Open Finance in Brazil: Which Opportunities Are You Missing

September 9, 2026

Summary: Open Finance has transformed financial data and payments into shared, regulated infrastructure. Understand the legal framework, the four phases, and where the real opportunities lie for those offering payments.

Introduction

If your company already offers payments, or is considering entering this market, Open Finance is not a compliance matter for next year. It is a structural change that redistributes who has access to financial data and who can initiate a payment directly from a customer's account, without relying on cards.

The point is simple: for decades, checking account, card, and credit data were locked inside each bank. Open Finance broke down this barrier by creating, under the coordination of the Central Bank, an ecosystem where the customer themselves authorizes the sharing of their data and the initiation of payments between institutions.

For managers and product teams, the question is no longer "is this going to happen?" but "what are we leaving on the table by not using this?". This post answers: what Open Finance is, how it was built in phases, and, above all, where the opportunities are for those working with payments.

Context: How Open Finance Was Born

The initial regulatory framework was Joint Resolution No. 1, of May 4, 2020, issued jointly by the National Monetary Council and the Central Bank of Brazil. It established the principle that underpins the entire system: data and service sharing is driven by customer consent. Nothing moves without the person or company expressly authorizing it, with a defined purpose and term.

The governance structure came soon after, with BCB Circular No. 4,032, of June 23, 2020, which organized the ecosystem into three levels: strategic, administrative, and technical. In practice, technical standards, security rules, and conflict resolution among participants follow a common model, not the goodwill of each institution.

In 2021, the project, initially named Open Banking, was renamed Open Finance, reflecting a broader ambition: to go beyond accounts and cards and encompass foreign exchange, investments, insurance, and pensions. Two years after its launch, the Central Bank reported that Open Finance already brought together around 15 million customers and an ecosystem with hundreds of participating institutions.

How the System Was Built: The Four Phases

Open Finance was not switched on all at once. It was implemented in four phases, each opening up a new layer of data or functionality:

Opening of institutions' data: The first phase released public, standardized data about the institutions themselves and their products, allowing structured comparison of offerings.
Customer and transactional data with consent: The second phase opened up what truly changes the game. With customer authorization, an institution can access their registration data and transaction history at another institution, providing a basis for personalization, fairer credit analysis, and real portability.
Payment initiation and credit proposals: The third phase enabled payment initiation, paying directly from a customer's account without using a card, and the forwarding of credit proposals. Here, Open Finance starts moving money, not just reading data.
Scope expansion: The fourth phase extended the ecosystem to foreign exchange, investments, insurance, and pensions, turning Open Banking into true Open Finance.

For those offering payments, phase 3 is the heart of the opportunity, but phases 2 and 4 open up revenue streams that many still ignore.

Where the Opportunities Are for Those Offering Payments

Translating the regulatory framework into business moves, three fronts stand out.

Payment initiation: pay without a card. With customer consent, a payment initiation provider triggers a transfer directly from the payer's account, typically via PIX, without intermediating the funds. For an e-commerce, marketplace, or SaaS, this means offering a checkout that dispenses with the traditional card brand and acquirer for some transactions. It is worth remembering: the payment initiation provider model always requires Central Bank authorization, regardless of volume.

Credit with real data. With transactional history shared by the customer themselves, it is possible to assess risk using true cash flow information, not just traditional credit bureaus. For those offering payments to merchants, this unlocks products such as receivables anticipation, working capital, and point-of-sale credit with better-controlled default rates.

Data as a product layer. The data-sharing phase enables experiences that were previously impossible: account aggregation, automatic reconciliation, product recommendations, and fraud prevention using signals from multiple institutions.

The common denominator of the three fronts is that they all require technical integration with ecosystem standards, certificates, and security requirements, and, in many cases, hold a regulated status before the Central Bank. It is precisely here that the decision between building from scratch and using ready-made infrastructure defines time to market.

Practical Application: Where to Start

Before investing, a honest diagnosis with this checklist is worthwhile:

Which front solves a real pain today? Reducing acceptance costs, improving credit granting, or enriching the product. Start with one, not all three.
What regulatory role is required? Being a payment initiator requires BCB authorization. Consuming data as a recipient has a different set of requirements.
Build or integrate? Implementing Open Finance APIs, certificates, and security controls from scratch is a long, costly project. A partner already operating within the ecosystem drastically shortens this path.
How does consent fit into the journey? The consent experience, transparent, reversible, and with explicit purpose, is part of the product, not a legal detail.

A point managers often underestimate: Open Finance directly integrates with PIX. Payment initiation uses the instant infrastructure as a settlement rail, so those who already master PIX are halfway there.

Next Steps

If you have made it this far, the recommended action is to choose one of the three fronts (initiation, credit, or data) and run a focused feasibility study, including the regulatory classification and the decision between building or using ready-made infrastructure.

In the next post, we look at a parallel and highly strategic move: the arrival of large Asian companies in the Brazilian payments market, and why payments are often the gateway to operating in Brazil.

Conclusion

Open Finance is not a distant promise: it is regulated infrastructure, in production, with millions of customers. The question is not whether it changes the payments game, but when your company will seize this opportunity. Plutech operates the technical and regulatory layer so you can launch products on Open Finance and PIX without building everything from scratch. Talk to our team and turn consent into revenue.