December 19, 2025
Opening a digital bank from scratch seems "just" like creating an app with a balance on the screen. However, money requires rules, controls, partners, technology, and operations functioning. Therefore, when someone searches how to open a digital bank from scratch, the correct answer starts here: "digital bank" is the channel. The license and the regulatory framework may be different, depending on what you intend to offer.
Here is a practical step-by-step guide, from the framework to customer service.
Warning: educational content, it is not legal or regulatory advice. For formal decisions, involve specialists.
Understand what you want to build: bank, payment institution, or credit fintech
In common usage, "bank" has become synonymous with digital account. In practice, there are categories with different permissions and obligations. The Central Bank maintains authorization processes and acts of release for institutions of the National Financial System and the Brazilian Payment System.
Three categories cover most initial projects:
Payment institution (PI):
focuses on payment accounts and payment services. Resolution BCB No. 80/2021 regulates the constitution and functioning of payment institutions and addresses parameters for authorization requests.
Credit fintech (SCD or SEP):
if the core is credit, you enter SCD and SEP. Resolution CMN No. 5.050/2022 provides for the organization and functioning of these companies and regulates operations through electronic platforms, with the current version updated in 2025 in the BCB repository.
Bank (banking license):
tends to require more capital, governance, and time, but offers the broadest umbrella of products.
Choosing the wrong category is costly. You can have the best product in the world and still get stuck due to classification.
Four ways to launch without stumbling in regulation
Path 1: partnership with a regulated institution (BaaS or embedded finance)
You use the license and part of the regulatory infrastructure of a partner, focusing on brand, journey, distribution, support, and data. It is the quickest way to validate demand.
Point of attention: outsourcing the license does not outsource the reputation. Fraud and poor service turn into a brand crisis.
Path 2: becoming a payment institution
This makes sense when the focus is on accounts and payments. BCB Resolution No. 80/2021 is a central reference to understand the framework of payment institutions and the authorization process.
Path 3: becoming SCD or SEP
This makes sense when credit is the product. CMN Resolution No. 5,050/2022 organizes the functioning and what can be done by electronic platform.
Path 4: seeking a banking license
This is the most demanding way. It usually appears when the company already has scale, mature governance, and capital appetite to broaden its scope.
Value proposition: choose an audience and become indispensable
The market is crowded with "free accounts for everyone." This becomes a commodity.
A well-made cut accelerates everything:
• PJ and microenterprise: billing, reconciliation, card, cash management
• Freelancers: receiving, organization, and taxation without trauma
• Platforms: accounts and payments embedded in their own base
• Verticals: health, education, logistics, agribusiness
A strong proposal can fit into a sentence with a verb and metrics: “We help X reduce Y in Z.” If it can't be written like that, it's still a draft.
Real MVP: the first transaction and support working
MVP in finance is not a "registration screen." MVP is the smallest set that allows opening an account, depositing money, transferring money, and resolving issues when something goes wrong.
A realistic MVP to start:
• Onboarding with identity verification and anti-fraud validation
• Account with balance and statement
• Pix to send and receive
• Simple limits and notifications
• Support with refund, return, and blocking routines
Pix influences your architecture and your negotiations with partners. The Central Bank describes forms of participation and indicates that unauthorized payment institutions, if they are Pix participants, must be indirect participants of the SPI. This affects settlement, access to the DICT, and operational responsibilities.
Risk and compliance: the "invisible product" that keeps the company standing
Fintechs do not die only from lack of users. They die from fraud, poorly explained blocks, and chaotic operations.
Three pillars must exist before scaling acquisition:
Identity and Registration
• KYC and KYB with an auditable trail
• rules for repeated attempts and inconsistent data
• acceptance and rejection policy
Layered Fraud Prevention
• device and behavioral signals
• rules per transaction (amount, destination, time, pattern)
• human review at the start, to learn from real cases
Money Laundering Prevention
Transactional monitoring, alerts, and investigation. Even with a partner, you need to understand and explain movements to the client and to the regulator.
Technology: core banking, ledger, and reconciliation, without romanticizing.
The heart of the digital bank is the ledger, the reason that ensures that debits and credits always match.
Two approaches usually work:
Pre-built core with integrations and custom layers
You hire a core and build the experience, rules, and intelligence. Good for gaining speed.
Attention:
• limits of customization
• cost per transaction and per active account
• dependence on the supplier's roadmap
• quality of reports and reconciliation
Own ledger and pluggable services
You control the accounting heart and plug in Pix, cards, boletos, KYC, and anti-fraud measures. It gives freedom but requires a senior team.
In any model, do not give up on:
• daily reconciliation with alerts
• audit trail and logs
• availability monitoring
• secret management, encryption, and incident response
Operation and service: a bank is a factory of exceptions
When everything goes well, any app seems good. Quality shows up in the exceptions: wrong Pix, suspicion of fraud, disputes, payment slips that didn't clear, partial refunds.
Set up a back office with an internal panel from the beginning. It needs to be simple and efficient. Define SLAs, workflows, and who decides each type of case. The app is only half of the product. The other half is how you solve the problem.
Recipe model: two legs first, then acrobatics
Revenue in a digital bank usually comes from combinations such as:
• card margin (depending on your role)
• premium fees and services for legal entities
• credit
• financial management solutions for companies
Choose two sources for the first 18 to 24 months and model conservative scenarios. If you only close with five sources at the same time, the plan is too optimistic.
Metrics that show whether you are building a real bank
Product:
• activation: first transaction in 1, 7, and 30 days
• retention: how many transact monthly
• revenue per active user
• cost per service
Risk and operation:
• fraud per thousand accounts and per thousand transactions
• average resolution time
• chargeback and dispute rate (if card present)
• availability and incidents
Registration and download are vanity. Secure and recurring transactions are health.
Final checklist: how to open a digital bank from scratch without falling into traps
• Defined audience and measurable proposal
• Regulatory path or chosen partner
• MVP with Pix, limits, and support ready
• KYC, anti-fraud, and structured transactional monitoring
• Daily reconciliation and guaranteed audit trail
• Internal dashboard and exception processes defined
• Two planned revenue sources with conservative scenario
• Product, risk, and operation metrics monitored
Frequently asked questions
Do I need to be a bank to offer an account and Pix?
Not necessarily. Many people refer to any digital account as a "bank," but you can start with a payment institution or a regulated partner. BCB Resolution No. 80/2021 addresses the operation of payment institutions and the authorization pathway for this type of operation. For Pix, the form of participation (direct or indirect) depends on your classification and the arrangement with partners.
What is the difference between a payment institution and SCD or SEP?
In general, a payment institution is focused on payment services and transactional accounts. SCD and SEP fall within the universe of credit and loan intermediation through electronic platforms, with their own rules for organization and operation in CMN Resolution No. 5,050/2022. The practical point is: if you want credit as a central product, think early about compatible risk, funding, and governance.
Can I start as an indirect participant in Pix?
Yes. The Central Bank states that unauthorized institutions participating in Pix need to be indirect participants of the SPI. For startups, this is usually the most viable way to start, as it reduces technical and operational complexity while you validate the product and build risk and service capabilities.
