The Brazilian retail sector is entering a new phase: the integration of financial services into the customer journey through embedded finance.
As the Central Bank’s regulation of Baas has progressed, retail companies have come to view credit, digital accounts, and payment methods as a strategic part of their business, rather than merely as ancillary services.
However, before any technological decision is made, there is a critical issue: the regulatory framework and compliance of the operation. Infrastructure serves as an enabler, ensuring execution, traceability, and adherence to the financial system.
With the rise of embedded finance and tokenization infrastructure gaining traction in the market, retail companies have come to view credit, digital accounts, and payment methods as a natural extension of their value proposition.
Esse movimento não é apenas tecnológico. Ele representa uma mudança estrutural na forma como o sistema financeiro é construído.
As non-financial companies begin to integrate financial services into their operations, the technological and institutional infrastructure that underpins these operations becomes a key factor in their viability.
Before selecting the infrastructure, it is essential that the operation be properly structured from a regulatory and compliance perspective.
Infrastructure serves as the layer that enables this framework, connecting technology, governance, and regulated entities, and allowing the model to operate within the requirements of the financial system.
Furthermore, the Central Bank’s recent regulation of BaaS has created a new landscape that requires strategic clarity before any operational steps are taken.
The key issue that drives executives and managers today is not is more whether retail should offer financial services, but yes how to do that in a sustainable way, compatible with the rules of the financial system and aligned with the operational capacity of each business.
This article addresses precisely that question, outlining the available models, their structural differences, and what is required to operate with institutional safety in this new regulatory environment.
What is embedded finance in retail?
For many years, credit and means of payment were viewed by retailers as ancillary services, outsourced to partner banks or financial institutions. This model worked as long as the customer experience was fragmented and technology did not allow for deeper integration.
The landscape has changed rapidly with the emergence of fintech companies, the rise of open finance, and the maturation of the API infrastructure in Brazil’s financial system.
From that point onward, retail companies with a large base of customers began to realize that the financial relationship with the consumer was a strategic asset being exploited by third parties.
Retailer-branded credit cards, instant credit at the point of purchase, and digital billing integrated into loyalty apps: all of these initiatives demonstrate how the industry has gradually incorporated financial products into the customer journey.
This trend has been given a name: embedded finance. And with it, the retail sector began to compete for a space that was previously exclusive to financial institutions traditional, not through the means of banking banking, but through the use of technological integrations with regulated providers which enabled this transaction on behalf of the retailer.
In this context, the infrastructure that connects retailers to the financial system has come to play a strategic role.
It is not just a matter of integrating payment or credit APIs, but of designing an architecture that combines technology, regulatory governance, and integration with agents authorized by the Central Bank.
It is precisely this layer of infrastructure that enables non-financial companies to offer financial products in a manner consistent with financial system regulations.
How does BaaS work in practice in Brazil?
The expansion of Banking as a Service has created a highly dynamic environment, but one marked by uncertainty as well.
Operational models were developed based on different interpretations of regulatory responsibilities, and it was not always clear who was actually responsible for granting credit, conducting risk analysis, and ensuring compliance with Central Bank regulations.
What is Banking as a Service (BaaS)?
BaaS enables companies to operate financial services using the infrastructure of authorized institutions.
However, regulatory responsibility remains with these institutions, and the viability of the operation depends on the quality of the infrastructure connecting all parties involved.
In practice, this means that non-banking companies can offer digital accounts, credit, or payment methods by using the regulated infrastructure of authorized institutions.
What has changed with the Central Bank’s regulation?
The publication of the Banking-as-a-Service Regulations [LINK TO THE ARTICLE “Banking-as-a-Service (BaaS) Regulations in Brazil: What Will Change with the Central Bank’s Stance?”] The Central Bank’s regulation of BaaS, particularly through Joint Resolution No. 16/2025, marked a milestone in the market’s maturation. By establishing clearer guidelines regarding the responsibilities of each party involved in a transaction, the Central Bank’s regulation of BaaS signaled that the sector’s growth needed to be accompanied by robust governance and institutional traceability.
For the retail sector, this development had a twofold effect. On the one hand, it provided greater legal certainty for companies that were already offering—or wished to offer—financial products. On the other hand, it raised the bar for the technological and contractual frameworks needed to support this type of operation.
This point is central. In modern embedded finance frameworks, the infrastructure is no longer merely a technological backbone but comes to represent the very institutional architecture of the operation.
It connects different segments of the financial market, such as technology, legal, compliance, regulated institutions, and fiduciary services, ensuring that every transaction has traceability, governance and compliance with regulations.
Without this foundation, retail banking initiatives may grow rapidly, but they ultimately face operational limitations or regulatory risks as they scale up.
Why did the Central Bank tighten credit rules?
The Brazilian financial system is based on a fundamental principle: only institutions authorized by the Central Bank may grant credit, raise funds and conduct certain financial transactions. This principle was not altered altered by regulation of the Baas by the Central Bank, but the proliferation of models of partnerships between retailers and fintechs created situations in which this line became blurred in practice.
The regulatory tightening It was introduced precisely to reaffirm that responsibility for granting credit and managing risk cannot be diluted through contractual structures lacking institutional backing. Those who grant credit must be authorized to do so, and those who distribute it must be clearly positioned as a channel, not as the credit decision-maker.
Which models allow retailers to offer financial services?
The future of retail lies in credit. But, within this new regulatory framework, the question that many managers ask is straightforward: how can I be a provider of financial solutions for my ecosystem of clients without creating a financial institution from scratch? There are three viable paths to operate in a sustainable manner.
Operating as a correspondent bank: the model with the least regulatory complexity
The banking correspondent model is the most established and accessible option for retailers looking to distribute financial products. Under this structure, the retailer acts as a distribution channel for an authorized financial institution, offering credit, insurance, or other products without assuming regulatory responsibility for the operation.
