoral ANCI incident-reporting and sanctions regime, ensuring that its incident-response procedures satisfy both the CMF's operational-incident-information expectations and the 3-hour CSIRT alert obligation. The two regimes are not interchangeable, and the harmonisation burden falls on the operator.

Outlook

Law 21.663 is in force on a staged basis, with the incident-reporting and sanctions provisions effective since 1 Mar 2025, and the sectoral CMF RAN regime is stable. The forward question is operational rather than legislative: how payments operators harmonise their dual obligations in practice as ANCI's supervisory and sanctioning activity matures.

The cap sits on a foundation of scheme-conduct remedies. In ICG No.5 the competition court (TDLC) recognised Visa and Mastercard's dominant position and ordered public disclosure of interchange fees, removal of acquirer-licensing restrictions, no mandatory joint acceptance, and a temporary surcharging allowance pending interchange fees meeting the merchant-indifference 'tourist test'. These remedies target the two dominant schemes directly and aim at structural transparency and access, not merely price.

The participant architecture has also been reworked. CMF NCG 541 (published 23 July 2025, in force) amended non-bank card issuance and operation rules, created the 'Sub-Acquiring Operator' figure for entities settling 0.5%-1% of total payments, and strengthened contract, interoperability and oversight standards. This creates a graduated participant spectrum keyed to processed-payment volume, formalising a tier of non-bank PI/EMI operators below the full acquirer threshold. The bank-versus-non-bank distinction matters here: the interchange caps and TDLC remedies apply across bank and non-bank participants, while the Sub-Acquiring Operator figure is specifically a non-bank participant category.

Taken together, the interchange caps, the NCG 541 sub-acquiring registration regime and the TDLC ICG No.5 remedies compress acquirer and issuer margins and lower entry barriers simultaneously, accelerating the competitive reconfiguration already underway in the acquiring layer.

Outlook

The October interchange caps are the dominant forward event in this module, resetting card economics across the market. The TDLC ICG No.5 remedies remain in force and the NCG 541 sub-acquiring regime is established. The trajectory is escalating: the combination of margin compression and lowered entry barriers will continue to pressure incumbent scheme and acquirer economics through and beyond the October effective date.

This shapes both bank and non-bank participation. The A2A rail is a bank-anchored capability, and the wallet ecosystem — MACH, Mercado Pago and Tenpo — sits atop the digitised payments landscape, projected to take a meaningful share of in-person payments over the medium term. The high level of digitisation coexists with the structural gap of no central instant scheme, which distinguishes Chile from regional peers that have built centrally governed instant rails.

The absence of a dedicated instant scheme is recorded as not-applicable-in-regime rather than as a pending development, reflecting that the domestic instant-payment function is currently met through the TEF bank rail and wallet adoption rather than a central scheme in build.

Outlook

The corridor picture is stable. The TEF bank A2A rail remains the domestic transfer backbone, there is no central instant scheme in build, and wallet adoption is the principal medium-term variable, projected toward around 24% of in-person payments by 2030. Emerging-market rails and wallet adoption are lightly evidenced relative to card-market coverage, and remain a thinner surface in the current window.

The pace of erosion is material. A market that was effectively a near-monopoly in 2021 has, within a few years, moved to a multi-acquirer model with six operating acquirers, a further three in the approval queue, and around 20 PSPs in competition. The projected fall below 70% market share signals that the incumbent's dominance is no longer structural, and the opening creates room for new PSPs and acquirers to take volume.

The distinction between this module and commercial intelligence is important: the broad structural M&A and competitive trend lives here, while specific announced deals — such as bank-led acquisitions of domestic acquirers — are commercial events recorded separately. The structural reading is that the multi-acquirer model has fundamentally altered the competitive baseline of the Chilean card-acceptance market.

