Latin America is scaling Open Finance fast. Europe already knows what happens when the infrastructure outpaces the regulation. The lesson is still relevant.

Brazil has 128 million active Open Finance consents as of December 2025. Chile enters mandatory implementation in April 2026. Colombia launched its interoperable Open Finance hub in 2025. Mexico passed its Fintech Law in 2018 and has been navigating regulatory gaps ever since. The infrastructure is being built across the region at different speeds and with different rules, and somewhere in the middle of all that fragmentation, a new type of player is quietly becoming essential. API aggregators, companies that merge dozens of bank APIs into a single unified interface, emerged as a practical solution to a real problem: connecting to every bank in a market individually is expensive, slow, and technically complex. For most fintechs, outsourcing that layer to a specialist made sense. What markets are now learning is that infrastructure decisions made for operational convenience tend to have structural consequences that nobody fully anticipated at the time.

Europe learned this the hard way. When PSD2 came into force in 2018, implementation was uneven. Some banks opened their APIs cleanly. Others imposed technical barriers that made direct access unreliable or prohibitively costly. Smaller fintechs, unable to maintain connections across dozens of banks in multiple countries, turned to aggregators like Plaid, TrueLayer, and Salt Edge. Those companies solved a genuine problem. They also accumulated something that nobody initially described as power: control over data flows, API connectivity standards, and in some cases, insight into the transaction behavior of every fintech routing through their infrastructure. My own research on European PayTechs, developed with the JRC of the European Commission, found that regulatory design directly shaped who received investment and who gained market access after PSD2. Aggregators were not a neutral layer. They became investors, partners, and in some markets, competitors to the fintechs they were serving. PSD3 and FIDA are now attempting to address governance gaps that the original framework did not anticipate. That process takes years.

Latin America is at an earlier stage, which means the decisions being made now, about which infrastructure providers to rely on, how to govern API access, and what standards to enforce, will define the competitive landscape for the next decade. The Sensedia 2026 State of Open Finance report shows that reliance on third-party infrastructure is already deep. Banco Rendimento routes over 80% of its transactions through a single provider. EBANX outsourced its entire Open Finance regulatory layer to manage ecosystem complexity. These are rational firm-level decisions. At the market level, they create concentration in a layer that regulators have not yet fully defined. Brazil is the most advanced market in the region and has the governance structures to manage this. The markets currently in early implementation, Chile, Colombia, Peru, and Mexico, are making those same infrastructure choices without the benefit of a mature regulatory framework to back them up.

This is not an argument against aggregators. They exist because regulation left room for them, and they solve a real problem for fintechs that cannot afford to build every connection from scratch. But infrastructure decisions made today for operational convenience tend to have competitive consequences tomorrow. Europe is writing new regulation to correct gaps it did not anticipate in 2018. Latin America is still early enough to ask the right questions before the market answers them on its own.