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Your own license, as a service, or a path between the two.

To run Pix and Open Finance in Brazil, every company chooses between applying for its own license at the Central Bank or hiring an as-a-service provider. The two paths carry different costs, and they are not the only ones: infrastructure and license can come from different places.

Author
Bruno Cury, COO and Co-founder
Published
Oct 16, 2026

Your own license costs capital, time and risk.

Operating under your own license requires Central Bank authorization as a Payment Institution. The cost shows up on three fronts:

  • Capital. Between R$ 9.2 million and R$ 32.8 million in minimum capital, depending on the authorized activities (CMN/BCB Joint Resolution No. 14/2025), tied up before the operation even starts.
  • Time. Authorization takes 24–36 months. Only at the end of it does your company find out whether the thesis still holds.
  • Risk. Statutory directors are personally liable, with their name and tax ID, for the areas they sign for before the Central Bank, such as the ombudsman and cybersecurity, and the controlling shareholder answers for the institution. When a company operates under a third party's license, that risk stays with the license holder.

As a service costs dependency.

Hiring an as-a-service provider shortens the way in, makes cost predictable and transfers the regulatory risk. In exchange, your company comes to depend on:

  • the provider's roadmap;
  • support designed to serve every customer the same way;
  • availability that may not keep up with your operation;
  • a price that is hard to compare, because cost and margin sit with the provider.

This comes from the model, not from a provider's failure. For the Central Bank, every company operating under the provider's license is the provider's responsibility. To control that risk, the provider standardizes service, usage and processes, and serving hundreds of companies leads to a lowest common denominator.

The limit shows up as the operation grows.

Downtime, lack of customization, pricing and support that do not keep up with volume are the signs. At that point the choice seems to be between living with the limits or taking on the cost and risk of your own license. What the company needs, though, is what the license enables: operational freedom, customization, availability and control over its own service.

Cumbuca lived this as a customer. With more than 300,000 accounts on the platform, a provider announced it would stop serving the operation, after a Central Bank rule banned pooled accounts for some uses. The migration meant redoing, in record time, decisions that had been in place for months. Screens, experience and onboarding were ours. Margin, service quality and where the data went were not.

Infrastructure and license can come from different places.

Between renting a provider's platform and investing years and capital in a license, there is a journey. Each company enters at the point that fits where it is:

  1. An authorized institution's infrastructure. The operation starts on the infrastructure of an institution that is already authorized, with the Central Bank's official standard as the base.
  2. Your own infrastructure. Your company builds its own infrastructure in a segregated instance. Variable cost goes down, control of the architecture returns to your team and the operation's data stays with you. The regulatory layer remains on top.
  3. Your own license. If the service becomes essential to the business, your company applies for its own authorization. Since the integration uses the official APIs, there is no migration: you just switch the license that signs the requests.

“You stop pointing at our proxy and point at your own license.” Daniel Ruhman, Cumbuca's CEO.

Why companies leave shows whether the model is healthy.

When a company swaps its provider for its own license because the service got worse or the price became prohibitive, it is escaping the model. When it does so because the operation reached a scale where bringing the service in-house is the right call, the model did its job.

Without meaningful volume, your own license and your own infrastructure rarely pay off. If your company is close to tying up millions, or already depends on a roadmap it does not control, compare the three paths before deciding.

Want to run the numbers for your operation? Talk to Cumbuca.

Sources

About the author

Bruno Cury, COO and Co-founder · Cumbuca.

Ran customer service, ombudsman, KYC and growth for an operation with more than 1 million accounts, as a customer of Banking as a Service (BaaS) and Open Finance as a Service (OFaaS) providers. Knows firsthand the pain of buying solutions in this market.

Today leads sales and customer success at Cumbuca, solving those pains with our service.