Alert
Banking and Finance - December 2025
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December 1, 2025
THE SUPERINTENDENCY OF BANKING, INSURANCE, AND PRIVATE PENSION FUND ADMINISTRATORS (“SBS”) MODIFIES THE REGULATION FOR THE TEMPORARY IMPLEMENTATION OF ACTIVITIES USING INNOVATIVE MODELS, APPROVED BY SBS RESOLUTION NO. 02429-2021 (“REGULATION”)
Through SBS Resolution No. 04142-2025, published in the Official Gazette El Peruano on November 24, 2025, the SBS approved the modification of the Regulation (the “Modification”), which implements the Fifth Supplementary Amendment Provision of Emergency Decree No. 013-2020. This provision empowers the SBS to authorize the temporary implementation of any operation or activity through innovative models, and may grant exceptions to applicable regulations. The Regulation establishes the regulatory framework for financial institutions and other organizations to develop, test, and validate innovative business models, products, or services in the financial sector.
The Modification primarily stipulates the following:
- Expansion of Eligible Entities. This includes legal entities established in Peru or abroad, not supervised by the SBS (Superintendency of Banking, Insurance and Private Pension Fund Administrators), as well as Regional or Provincial Associations of Funds against Traffic Accidents (AFOCAT) and Savings and Credit Cooperatives not authorized to operate with third parties, among the entities that may implement the aforementioned innovative models.
- Extension of Pilot Test Duration. The duration of pilot tests is extended from 12 to 18 months, and the renewal period for these tests is reduced from 24 to 12 months.
- Deadlines for the start of authorized pilot tests. Authorized pilot tests must begin within a maximum period of 6 months from their approval, extendable for an additional 6 month.
- Group Applications. It is stipulated that the new entities allowed to implement novel models, as well as the other permitted subjects, may also submit group applications for authorization, requiring for this purpose an agreement that establishes the conditions of participation of each entity in the application and eventual operation of the pilot test.
- Interaction with the SBS. It is established that, before submitting the authorization request, it is possible to request a meeting with the SBS to present the pilot project and receive information about the supervisor's expectations, requirements, procedures, general guidelines, evaluation criteria, and how the evaluation results will be communicated.
- Special Regime for Non-Supervised Entities. The regime that companies not supervised by the SBS must follow for the implementation of innovative models is included. The main provisions include the following:
- These companies may request regulatory flexibility or implementation if their operations are not covered by the current regulatory framework.
- These companies must comply with the general regulations established for obtaining the corresponding authorization.
- The SBS may exclude certain operations and/or activities for prudential reasons and/or due to the characteristics of the operation and/or activity.
- These companies must submit a sworn statement declaring their willingness to comply with the pilot program rules in accordance with the Regulations.
- Participation by these companies implies acceptance of special supervision and does not constitute authorization to operate in regulated systems.
- If a significant risk to the company or participants arises, the company must inform the SBS within the next business day.
- These companies must define policies and guidelines for conducting pilot tests.
- Additional requirements are established for these companies, such as: (i) moral integrity for directors and administrators; (ii) sufficient human, material, technological, and financial resources; and (iii) submit a declaration agreeing to comply with the provisions of the SBS and accepting that they may be subject to sanctions by it.The SBS has 60 business days to issue authorization.
- SBS Calls for Proposals. The SBS may issue calls for proposals to conduct pilot tests for the experimentation of innovative models that address an identified public interest, under one of the following two modalities: (i) open, for the participation of interested companies; or (ii) direct, with a direct invitation to one or more companies.
- SBS Participation in Pilots. Furthermore, it is established that the SBS may participate in the development of pilots with both supervised and non-supervised companies.