Outlook

The market structure is opening. Transbank's share is projected to continue falling below 70%, with three further acquirers awaiting approval and a competitive PSP layer already in place. The trajectory is one of continued fragmentation of a formerly concentrated market, with the interchange and scheme-conduct interventions in the scheme module amplifying the competitive pressure on incumbents.

The analytical significance is that the reform agenda in the scheme, acquiring and licensing modules is not free-standing regulatory initiative but is in substantial part the downstream consequence of litigation. The 2005 FNE complaint, the antitrust finding of dominant-position abuse, the Supreme Court overturning of the self-regulated fee structure, and the TDLC's subsequent remedies form a continuous thread that has shaped the contemporary structure of the card market. The recommendation to bring PSPs into the CMF's sectoral scope, flowing from the same litigation, connects the legal thread directly to the licensing and supervision perimeter.

This module establishes the litigation backdrop against which the interchange caps, sub-acquiring regime and scheme-conduct remedies should be read: each is, in part, a response to or continuation of the dominant-position findings against Transbank and the schemes.

Outlook

The Transbank antitrust and tariff thread is established as the foundational litigation underpinning the card-market reform agenda. The forward question is the degree to which the recommendation to incorporate PSPs into the CMF's sectoral scope is operationalised, carrying the litigation legacy into the supervisory perimeter.

The volume-graduated structure is the analytical spine. Rather than applying a uniform prudential burden, the regime scales obligations to processed-payment volume, with the Sub-acquiring Operator figure (under NCG 541, settling 0.5%-1% of total payments) sitting within a graduated participant spectrum. Objective, non-discriminatory contracting and proportionate collateral requirements aim to ensure that the entry of non-bank acquiring participants does not import unmanaged settlement risk into the merchant-acceptance chain.

The TDLC's transparency requirement — full cost disclosure to merchants — connects the merchant-acquiring risk framework to the broader scheme-conduct remedies, ensuring merchants can see the costs embedded in their acceptance arrangements. The proportionate-collateral requirement on PSPs is the risk-management counterpart to the market opening, calibrating prudential demands to participant scale.

Outlook

The merchant-acquiring registration and risk-graduation regime under Compendio III.J.2 and NCG 541 is established. The forward dynamic is the practical operation of the volume-graduated thresholds as more PSPs and Sub-acquiring Operators register and the multi-acquirer market continues to expand, testing whether the proportionate-collateral framework scales with the participant base.

The framework carries the bank-versus-non-bank dimension directly. Mandatory Information Provider and Account Provider Institution roles fall on incumbent institutions, while the voluntary Information-Based Service Provider and PISP roles are the market-access opening for non-banks. The postponement to July 2027 therefore shifts go-to-market timelines specifically for non-bank PISP entrants whose business models depend on payment-initiation access under the open-finance regime.

For market entrants the practical consequence is a deferred opportunity: the PISP and IBSP roles that operationalise non-bank participation in open finance now activate in July 2027 rather than on the original schedule, requiring entrants to re-plan their launch sequencing around the extended 36-month implementation period.

Outlook

The Open Finance System's entry into force is postponed to July 2027 via NCG 569, with implementation extended from 24 to 36 months. The trajectory is one of delay rather than retreat: the PISP and IBSP roles remain defined and will operationalise on the revised timeline, making July 2027 the operative date for non-bank open-finance market access. No formal regulatory sandbox accompanies the framework.

The regime applies across both bank and non-bank participants, with the reimbursement obligation and the authentication requirements under NCG 538 reaching the providers serving defrauded customers. The sharp rise in SERNAC fraud complaints — up 109% year-on-year in 2024 to 19,834 — is the pressure behind the legislative tightening, signalling escalating fraud volumes that the regime is attempting to manage without abandoning the fast-refund commitment.

The analytical tension is the balance between the fast statutory refund and the anti-autofraude rebalancing. The 2024 reform leans the regime back toward the provider where fraud is contested, requiring customers to substantiate claims through a sworn statement and criminal complaint, while NCG 538 raises the authentication bar that providers must meet.

