September 27, 2025
On September 2, 2025, the Board of Directors of the Central Bank of Paraguay approved Resolution No. 1/2025. The rule establishes the «Regulation on Transparency and Minimum Criteria for the Collection of Fees, Expenses, and Penalties in the Financial Sector,» taking immediate effect. Its scope covers all entities supervised by the Superintendency of Banks, including lending institutions, and repeals the previous regulation (Resolution No. 9, Minute No. 9 of March 7, 2024).
Among the key provisions, Article 4 mandates that all fees must correspond to a real, voluntarily requested service supported by a demonstrable cost. Furthermore, the rule prohibits charges for services considered «essential or inherent» to a product or service—those without which the main operation is not viable.
The regulation introduces a system of authorized denominations for all charges. To add concepts not listed in this system, entities must request technical approval from the Superintendency of Banks. Article 6 also requires that all contracts of adhesion receive prior «no-objection» from the Superintendency before implementation.
The regulation also governs unilateral contract modifications, requiring verifiable notice to the client 30 days in advance. It establishes the mandatory express consent of the client for services such as insurance contracts or credit line increases, eliminating tacit acceptance for such cases.
Overall, Resolution No. 1/2025 shifts the burden of justification for all charges to the financial entity. This framework compels institutions to review their fee schedules and product structures to align each charge with an authorized denomination and verifiable technical support. The prohibition on charging for «inherent» services requires a functional analysis to separate ancillary services from the essential components of each product. The «no-objection» requirement for contracts of adhesion introduces a new layer of prior regulatory control that redefines product launch cycles, demanding validation from the supervisor before market release.