In BaaS, Partner Operations Become Issuer-Level Network Risk

In BaaS, a partner’s ops can become an issuer-level network(scheme) compliance problem.

I was speaking recently with a large issuer and BIN sponsor about how network compliance is changing in BaaS. Most banks already know a single program can create outsized risk.

What’s changed is the scale and speed, because performance is increasingly assessed at the issuer level. Visa’s Issuer Monitoring Program (VIMP) makes that real for a lot of teams.

For example, in a BaaS model, fraud and disputes don’t stay contained; they roll up across the book. So one fintech’s operational gaps can affect every program under the same license.

The hard part isn’t agreeing on compliance. It’s the operational burden:
- getting every partner the latest requirements
- chasing status on who implemented what (and when)
- having evidence you can actually rely on

Trying to run that through email threads, shared folders, and periodic check-ins is starting to break. Those tools capture communication, not control.

One issuer put it in a way that finally landed with leadership: traditional issuing is one perimeter. BaaS is many moving perimeters tied to the same license.

BaaS will keep growing, and network expectations will keep tightening.