.svg)
The second Trump administration is emphasizing innovation and fair access in the US financial system, with federal agencies and state regulators providing new pathways for non-banks to participate in traditional banking.
Fintechs, payments companies and digital asset providers are set to seek direct access to US financial networks during 2026 via special-purpose bank charters or state licences that allow them to operate on traditional banking rails without becoming full-service, federally regulated banks.
This shift has the potential to lower operating costs, accelerate product rollouts and reshape competitive dynamics, but it also increases regulatory scrutiny and operational expectations for firms entering the banking system.
States are also encouraging additional market participation: Nebraska recently approved Telcoin Digital Asset Bank, the first digital asset depository institution in the US, and others may follow in 2026.
Expanding entry pathways for non-banks
Non-banks now have more options for obtaining charters, although limitations remain. For example, charter holders often cannot accept insured deposits or provide a full range of traditional retail banking products.
However, charters offer greater flexibility than the state-by-state money transmitter licence model, which is fragmented and dependent on partner banks.
In 2026, firms are likely to compare regimes to optimise cost, speed and supervisory burden. The expanded path may prompt some to seek chartering or licensing environments that offer expedited entry, streamlined supervision or more direct access to traditional banking rails.
Banks and payments firms must understand how charters and licences vary in their access to core banking rails and assess the risks and the potential impact on competitive dynamics and partnerships.
Increasing supervisory expectations for non-bank participation
As non-banks gain access to traditional financial networks, regulators are expected to impose the controls that apply to traditional banks, including liquidity and capital requirements, enterprise-wide risk management, board-level oversight and model governance frameworks.
Alternative charters and licenses are not intended to provide simplified entry into the regulated banking system. Rather, they are designed to make non-banks subject to the same regulatory scrutiny as banks, ensuring fair access and a level playing field.
Non-banks will need to shift from a growth-first mindset to one grounded in safety, soundness and accountability, which will require investment in compliance, risk and internal governance.
They will need to enhance operational controls, formalize risk assessments, document processes thoroughly and build compliance teams that can support ongoing regulatory examinations and reporting cycles.
The Office of the Comptroller of the Currency will conduct comprehensive reviews of onboarding and offboarding processes at larger institutions under Executive Order 14333 to ensure that banks and non-banks provide fair access to banking services.
Ongoing litigation over whether the Federal Reserve must grant master accounts to certain non-banks, most notably the Custodia Bank case, could determine whether direct access remains limited to selected entities.
Implications for competition and market structure
Based on the number of applications in the second and third quarters of 2025, around 20 applications for special charter and license approvals could be expected in 2026. If they are approved, it will mean greater competition, as well as increased compliance obligations and operational considerations for both banks and non-banks.
Regulators should be wary of moving too quickly and not thoroughly assessing the impact of allowing new entrants into the financial system. An influx of non-banks could affect market stability and concentration, as well as create new points of vulnerability in payments, liquidity, cybersecurity and consumer protection.
Firms should prepare for increased competition by reviewing strategies, partnerships and compliance programs, and by assessing how regulatory changes may affect costs or product development. Banks should scenario plan around losing partner-bank exclusivity and facing new competitors with direct rail access.
