• The intense regulatory scrutiny of BaaS in 2024 highlighted weaknesses but left the sector better prepared for future growth.

• A shift in regulatory attitudes under the new administration suggests a less hostile environment for BaaS providers.

• Small banks face ongoing challenges due to resource constraints, delaying their ability to fully leverage BaaS opportunities.

• Collaboration between banks, fintechs, and regulators is crucial to ensuring BaaS remains a sustainable and secure financial model.

After a challenging year of heightened regulatory scrutiny, the outlook for banking-as-a-service (BaaS) in 2025 is showing signs of improvement.

While enforcement actions targeting BaaS providers surged in early 2024, the pace slowed considerably as banks, fintechs, and regulators gained a deeper understanding of the model, according to industry analysts.

BaaS enables nonbank companies, such as fintechs, to offer banking products by partnering with chartered banks.

Over the past few years, the model has faced increasing oversight, with regulators issuing formal and informal enforcement actions against banks that failed to meet compliance standards.

According to Konrad Alt, co-founder of the financial advisory firm Klaros Group, regulatory attitudes may be shifting with the turnover in the presidential administration.

While the policies of the new Trump administration remain uncertain, Alt noted, ‘the vibe is a lot less hostile,’ suggesting a more favorable environment for BaaS operations.

Enforcement Trends and Market Impact

Since 2020, regulators have issued approximately 42 formal enforcement actions against BaaS providers, with a similar number of informal actions likely. With only about 150 banks offering BaaS, the pool of targets for regulatory action is diminishing, Alt explained.

The intense regulatory cycle over the past two years addressed many of the BaaS sector’s weaknesses, leaving it better positioned for growth, according to James Stevens, a partner at Troutman Pepper Locke. “Banks that are already in the space and that are not held back by enforcement actions will generally increase their efforts in the space,” Stevens said in an email.

Challenges Persist

Despite the improving outlook, some banks in the BaaS sector still face hurdles. Many are small and resource-constrained, making it difficult to resolve ongoing enforcement actions.

These institutions may continue to struggle with compliance challenges, delaying their ability to fully capitalize on the sector’s growth potential.

“Those banks still have a lot of wood to chop even in a more positive environment,” Stevens noted.

The Path Forward

While regulatory scrutiny of BaaS will not disappear entirely, industry observers anticipate a more measured approach moving forward. Analysts expect the sector to avoid a repeat of the enforcement surge seen in early 2024, which was driven by regulators addressing weak compliance programs and bad actors within the industry.

As banks refine their operations and demonstrate stronger compliance practices, the sector could see renewed expansion.

For now, the future of BaaS appears brighter, offering opportunities for banks and fintechs to continue innovating while navigating a complex regulatory landscape.

This evolving environment underscores the importance of collaboration among banks, fintechs, and regulators to ensure that BaaS remains a sustainable and secure model for delivering financial services.