NEW STANDARD
Getting Paid Better, Frictionless: Why Transfer-Based Collections Are Changing the Rules of the Game

National Payment System | This article aims to explain what CCT is, why it is relevant, and how approaches such as consent at origination can help make it more efficient and beneficial for all parties.

On March 2, 2026, Communication “A” 8406 of the BCRA was published, regulating, within the National Payment System, an adjustment to transfer-based collections (“CCT”).

This regulation mainly applies to non-financial credit providers (PNFCs) and financial institutions that grant loans to individuals.

This regulation and the developments being carried out by electronic payment transfer networks and payment scheme administrators respond to the fact that, for years, collecting loan installments in Argentina has been more difficult than it should have been. Poor interoperability, cumbersome user experiences, high costs, and, above all, increasing delinquency in recent years have exposed the limits of traditional schemes.

Against this backdrop, the Central Bank decided to organize the system and send a clear signal: transfer-based collections (CCT) become the new standard for recurring collections, starting with loan installments. This is not just a technical change—it is a shift in logic.

The underlying problem: collecting should not be so complicated

Credit has grown, but collection mechanisms have not kept pace. In practice, many models have faced the same obstacles:

Customers abandoning the process when giving consent.
Costly and slow integrations.
Lack of real interoperability between banks, fintechs, and PSPs.
Poorly distributed risks among stakeholders.
And, as a result, increasingly difficult levels of delinquency to manage.

Experience has shown that simply having a payment method available is not enough: if the experience is poor, collections fail.

What changes with transfer-based collections

With Communication “A” 8406, the BCRA establishes something very concrete:

Transfer-based collections are the only enabled modality for recurring collections using immediate transfers.
Their use will be mandatory for collecting loan installments.
The system is based on explicit consent, interoperability, and clear rules for all.

In other words, the multiplicity of schemes is left behind, and a unified framework is built with well-defined responsibilities.

How CCT works, simply explained

The scheme has three key moments:

1. Consent
   The customer explicitly authorizes a specific account to be debited for installment payments. This consent is:

• Clear
• Revocable
• Traceable

2. Disbursement
   In installment loans, funds are credited to the same account that will later be debited. This is not a minor detail: it ensures consistency, reduces disputes, and organizes the flow of funds.
3. Collection
   Each installment is collected according to the contract, with precise rules:

• One main attempt.
• Up to two retries.
• No reversals.
• Fraud liability clearly assigned to the lender.

The result is a predictable system, both for the collector and the payer.

The main bottleneck: the consent experience

One of the biggest problems with previous schemes was how consent was requested. Redirects, web views, multiple apps open, manual credential entry—all of this leads to abandonment and, consequently, lower collection effectiveness.

This is where the concept of consent at origination comes into play.

What does consent at origination propose?

The idea is simple: if the lender has already identified the customer, assessed the risk, and disbursed the loan, why force a complex experience at the moment of authorizing collections?

The consent-at-origination model proposes:

That the lender properly identifies the customer.
That consent is managed securely, without exposing credentials.
That validation ensures the loan was effectively credited.
That the customer can revoke consent at any time.
That friction from navigating between applications is eliminated.

All of this while remaining within the regulatory framework, maintaining explicit consent and required controls.

What is happening in the region: consent is increasingly given at the beginning

When looking at what is happening in other countries in the region, a clear pattern emerges: consent for collections is no longer requested every time a debit is executed, but instead is integrated at the beginning of the relationship between the customer and the service provider or lender. The logic is simple: if the relationship is well defined from the start, there is no need to recreate the entire authorization process month after month.

This shift is not driven by a technological trend, but by a concrete problem affecting all markets: friction kills collections. The more steps, screens, and validations placed between the customer and the payment, the higher the likelihood of abandonment, errors, or delinquency. That is why more modern systems are moving consent “backward” in the flow, placing it at the time of contracting.

(i) Brazil: single consent and collections that work.

The clearest case in the region is Brazil, with the implementation of Pix Automatic. There, the Central Bank designed a scheme in which the customer authorizes recurring payments once, at the time of contracting the service. From that initial authorization, collections are executed automatically, without the user having to intervene each month.

Importantly, this model does not remove control from the customer. Users can view scheduled debits, set limits, and revoke authorization whenever they want through their bank. But the experience becomes frictionless, and service providers can collect predictably.

The explicit objective of the Brazilian regulator was to eliminate the historical frictions of automatic debits and reduce delinquency without sacrificing security.

(ii) Chile: a well-known contractual logic.

Although Chile does not yet have a recurring immediate transfer scheme comparable to Pix or Argentina’s CCT, it has a strong tradition of consent at origination from a legal perspective. In many loans, the customer signs a payment mandate from the outset, authorizing the creditor to debit specific accounts according to the agreement.

In practice, this works as an advance declaration of will: the customer consents to the collection mechanism when entering into the loan, not at each due date. Operational risk lies with the creditor, and the scheme gains predictability. Although the infrastructure differs, the underlying logic is the same now being replicated in modern payment systems.

(iii) Colombia: fewer steps, more focus on the relationship.

In Colombia, the electronic payments ecosystem—particularly through PSE—also shows evolution in the same direction. Although there is not yet a fully formalized regime like Brazil’s, many recurring collection schemes rely on an initial customer authorization that identifies the merchant as recurring and reduces the steps required for subsequent payments.

Consent shifts from being transaction-by-transaction to being tied to the underlying commercial relationship, improving user experience and increasing effective collection rates.

(iv) A regional trend, not an Argentine exception.

Taken together, these experiences show that consent at origination is neither an anomaly nor an isolated “creative” solution. It is a logical and consistent response to the problems faced by recurring collection systems across the region.

In all cases, the same idea repeats: consent is integrated at the beginning, risk is assumed by the party originating the credit or service, and the customer always retains the ability to stay informed and revoke authorization. In this sense, Argentina’s transfer-based collection scheme, combined with consent-at-origination models, naturally aligns with a broader regional trend toward simpler, more predictable, and ultimately more human collections.

Clear risks, clear responsibilities

One of the major strengths of CCT is that it does not obscure risk:

There are no reversals.
Fraud is borne by the lender.
The acceptor must verify authorizations and consents.
The system prioritizes traceability and control.

Consent at origination is consistent with this logic: risk remains where it should always have been—on the party that decides to grant the loan.

More protection for the user

From the customer’s perspective, the new scheme improves several key aspects:

They know exactly which account will be debited.
They can revoke consent.
They receive prior information about collections.
They do not suffer unexpected or out-of-contract charges.

In terms of financial consumer protection, CCT is more transparent and fair than many previous mechanisms.

What this implies for organizations

Implementing CCT is not just a technical matter. It requires:

Regulatory and registration adjustments.
Review of contracts and terms.
Clear policies on fraud, collections, and customer service.
Controls over technology, security, and digital identification.

In our experience, the most successful projects are those that approach CCT as a comprehensive compliance and operations initiative, not as just another integration.

Conclusion

Transfer-based collections represent a new standard that organizes the payment system, improves user experience, and aligns incentives.

Consent-at-origination models, when properly implemented, enable this standard to work in practice: less friction, less abandonment, greater effectiveness, and better controls.

The challenge is not only to comply with regulation. The real challenge is to collect better—more simply, more securely, and more humanly.

Alejandro Emanuel de Dios MONTIEL
Partner at Integria Consulting – Correspondents of SMS Latin America
Expert in Financial Integrity and Payment Systems.