Banking as a Service (BaaS) is one of the most innovative models in the financial sector. Under this scheme, fintech companies offer financial products such as accounts, cards, or loans, using a bank’s infrastructure and license. We can say that it is a form of “regulated outsourcing” that allows new players to enter the market without becoming banks, while traditional institutions expand their reach through digital platforms.
In Honduras, where financial inclusion remains a challenge, BaaS could act as a bridge between traditional banking and the unbanked population. Through low-cost apps and digital solutions, it would be possible to expand access to savings, credit, or insurance products, bringing the financial system closer to historically excluded sectors.
Like any idea, this one poses challenges, the main one being supervision, which raises the following question: should a fintech company that uses BaaS be supervised with the same rigor as a bank? If we adhere to the principle of permission, no; however, the conservative stance of regulators and the ambiguity surrounding these issues have led to the same regulations being applied to both traditional banking institutions and fintech companies.
Adopting this model presents risks, the main one being the lack of regulatory clarity. What happens in the event of a technological failure that affects users? Who is liable in cases of breach of contract or fraud? For now, Honduran regulations do not offer clear answers.
In this context, the National Banking and Insurance Commission (CNBS) has a key role to play. Until now, regulations have been established to supervise cooperatives and banks, without taking into account technological integration systems. However, with the development of fintech, there is a need for traditional banking and its regulations to evolve in order to obtain better results from partnerships and market developments.
The implementation of BaaS also requires improvements to the technological infrastructure of banks in Honduras. Although some institutions have made progress in digitization, most continue to use rigid platforms, which complicates integration with third parties. Therefore, the model would lack viability if there is no investment in interoperability, data management, and cybersecurity.
However, regional experience provides learning opportunities. In Brazil, the fintech ecosystem has experienced growth alongside BaaS schemes, which have enabled the emergence of new players such as Nubank. This has occurred under the supervision of a dynamic legal framework. Mexico’s Fintech Law, which regulates banks and financial technology institutions, has also made progress. Honduras has the potential to apply these practices, considering its level of technological maturity and institutional context.
In summary, for banking in Honduras, Banking as a Service represents a tactical opportunity. It has the potential to stimulate innovation, democratize access to the financial system, and activate the market. However, it needs a competitive and contemporary regulatory framework for each participant, investments in technology, and updated supervision that encourages investment and competition without compromising security. If these factors coincide, BaaS has the potential to be an essential component in the country’s digital banking transformation.