CMF 对未在登记簿注册而提供金融科技服务的金融实体课以信息披露义务 — Cubillos Lama
Regulatory

CMF 对未在登记簿注册而提供金融科技服务的金融实体课以信息披露义务

2026年2月9日公布的第559号一般性规则(NCG 559)为受 CMF 监管、希望依据第21.521号法律第5条提供受规制金融科技服务而未在登记簿注册的实体增设了信息披露义务;其须在开展业务前通过 CMF Supervisa 通知 CMF,无需事先授权,若已在运营则须在2026年4月30日前合规。然而,在 CMF 出台具体规章之前,银行不得依据第5条第7项提供服务,这为满足通知要求的非银行实体开辟了机会。

Regulatory2026-02-18更新日期:2026-06-25作者: Jorge Lama Navarro
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NCG No. 559, published by the Financial Market Commission (CMF) on February 9, 2026, incorporates a new Chapter X into NCG No. 502. The regulation creates a disclosure duty — not an authorization requirement — for supervised entities that wish to offer services regulated by Article 5 of Law 21,521 (Fintec Law) without enrolling in the Financial Services Provider Registry. For those already operating, the deadline expires on April 30, 2026.

What changed

Until the publication of NCG No. 559, CMF-supervised entities providing services contemplated in Article 5 of the Fintec Law — crowdfunding platforms, alternative transaction systems, automated credit or investment advisory, financial instrument custody, among others — could do so under their general regulatory framework, without a specific communication mechanism to the regulator.

The new regulation introduces a concrete obligation. Before beginning to provide any of those services, the entity must notify the CMF through the CMF Supervisa platform, specifying in detail the services it plans to offer. No prior authorization or Registry enrollment is required.

The universe of affected entities is broad: securities intermediaries, commodity exchanges, commodity brokers, general fund administrators, portfolio managers, risk rating agencies, insurance and reinsurance companies, and any other CMF-supervised entity that develops activities under Article 5.

For banks, NCG No. 559 establishes a different rule. The services described in Article 5(7)(2) of the Fintec Law, insofar as they are not covered by the General Banking Law, will be subject to specific regulation that the CMF has not yet issued. Until that regulation exists, banks cannot provide such services. The regulation took effect on the day of its publication, February 9, 2026.

What this could mean for your company

If your company is a CMF-supervised entity and already offers — or plans to offer — any of the Fintec catalog services, you have an immediate operational obligation: notify the regulator before operating.

The mechanism is lightweight. There is no prior authorization process, no additional fitness assessment, no regulatory waiting period. The CMF opted for a notification model, not a licensing one. But the relevant point is different: failure to comply with this obligation may result in observations, requirements, or sanctioning proceedings under the CMF's general supervisory regime.

The deadline is the urgent point. If your company already provides any of these services as of the regulation's publication date, you have until April 30, 2026, to comply with the disclosure duty. If you have not yet begun, you must notify before starting the activity.

There is a nuance worth noting in the banking perimeter. The special rule for banks regarding Article 5(7) creates a transitional exclusion zone: until the CMF issues specific regulations, those services are off-limits for banks. This may open a competitive window for non-bank entities that timely comply with the notification duty.

What you can do

  1. Review whether your operation includes Fintec services. Compare your current activities against the Article 5 catalog of Law 21,521. If the answer is yes, initiate the notification process with the CMF through the CMF Supervisa platform before April 30, 2026.
  2. Audit services you may not have categorized as Fintec. NCG No. 559 did not create new services; it made the disclosure obligation explicit. Digital products you have been offering under your general framework may be covered.
  3. If you are a bank, confirm with your legal team the scope of Article 5(7). If any of your digital services falls within that category, the provision is suspended until the CMF publishes specific regulation.

If you need to assess whether your operation is covered by NCG No. 559 or prepare the CMF notification, schedule a consultation with our team.

This content is for informational purposes only and does not constitute legal advice for any specific case.

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