The private payroll loan portfolio in Brazil has already grown by approximately R$ 100 billion since the new sector regulations came into effect in March 2025. According to the Central Bank, the outstanding balance of private payroll loans was around R$ 40 billion that month. Today, according to the Ministry of Labor and Employment (MTE), the volume has already reached R$ 140 billion.

Until then, private payroll loans depended on a prior agreement between the company and the financial institution — a bilateral model that restricted the product to a few large companies.

With the integration into eSocial, any worker with a formal employment contract can now apply for the loan directly through the Digital Work Card app, with automatic payroll deduction and additional guarantees, such as the FGTS balance and part of the severance pay in case of dismissal.

Rapid growth has transformed private payroll loans into one of the most competitive credit markets in Brazil, attracting everyone from large traditional banks to fintechs and specialized asset managers. In total, 104 banks operate in this sector, according to the Ministry of Labor and Employment (MTE), with 23 million contracts already signed with more than 10 million workers.

According to the Brazilian Ministry of Labor and Employment (MTE), Itaú, Banco do Brasil, Santander, and Bradesco have some of the largest portfolios of payroll-deducted loans : R$ 17 billion, R$ 12 billion, R$ 7 billion, and R$ 4 billion, respectively. Banco Pan, with R$ 8 billion in this structure, and C6, with R$ 6 billion, also appear as relevant institutions.

The biggest highlight on the list, however, is not a bank, but a fintech company. It's Parati Financeira, a branch of MeuTudo, which originates the operations. The company, along with Itaú, is the largest player in this market, with a portfolio of R$ 17 billion in private payroll loans.

Meutudo is a credit fintech that started operating in 2017 offering payroll loans — initially only in the public sector, focusing on INSS (Brazilian National Social Security Institute) and civil servants — and began operating in the private sector as soon as the new regulations were released in March of last year.

Daniel Mello, from meutudo, says that even after the strong growth in just over a year since the new regulations came into effect, he still sees significant room for growth in this market.

“We are talking about 47 million employees. Penetration is, at most, 20% of that market,” says Mello. One of the main uses, according to him, has been the refinancing of more expensive debts, such as those linked to personal loans.

"I think that's the main benefit of the product for the customer: getting out of credit cards and overdrafts and having a debt with fairer rates."

To finance this portfolio, Parati operates through FIDCs — investment funds in credit rights — managed within the BTG Pactual structure. The fintech participates as a shareholder in the subordinated portion of the funds, the highest-risk segment of the structure, as it is the first to absorb any potential losses in the portfolio, but also the one that captures the highest returns.

The use of FIDCs — a class of funds that has almost quadrupled since 2019, reaching R$ 770 billion — is what has opened the eyes of different asset managers to this potential market. This is the case of Neo Investimentos, an independent asset manager with 23 years of experience, which began building its private credit structure precisely through private payroll loan FIDCs.

The firm launched its credit business in 2024, with a team brought in from Itaú and XP, and today considers private payroll loans its biggest strategy within the area — ahead of, even, special situations, court-ordered payments, and recovery of delinquent loans.

According to Arnaldo Braga Neto, partner and head of credit at Neo Investimentos, the product currently offers the best risk-return ratio of credit in Brazil. One of the advantages, he says, is the lower cost of acquiring the credit.

“In public sector payroll loans, you necessarily have to pay an originator who takes a large portion of the remuneration. In private sector payroll loans, since you have an auction mechanism, you have the option of paying an originator or not. Therefore, the customer acquisition cost is much lower,” he states.

Despite greater independence from the traditional originator figure, this role remains highly sought after in the market. It is this role that ARZ Capital — the asset management firm of founding partner Frederico Maluf, formerly of XP, with approximately R$ 1.1 billion under management — seeks to enter in the private payroll loan market.

According to Rodolfo Wassano, partner responsible for the firm's credit area, the asset manager has not yet made any disbursements for the investment thesis, but has been closely monitoring the market for over a year and is in the negotiation phase with potential originators. "We love to work with originators that are formed by people who have experience in the segment, but who are setting up their business now," he says.

For ARZ, the interest in this modality is linked to its risk diversification thesis, which allows for statistical analysis. Instead of analyzing each case individually, the asset manager can mathematically model the portfolio's historical behavior and project stress scenarios with greater predictability.

According to Wassano, the decision to enter the market only now was deliberate, as he preferred to wait for the market to mature. He explains that initially, the product faced technical problems that delayed the transfer of the deducted amount from payroll by up to 25 days in some cases.

"This was being recorded as a default in the portfolio." According to him, this bottleneck is now much closer to being resolved, with the transfer time currently around three days.

However, the technical problems have not disappeared, according to José Pires Neto, COO of Bull, a company that provides B2B infrastructure for private payroll loans. He points to two bottlenecks that are still unresolved.

The first scenario occurs in smaller companies, which often lack the operational structure to correctly process payroll deductions and remittances. The second occurs when a company withholds the amount deducted from an employee's salary and simply does not remit it to the creditor. In this case, the financial institution does not have an enforceable title against that company to collect the amount.

“This creates insecurity for those who have loans, because this company is not yet properly monitored and there are no effective collection mechanisms against it,” he says. According to him, the market is already debating the creation of a mechanism that would allow for direct collection from the company in these cases.

Although it considers the market promising and intends to enter it in the future, Integral Investimentos is waiting for some of these rough edges to be smoothed out first.

“What I want to understand is the default rate in this market, because I've seen transactions with default rates close to 50% and transactions close to 10%,” says Cristiano Greve, head of DCM at Integral Investimentos. “I think there's still a great deal of information asymmetry in this market and a risk that we're not yet comfortable with.”

Risk control

To operate in this market, banks and fintechs use different risk assessment models. Some buy this ready-made credit intelligence — as is the case with smaller originators that rely on infrastructure providers, such as Bull or Celcoin, which offer data on the risk of the worker and the employer.

Larger banks, however, prefer to keep this process internalized. This is the case with C6 Bank, which stated in a written response to the report that it evaluates credit based on proprietary models, considering both client and employer data. According to the bank, the main risk variable for this portfolio is the behavior of the labor market, especially unemployment, followed by the financial health of the paying company.

Changes to the program's rules also have a direct impact on the appetite for granting credit. In April, Resolution CGCONSIG No. 2/2026 came into effect, creating two rate levels: those who contract with FGTS (Brazilian employee severance fund) guarantee access a fixed ceiling of 1.99% per month; without a guarantee, a dynamic formula linked to the average market rate applies, currently around 4.98% per month.

The effect was felt quickly across the sector as a whole. According to the Central Bank, monthly private payroll loan disbursements fell 22.8% between April and May — precisely the period in which the new rule came into effect.

C6 itself admits that the recent change in regulations has forced the bank to be more conservative. "Recently, the combination of rate limits and rules for the use of collateral has required a more thorough risk assessment," the bank stated, adding that it "continues to focus on private payroll loans as an important modality within its credit product portfolio."

Optimism about the product also remains strong among asset managers. According to Arnaldo Braga Neto of Neo Investimentos, the private payroll loan market is still far from its peak. Currently, with a balance of around R$140 billion, he projects that the market could more than double in size, to approximately R$300 billion, within a horizon of one and a half to two years.

“We believe so strongly in this product precisely because it doesn't leverage the individual. It replaces expensive debt with cheaper debt.”