Regulatory advisory on Chile's Open Finance System (SFA) under the Fintec Law by Anguita Osorio.
NCG 514 readiness for banks, card issuers, cooperatives, insurers and fintech data consumers.
Open finance in Chile: what the SFA is and who must prepare
The Open Finance System turns customer financial data from a captive asset into a portable one: with the customer's consent, institutions must share it through standardized APIs. For incumbents it is a compliance and technology build with regulatory deadlines; for fintechs it is regulated access to the data their products need.
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This page covers the Open Finance System (SFA) created by Title III of Law 21.521: who participates and in which role, how customer consent works, the phased calendar of CMF rule NCG 514 and what each type of institution should be preparing. Deadlines cited reflect the rule as amended; always verify against the current CMF text.
The four roles of the system
The SFA assigns every participant one or more legal roles; obligations follow the role, not the industry label.
Information providers
Banks, card issuers and other entities holding customer data. They must expose APIs, answer authorized requests and carry the heaviest technical build, with the earliest deadlines.
Account providers
Entities offering sight or payment accounts from which payment initiation operates. Their APIs make third-party-initiated payments possible.
Information-based providers
Fintechs and others consuming SFA data to offer products: aggregation, scoring, advisory. They register with the CMF and must meet the system's security standards.
Payment initiators
Providers that, on the customer's instruction, initiate transfers from accounts they do not hold. A licensed activity with its own guarantees and obligations under the Fintec Law.
Consent is the axis
Nothing moves in the SFA without the customer’s express, purpose-specific and revocable consent. That design decision connects the system directly to the data-protection regime: participants must manage consent under NCG 514’s standards and, at the same time, comply with Law 21.719 for every personal-data operation, from lawful basis to security and breach reporting. Institutions preparing for the SFA and for the data law separately are building the same muscle twice.
The calendar: phased into 2027
NCG 514 was published on 3 July 2024 with a 24-month implementation. After a public consultation that drew over 400 comments, the CMF extended the phase-in to 36 months and added graduality by groups: large-scale information providers (banks, card issuers) go first, with preparation and sandbox connection stages, and cooperatives, insurers, fund managers and compensation funds follow. The operational start now points to 2027. Two practical consequences: the extension is build time, not waiting time, and the per-group dates must be read from the amended rule, not from the original one.
What to prepare, by type of institution
- Banks and card issuers: API build to the technical annex, consent management, traceability and the internal governance of who answers for the system.
- Cooperatives, insurers and fund managers: later deadlines, same build; the calendar rewards starting the inventory of exposed data early.
- Fintechs consuming data: CMF registration as an information-based provider, security standards, and a product design that survives consent revocation.
- Everyone: the Law 21.719 layer, because every SFA operation is also a personal-data operation.
Frequently asked questions
What is open finance in Chile?
The exchange of customers' financial information between institutions, with the customer's consent and through standardized interfaces (APIs). In Chile it is called the Open Finance System (Sistema de Finanzas Abiertas, SFA) and is created by Title III of Law 21.521 (Fintec Law). The detailed regulation is CMF General Rule (NCG) No. 514.
Who participates in the Open Finance System?
Four main roles: information-providing institutions (banks, card issuers and other entities that currently hold customer data), account-providing institutions, information-based service providers (which use the data to offer products, registered with the CMF) and payment-initiation service providers. The customer is the axis: nothing is shared without their express consent.
When does open finance start in Chile?
NCG 514 was published on 3 July 2024 with an original 24-month calendar. After public consultation, the CMF extended the phase-in: implementation now runs in stages into 2027, starting with the largest institutions (banks and card issuers) and later adding cooperatives, insurers and fund managers. The exact per-group calendar is in the rule and should be checked against the current version.
What does the SFA require from a bank or financial institution?
Exposing access interfaces (APIs) that meet the technical standards of the NCG 514 annex, managing customer consent and its revocation, implementing the security and traceability safeguards, and participating in the system directory. It is a compliance and technology project at once: the rule sets standards and outcomes, not just principles.
What does a fintech gain from the Open Finance System?
Regulated access to data only incumbents used to hold: account, product and transaction history of the authorizing customer. Aggregators, automated advisors, alternative scoring and payment initiation are built on that base. The counterpart is regulatory: information-based service providers must register with the CMF and meet the system's security standards.
How does the SFA relate to the Data Protection Law?
They are complementary frameworks. The SFA governs consented exchange of financial information within the CMF perimeter; Law 21.719 governs all personal-data processing and fully applies to system participants. An institution sharing or consuming data through the SFA needs both layers: the technical standards of NCG 514 and the lawful bases, duties and rights of the data law.
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