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  1. Investigations, Compliance & Ethics
  2. Colombia: The Board of Directors of the Central Bank published the updated External Regulatory Circular DSP-465 of 2025 on interoperability of low-value immediate payments

Colombia: The Board of Directors of the Central Bank published the updated External Regulatory Circular DSP-465 of 2025 on interoperability of low-value immediate payments

20 May 2025    2 minute read
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In brief

On 6 May 2025 the Superintendence of Industry and Commerce (SIC), in its role as national authority for the protection of personal data, published a draft External Circular, which establishes specific guidelines for the processing of personal data in the Fintech ecosystem (the "Draft Circular"). This draft seeks to provide guidance to those data controllers for offering financial services through technological means on the legal obligations regarding the protection of personal data, in accordance with the provisions of Laws 1266 of 2008 and Law 1581 of 2012.


Contents

Key takeaways 

The following are the most important points modified in the updated Circular:

  • It is defined that Payment Orders and/or Immediate Transfers will be processed as Inter-SPBVI or Intra-SPBVI transactions, according to the information in the "SPBVI Recipient" field of the Centralized Directory.
  • It is clarified that the registration process for Keys used in person-to-person payments must be carried out directly and exclusively by the Client.
  • Participants are authorized, upon the beginning of the Operational Settlement Mechanism, to assign an alphanumeric key to their Clients' active Payment Methods for Person-to-Person Payments and to register said Key when any of the cases indicated in the Circular arise.
  • The Key used in Person-to-Person Payments that is canceled will be released for immediate reuse.
  • The following transition measures are established:
    • The definition of "Identifier" is included, according to which it is a key linked to a payment method for immediate payment services through an SPBVI, prior to the start of operation of the Centralized Directory, and that coincides with one of the Key types described in the Circular.
    • The registration of keys used in payments between persons must be carried out directly and exclusively by the Client, except for the registration of identifiers as alphanumeric Keys.
    • The registration of Identifiers as Keys is authorized in Phase 4 once the Centralized Directory is operational and in Phase 5 before the operational Settlement Mechanism is operational.
    • It is authorized that, upon the start of operation of the Centralized Directory, Participants may use all or some of the defined Key types to process Payments to Merchants.

Additional information

For more information, the Circular can be consulted at the following link. 

Please do not hesitate to contact us in case you have any questions or require our advice.

*****

Click here to read the Spanish version.

Contact Information
María Carolina Pardo Cuéllar
Partner
Bogota
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carolina.pardo@bakermckenzie.com
Angelica Navarro Acevedo
Partner
Bogota
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angelica.navarro@bakermckenzie.com
Ricardo Trejos Robledo
Partner
Bogota
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ricardo.trejos@bakermckenzie.com
Carlos Arboleda
Associate
Bogota
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carlos.arboleda@bakermckenzie.com
Julieth Sanclemente Perez
Associate
Bogota
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julieth.sanclemente@bakermckenzie.com

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