For many years, the pooled account was a practical solution for fintechs that needed to handle payments and balances for multiple users without relying on a more complex banking structure. It made it possible to launch products quickly, with less integration and lower upfront cost.
That context, however, has changed. What was once an operational choice has become a point of attention — first regulatory, then technical and, finally, strategic.
Today, replacing the pooled account is a direct response to a structural change in how the financial system is being built.
If you haven't yet taken a deeper look at this model, it's worth first understanding what a pooled account is and how it works.
The problem isn’t the model — it’s its limit.
The omnibus account solves a specific problem: simplifying resource management.
But as the operation grows, that same model begins to create friction.
The first sign appears in traceability. In an environment where funds are concentrated, clearly identifying who the ultimate owner of each amount begins to depend entirely on the company's internal system. This works while the operation is small. At scale, it becomes a risk.
The second point is operational. Court-ordered freezes, audits, or regulatory requirements do not align with the logic of an internal ledger. They are based on what is recorded in the formal financial system — not on what is inside the platform.
The third is strategic. Fintechs that start with an omnibus account often reach a point where they need to migrate, because the model limits expansion, partnerships, and even fundraising.
It is at that point that replacement ceases to be optional.
What’s changing in practice
The change is not happening in theory. It is already underway, driven by three main forces: regulation, technology, and operational efficiency.
On the regulatory side, there is a growing requirement for beneficial owner identification and greater transparency in transactions. This creates a direct misalignment with centralized structures.
On the technology side, the infrastructure has evolved. What once required heavy integration with banks can now be done via APIs, with the creation of individualized accounts at scale.
And on the economic side, the equation has changed. The cost of maintaining more sophisticated structures has fallen, while the cost of operating with risk has increased.
This combination is forcing a transition.
The new foundation: individualized accounts
The main market movement is the adoption of individualized accounts.
This does not just mean “opening one account per user.” It means that each client comes to have its own representation in the financial system, not just within the platform.
In practice, this completely changes the structure:
The money is no longer concentrated
Ownership becomes clear
Traceability no longer depends on an internal system
This change addresses exactly the points where the pooled account begins to fail.
👉 If you'd like to go deeper into this topic, we recommend reading What are the alternatives to a pooled account (and how to choose the best structure)
The role of infrastructure in this transition
This change doesn't happen just by product decision. It depends on infrastructure.
Creating individual accounts for thousands, or millions, of users requires:
Integration with financial institutions
Scaled account management
Balance and transaction control
Compliance mechanisms
This type of infrastructure was not available at an accessible level a few years ago. However, it is much more accessible today, and that is what makes replacing the model viable.
How Banking as a Service enables this change
Banking as a Service (BaaS) emerges as the layer that makes this transition possible without the company needing to become a bank.
With BaaS, it is possible:
Create individualized accounts via API
Operate financial transactions at scale
Maintain compliance with regulatory requirements
Integrate all of this directly into the product
This completely changes the starting point for a fintech. If the pooled account was once an “entry-level” solution, today many companies are already born with more robust structures from the start.
Data showing this change happening
This transition is not just a market perception; it appears in the data.
The use of new financial infrastructures based on digital assets and more efficient settlement has been growing consistently. Stablecoins, for example, already account for about 30% of total on-chain transaction volume, with accelerated year-over-year growth.
In addition, about 90% of financial institutions are already adopting or planning to adopt stablecoins as part of their payment infrastructure.
This indicates a clear shift: the infrastructure base is being redesigned.
And when infrastructure changes, operating models change along with it.
The direct impact for fintechs and platforms
For fintechs, marketplaces, and companies that operate digital accounts, this change has direct implications.
First, in how the product is structured. Models based on individualized accounts allow greater control and flexibility from the start.
Second, in the relationship with partners and regulators. More transparent structures reduce friction in integrations and audits.
Third, in the ability to scale. What once required restructuring is now ready from the start.
Replacing the pooled account is not just a technical decision
There is an important point that is often overlooked: this is not just an architectural decision. It is a positioning decision.
Companies that continue operating with centralized structures tend to carry more risk, more future complexity, and less predictability.
Companies that adopt individualized structures begin to operate closer to the standard the market is building.
Where is the market headed
The trend is not an immediate ban on the pooled account. It is a more gradual movement. The market is moving toward a standard with:
Ownership is clear
Traceability is built in
Infrastructure is programmable
Operation is scalable from the start
The pooled account was an important step in the evolution of fintechs. But, like many first-generation solutions, it is being replaced by something more robust.
What to do next
For companies that currently use this model, the first step is not necessarily to migrate immediately. It is to understand the role of infrastructure in the operation.
How the resources are structured
Where the risk lies
What happens when the operation scales
From there, the discussion is no longer “use a pooled account or not” and becomes: what is the most suitable structure for the future of the operation
If you need help deciding the most suitable structure for your operation, speak with an expert and see how to evolve your operation beyond the pooled account.
