Banking; Fintechs | Brazilian Central Bank Regulates ‘Bank as a Service’ (BaaS): 8 Critical Points for Providers and Contracting Institutions
‘Bank as a Service’ (BaaS) in Brazil has just been redefined by the Brazilian Central Bank (Bacen). Joint Resolution No. 16, of November 28, 2025, re-establishes the BaaS model in Brazil, making it heavily regulated. See below 7 critical points for regulated institutions providing and receiving BaaS: 1. Scope of