Chile (CL)

Licensing, Authorisation & Market Access

Chile operates a deliberately dual-track non-bank payments licensing architecture, with no single unitary EMI licence. Banks access payment activity via the General Banking Law; non-bank operators must route through one of two distinct statutory channels. Ley 20.950 (2016) authorises non-bank entities to issue and operate stored-value payment means; issuers and operators must be Chilean sociedades anónimas with exclusive corporate purpose, governed by Banco Central rules under article 35 and subject to CMF supervision. Separately, Law 21.521 (published 4 Jan 2023, effective 3 Feb 2023) brought seven Title II financial-technology services into the CMF perimeter, requiring registration in the Registro de Prestadores de Servicios Financieros and, for several activities, prior CMF authorisation. This bank-versus-non-bank-PI/EMI distinction is structural: a bank PSP and a non-bank stored-value issuer face different statutory bases, different prudential anchors and different supervisory entry points, and an operator's structuring decision turns on which route fits its activity set.

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.

Scheme & Network Compliance

The Chilean card market is undergoing its most material economic reset in two decades, and this module is where that reset concentrates. The headline change is the interchange cap. An April decision capped interchange at 0.8% for credit and 0.35% for debit, effective October, expected to cut credit and debit interchange by roughly 46% and 42% respectively; the cap was set by the four-member Committee established under 2021 legislation. A reduction of this magnitude reshapes acquirer and issuer economics across the market and is the single most consequential pricing intervention in the current window.

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.

Correspondent Banking, Settlement & Access

The analytical spine of this module is the bank-versus-non-bank settlement-access asymmetry, and that asymmetry is precisely what is now being addressed. Settlement access in Chile is currently limited to banks, local CCPs and securities settlement systems, leaving non-bank financial entities dependent on bank intermediation to reach the high-value settlement layer. Under Ley 21.641 the BCCh opened a public consultation (Nov 2025) to regulate conditions for CMF-supervised credit cooperatives, securities custodians, low-value clearing houses and their non-bank participants, and recognised foreign CCPs to open BCCh accounts and pay directly via the LBTR; access is currently limited to banks, local CCPs and securities settlement systems, with differentiated timelines (12 months for high-value clearing houses) and no settlement guarantee.

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.

Conduct, Safeguarding & Financial Promotions

Customer-fund protection for non-bank payments operators in Chile rests on statutory segregation rather than deposit insurance, and this is the central conduct and safeguarding distinction between bank PSPs and non-bank PI/EMI operators. Under Ley 20.950 prepaid issuer funds received from the public may only be used for payments and refunds, must be accounted for and maintained segregated from the issuer's other operations, earn no interest for the holder, and cannot be attached or subjected to precautionary measures for the issuer's other obligations. This is statutory ring-fencing: customer funds are held segregated, used only for payments and refunds, and are non-attachable for the issuer's other debts. Critically, no deposit-protection scheme applies to non-bank issuers, so the protection posture for a non-bank prepaid customer is materially different from that of a bank depositor — segregation, not insurance, is the operative safeguard.

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.

Stablecoins & Digital Money

Chile's treatment of stablecoins as payment instruments sits at the boundary of two regulators. Under the Fintech Law, crypto assets, exchanges and intermediaries are regulated by the CMF, whereas stablecoins pegged to currencies are treated as a payment method and fall under BCCh regulation, provided they are issued in Chile by CMF-supervised entities. This local-issuance requirement is the analytically decisive feature: it creates difficulty regulating dominant global stablecoins such as USDC, because the framework anchors regulatory treatment to domestic issuance by supervised entities, leaving the largest global stablecoins outside the Chilean payment-rail perimeter. The stablecoin-as-payment-rail framework is still being built out via pending BCCh standards; the policy assignment of stablecoins to the BCCh perimeter exists, but no in-force domestic stablecoin issuance standard yet operationalises it.

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.

Operational Resilience & Critical Infrastructure

Chile's operational-resilience architecture for payments now rests on two coexisting layers: a cross-sectoral cybersecurity regime and a sectoral financial-supervisory one. Law 21.663 (promulgated Apr 2024) established the national cybersecurity institutionality, the ANCI agency with supervisory and sanctioning powers, and mandatory CSIRT incident reporting. Its entry into force was staged: most provisions applied from 1 Jan 2025, but Article 9 mandatory incident reporting, carrying a 3-hour initial alert, and the Title VII sanctions regime applied from 1 Mar 2025. Payments operators classed as essential services therefore face a 3-hour CSIRT alert obligation under the cross-sectoral regime, distinct from their sectoral duties.

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.

Payment Corridor Dynamics

Chile's domestic account-to-account infrastructure rests on a bank-operated rail rather than a central instant scheme. Chile's Transferencias en Línea (TEF) launched in 2008 as a bank account-to-account electronic transfer rail; Chile has no Pix/UPI-style central instant scheme but high digitisation, with nearly 70% of card payments on domestic schemes and wallets (MACH, Mercado Pago, Tenpo) projected to reach around 24% of in-person payments by 2030. The defining structural feature is the absence of a dedicated central instant scheme: the domestic A2A capability is delivered through the bank-operated TEF rail rather than a centrally governed real-time scheme on the Pix or UPI model.

