TikTok has applied to Brazil's central bank for two financial licences. The first would allow it to operate as an electronic money issuer, offering prepaid accounts that allow users to hold balances, receive funds, and make payments within the app. The second would classify it as a direct credit company, enabling TikTok to lend from its own capital or connect borrowers and lenders on its platform. If approved, TikTok would be able to offer a basic suite of financial services to its 131 million adult users in Brazil.
When I first wrote about TikTok and embedded finance in 2023 (EFR), the question was whether the platform was serious about financial services or just testing a wallet interface. A year later, TikTok partnered with Storfund to offer a cash advance product to sellers on its US marketplace (EFR). The Brazil licence application is the next step, and this time, TikTok is seeking its own regulatory standing rather than partnering with a third party.
The Super App Playbook
The approach TikTok is following in Brazil is familiar. WeChat built payments into its messaging platform in China and gradually expanded into lending and insurance. Grab in Southeast Asia started as a ride-hailing service and added financial services as it scaled. Both had the distribution first and added financial services on top. TikTok has the same starting position in Brazil, where ByteDance's Douyin Pay in China already demonstrated that the model works when the platform has enough daily active users.
What the Two Licences Would Enable
The EMI licence covers the payments and accounts layer. The direct credit company licence covers lending, either from TikTok's own balance sheet or by connecting borrowers with external lenders. Together, they would give TikTok the regulatory foundation for a basic financial services operation without a full banking licence. The applications are still pending and have not been officially confirmed by TikTok or Brazil's central bank.
My Comment
The question I asked in 2023 was whether TikTok was entering the embedded finance space. The answer is clearly yes. The more relevant question now is how far it intends to go and in which markets. The Indonesian experience, where TikTok was blocked from processing transactions directly and had to partner with GoTo instead, shows that regulatory approval is not guaranteed (GoTo). But the direction has been consistent across years and markets.