The advantage of this model lies in its simplicity of implementation. The regulatory complexity is low because the institutional responsibility remains with the financial partner institution.
However, this very characteristic represents a significant strategic limitation: the retailer has little autonomy over the rules of credit, the customer journey and the model for monetization. The financial experience, in this case, is built by the partner institution, not by the retailer.
Operate with Banking as a Service: autonomy without taking on the burden of regulation
The model of Banking as a Service enables the retailer to offer financial products under their own brand, controlling the customer experience and the credit strategy, supported by a provider of BaaS that has an financial institution authorized by the Central Bank.
This is the model that combines strategic autonomy with operational feasibility for most retailers.
The quality of the infrastructure used becomes a determining factor. The operation depends on an architecture capable of connecting the retailer to regulated institutions, compliance mechanisms, fiduciary services, and financial systems within the regulated ecosystem.
It is precisely this layer of infrastructure that enables companies to operate embedded finance with governance and traceability at the institutional level.
In this context, operating embedded finance in a sustainable manner requires an infrastructure market infrastructure capable of integrating technology, compliance, and regulated entities.
It is precisely this role that solutions such as the BLOCKBR Station fulfill, acting as an institutional layer that a21> enables the operation within the regulated environment.
Create a financial institution of its own: the path to greater autonomy
For retailers with a high volume of financial transactions, strong corporate governance, and a long-term vision, establishing their own financial institution—such as a Payment Institution, a Direct Credit Company, or a Credit, Financing, and Investment Company—may be the path to greater strategic autonomy.
This model offers complete control over credit policies, the customer experience, and financial operations governance. However, it requires directly assuming the full regulatory burden of the financial system, including minimum capital requirements, a compliance framework, reporting to the Central Bank, and authorization processes that can take months or years. It is a path recommended only for those with the institutional maturity to sustain it.
Banking correspondent, BaaS or digital infrastructure: Which model makes the most sense?
The choice between the three models should not be guided by the technological sophistication or by strategic ambition in isolation, but because of alignment between the model and the current reality of the business. Each structure has a profile of company for which it makes sense, and adopt a model more complex than which the capacity operational of the company supports may compromise the entire operation.
Below is a summary of the main differences between the three approaches:
- Correspondent Banking: low autonomy, low regulatory complexity, suitable for retailers in the early stages of financial integration.
- Banking as a Service (BaaS): Medium to high autonomy, indirect regulatory complexity; suitable for retailers with a well-established embedded finance strategy and a significant customer base.
- Financial Institution: complete autonomy, high regulatory complexity, and direct, suitable for large retailers with governance institutional mature.
The right question to ask isn’t which model is the best, but rather which model best aligns with your business’s current strategy, stage of maturity, and execution capabilities. The right technology allows you to choose autonomy without burdening yourself with bureaucracy that doesn’t make sense for your current situation.
Why has technological infrastructure become the central element of the model following the Central Bank’s regulation of Baas?
Offering financial products in the retail sector is not just a business decision. It is an operational architecture decision. The technological infrastructure chosen to support this operation directly determines the company’s ability to scale, maintain regulatory compliance, and evolve its model without having to rebuild everything from scratch every time regulations change.
In the context of digital assets and financial operations modern, market infrastructure means much more than just technology.
It involves the integration of financial systems, fiduciary services, compliance processes, governance mechanisms, and connections with regulated entities in the financial system. This combination is what enables digital financial transactions to operate with institutional security and traceability.
Governance, compliance, and operational execution
A financial operation within the retail sector requires multiple layers of governance that many companies underestimate at the outset. KYC and AML compliance, credit risk management, transaction traceability, and the segregation of duties between those who initiate and those who approve transactions: all of these elements must be in place from day one.
The operational execution of these structures requires control, governance, and traceability—a role fulfilled by solutions such as BLOCKBR Management, which organizes financial operations within an architecture compatible with the regulated system.
The importance of operating within frameworks compatible with the financial system
Integrating financial services into retail requires that the technological infrastructure be compatible with the systems and protocols of the Brazilian financial system. This includes integration with point-of-sale systems, clearinghouses, custodians, and fiduciaries. Systems built outside of this standard create operational friction, regulatory risk, and limitations on scalability.
BLOCKBR’s tokenization infrastructure was developed specifically to operate within this regulated ecosystem, enabling financial transactions to be structured with traceability, efficiency, and institutional compliance. This technological layer is what makes it possible for a retailer to offer its own private-label credit, for example, without having to build the entire financial architecture from scratch.
What infrastructure is needed to operate in compliance?
The rise of embedded finance and the Central Bank’s consolidation of BaaS regulations mark a new stage of maturity for the Brazilian financial market.
As retail companies begin to integrate financial products into their operations, the challenge is no longer merely technological or commercial. It becomes structural. Modern financial operations depend on infrastructures capable of connecting technology, governance, compliance, and regulated entities within a trustworthy institutional environment.
In this new landscape, the choice of infrastructure is no longer merely an operational decision but has become a key factor in the viability and governance of digital financial operations.
Companies that understand this shift are able to turn embedded finance into a strategic growth driver. Those that ignore this structural aspect, however, tend to face operational and regulatory constraints as their operations evolve.
BLOCKBR operates precisely at this intersection of technology, governance, and the digital financial market, providing the infrastructure needed to structure tokenized financial transactions that are integrated into the regulated financial system.
If your company is considering how to integrate financial services into its business model, the first step isn’t technology—it’s the structure.
Talk to the experts at BLOCKBR and learn how to ensure your operations run smoothly with the right infrastructure, compliance, and regulatory adherence.