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.

Industry Structure & Commercial Dynamics

The structural story in Chilean payments is the dismantling of a single-operator acquiring market. The acquiring market opened from a Transbank near-monopoly — around 98% in 2021, around 80% by end-2022, and projected below 70% — to a multi-acquirer model from 2020, with six acquirers operating, three more awaiting approval and around 20 PSPs competing. This is a structural competitive-landscape shift rather than a discrete commercial event: the erosion of Transbank's share is a market-architecture change, with the discrete deals that flow from it routed to the commercial-intelligence module.

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.

Legal & Litigation

The litigation thread that anchors Chilean payments reform runs through the Transbank antitrust and tariff saga. The Supreme Court ruling (Case 82.422-2021) overturned Transbank's self-regulated fee structure following a 2005 FNE complaint and antitrust finding of dominant-position abuse; the TDLC's ICG No.5 then imposed scheme-conduct remedies and recommended incorporating PSPs into the CMF's sectoral scope. This long-running litigation underpins the broader card-market reform agenda, connecting the antitrust finding against the incumbent acquirer to the scheme-conduct remedies and the proposed extension of supervisory perimeter over PSPs.

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.

Merchant Acquiring & Risk

Merchant-acquiring registration and risk graduation form a previously under-indexed surface now covered in the Chilean baseline. PSPs that settle to affiliated merchants must constitute themselves as Sub-acquiring Operators and registered Operators under Compendio III.J.2 and NCG 541, observe objective non-discriminatory contracting, and meet prudential thresholds graduated by payment volume; the TDLC required full cost disclosure to merchants and proportionate collateral on PSPs. This registration and risk-graduation regime is principally a non-bank PI/EMI matter: PSPs settling to affiliated merchants are pulled into a formal registration obligation and a prudential framework keyed to the volume of payments they process.

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.

Product Innovation & Market Development

The open-finance framework is the central product-access development in Chile, and its timeline has just shifted. CMF NCG 514 (3 July 2024) governs the Open Finance System under Title III, defining mandatory Information Provider and Account Provider Institutions and voluntary Information-Based Service Providers and Payment Initiation Service Providers (PISPs); CMF NCG 569 (issued June 2026) postponed SFA entry into force to July 2027, extending the implementation period from 24 to 36 months with greater graduality. The postponement is the live development: a delay from the original schedule to July 2027, lengthening the implementation runway by a full year. This is a regulatory product-access theme rather than a discrete commercial product launch, and it sits in this module rather than commercial intelligence accordingly.

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.

Consumer Protection & APP Fraud

Chile's card-fraud reimbursement regime is the local analogue to the international authorised-push-payment fraud debate, combining a fast statutory refund with a recent tightening against customer-side abuse. Ley 20.009 requires a fraud victim to be refunded or have unrecognised transactions cancelled within 5 working days for claims at or below 35 UF; Ley 21.673 (May 2024) strengthened banks' ability to contest 'autofraude' and placed more responsibility on customers through a sworn statement and criminal complaint, with CMF NCG 538 adding authentication requirements; SERNAC reported 19,834 fraud complaints in 2024, up 109% on 2023. The fast statutory refund — five working days for qualifying claims — establishes a strong consumer-protection baseline, while the Ley 21.673 anti-autofraude provisions rebalance the regime toward the bank where customer-side abuse is suspected.

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.

AML/CFT & Financial Crime

The AML/CFT surface for Chile is sourced from the Sentinel feed, and no original illicit-finance analysis is performed in this module. As carried from Sentinel: Ley 19.913 (in force 17 May 2004) created the UAF, Chile's FIU receiving suspicious-transaction reports (ROS); obliged informing entities include CMF Registry of Financial Service Providers registrants and PISPs, with KYC/CDD required for occasional transactions at or above USD 3,000; Chile is a GAFILAT member following the FATF risk-based approach and is not on the FATF strategic-deficiency list. The inclusion of PISPs among obliged informing entities is the point of direct intersection with the payments perimeter, bringing payment-initiation service providers into the AML/CFT reporting framework.

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.

Commercial Intelligence (M&A, Investment & Product)

Three discrete commercial events define the trailing-window commercial intelligence picture for Chile, each distinct from the structural market analysis carried elsewhere. On M&A, Chilean paytech Klap was acquired by Itaú Chile for US$43.7M (reported 16 Dec 2025) to strengthen its payments ecosystem. This is a bank-led consolidation of a domestic acquirer, signalling an incumbent response to the multi-acquirer market opening; as a specific announced deal it sits here rather than in the structural market-structure module. The deal value is publicly disclosed at US$43.7M, with Itaú Chile as acquirer and Klap as target.

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.