Outlook

The trajectory is escalating, driven by rising fraud volumes. The Ley 20.009 fast-refund baseline coexists with the Ley 21.673 anti-autofraude tightening and the NCG 538 authentication requirements, and the year-on-year rise in complaints signals continued pressure on the regime. The forward question is how the rebalanced liability split operates in practice as fraud volumes stay elevated.

The perimeter spans both bank and non-bank participants. The obliged-entity definition reaching CMF Registry registrants and PISPs means that the AML/CFT framework follows the licensing perimeter into the non-bank payments space, with the USD 3,000 customer-due-diligence threshold for occasional transactions setting the operative trigger. Chile's GAFILAT membership and absence from the FATF strategic-deficiency list situate the jurisdiction within the international risk-based standard-setting framework.

Any original illicit-finance analysis — including the bank-versus-non-bank supervision gap, FATF mutual-evaluation status detail, or stablecoin sanctions-evasion significance — is a cross-monitor referral to FIM and is not developed here. The intelligence in this module is attributed to the Sentinel feed and links out accordingly; the AML/CFT surface for Chile should be sourced from the Sentinel and FIM feeds in subsequent cycles.

Outlook

The AML/CFT surface is stable as carried from Sentinel. The bank-versus-non-bank supervision gap and any FATF mutual-evaluation detail for Chile were not independently developed and should be sourced from the Sentinel/FIM feed next cycle. Original illicit-finance analysis remains a FIM referral rather than a WPM conclusion.

The significance is structural. Direct RTGS access for non-bank financial entities cuts dependency on bank settlement intermediation, removing a layer of credit risk and cost that currently sits between non-bank operators and final settlement. The consultation contemplates differentiated timelines — 12 months for high-value clearing houses — and explicitly carries no settlement guarantee, signalling a calibrated rather than wholesale opening of the access perimeter. This is a non-bank PI/EMI development at its core: the entities gaining contemplated direct access are precisely those currently obliged to route settlement through banks.

The asymmetry framing matters because correspondent banking and settlement access have historically reinforced bank intermediation as the only route to the RTGS layer. The Ley 21.641 consultation is the clearest near-term move to narrow that asymmetry, opening direct LBTR participation to a defined set of non-bank financial entities.

Outlook

The settlement-access regime is opening. The BCCh's Ley 21.641 consultation is expected to finalise across the second half of 2026, with differentiated timelines and no settlement guarantee shaping the eventual access framework. The forward question is the final scope of eligible non-bank entities and the pace at which direct RTGS access displaces bank-only settlement intermediation.

On investment, Chilean recurring-payments fintech Toku secured a US$48M Series A led by Oak HC/FT, described as the largest Series A by a woman-led Latin American fintech (reported May 2025). This sizeable Series A signals investor appetite for Chilean recurring-payments infrastructure, with Oak HC/FT as lead investor and the round value disclosed at US$48M. Toku is a non-bank PI/EMI-type operator, and the round is a discrete investment event within the trailing 12-month window.

On partnerships, Mercado Pago Chile partnered with Fintoc to enable bank-transfer payments at checkout (reported Dec 2025); the deal value is not publicly disclosed. This A2A bank-transfer checkout integration advances pay-by-bank adoption against the card-dominant market, and as a partnership and restructuring event it is recorded here with its value flagged as not publicly disclosed.

These commercial events are corroborated principally through a single aggregator for the Klap/Itaú and Mercado Pago/Fintoc items, and deal values and statuses (announced versus completed) are not independently confirmed; confidence is consequently held at the assessed level for these private-company and deal-announcement signals.

Outlook

The commercial layer is active. Bank-led consolidation of domestic acquirers, sizeable venture funding into recurring-payments infrastructure, and A2A checkout partnerships together signal an incumbent-and-challenger reconfiguration tracking the structural market opening. Private-company and deal-announcement signals remain an under-corroborated surface, and future cycles should seek independent confirmation of deal values and completion status.