The Dependence on Banking as a Service in White Label Fintechs: Impacts on Security and Operational Continuity in Brazil (Revista Tópicos.)

Summary

• A study recorded 3,069 fintechs in Latin America and the Caribbean at the end of 2023, up from 703 in 2017.p.5
• Brazil, Mexico, and Colombia together accounted for 57% of mapped fintech companies in the Latin America and Caribbean region.p.5
• The narrative literature review prioritized publications from 2024 and 2025 to evaluate BaaS dependencies in Brazilian white label fintechs.p.2
• The discussion organizes BaaS dependency analysis across 4 main dimensions: technology configuration, security, governance, and operational continuity.p.14

Key insights

1. Combining white label models with Banking as a Service creates critical technological dependencies that directly impact information security and operational continuity.p.2
2. White label fintech setups allow companies to offer financial products under their own brand without transferring regulatory authorization or operational responsibilities.p.4
3. Open Finance and BaaS both rely on API integrations but differ fundamentally, as Open Finance shares ecosystem data while BaaS delivers infrastructure capabilities.p.5
4. Under Brazil's LGPD, outsourcing infrastructure to a BaaS provider does not eliminate data protection liabilities for participating entities.p.11
5. Concentration on a single BaaS provider creates systemic vulnerability, where an outage at one provider can propagate across multiple white label fintechs.p.11
6. Adopting multi-provider BaaS architecture can mitigate vendor concentration but does not guarantee automatic failover without technical and regulatory alignment.p.16
7. Governance strategies require verifiable Service Level Agreements (SLAs) that specify strict metrics for incident detection, response, and service restoration.p.16