Pakistan EMI License — SBP Electronic Money Institution 2026

Bern old town cobblestone rainy — Pakistan EMI Licence (SBP)

Overview

SBP EMI Regulations 2019 & What EMIs Can Do

The State Bank of Pakistan (SBP) issued the EMI Regulations in 2019 to provide a clear framework for non-bank electronic money institutions. Prior to these regulations, mobile money services in Pakistan operated under informal frameworks or as bank-subsidiary operations. The 2019 regulations opened the sector to independent non-bank firms for the first time in a structured way.

Under the EMI Regulations, a licensed EMI can: issue electronic money (digital wallets) to individuals and businesses; provide domestic payment and transfer services; facilitate merchant payments and bill payments; operate agent cash-in/cash-out networks for wallet loading and withdrawal; and provide interoperable payment services within Pakistan's RAAST interbank payment infrastructure.

EMIs in Pakistan cannot accept deposits (which requires a scheduled bank licence), provide credit or lending services, or conduct international money transfers without separate SBP authorisation. The licence is specifically scoped to domestic e-money and payment services.

A unique and powerful feature of Pakistan's regulatory framework is the mandatory integration with NADRA's (National Database and Registration Authority) Verisys biometric verification system. This allows EMIs to perform KYC verification using Pakistan's national identity database, enabling fully digital customer onboarding at scale — a significant operational advantage that most other markets lack.

The SBP's RAAST (Roshan Aamdani and Savings Transformation) instant payment system, launched in 2021, provides real-time interbank payment rails. Licensed EMIs can connect to RAAST, allowing their wallet customers to send and receive money in real time with any bank or EMI account in Pakistan.

Requirements

Capital, Technology & Governance Requirements

Min Capital

PKR 200,000,000

~US$700K — fully paid up

Local Presence

Required

Pakistan-incorporated company

Technology

SBP-certified systems

Core banking / e-money system must meet SBP tech standards

AML Authority

FMU Pakistan + SBP

Financial Monitoring Unit

Remittance

Pakistan → Gulf Remittance Corridor

Pakistan receives over US$27 billion in annual remittances — the fifth-largest globally. The primary sending countries are Saudi Arabia (the largest corridor), the UAE, the UK, Qatar, and Kuwait. An estimated 9 million Pakistani expatriates live and work abroad, with the Gulf countries alone hosting over 5 million.

The SBP has actively promoted the Roshan Digital Account (RDA) programme to attract remittance flows through formal channels, offering high-yield accounts to overseas Pakistanis. This has increased the percentage of remittances flowing through official channels, creating a growing pool of digitally onboarded overseas Pakistanis who are comfortable with digital financial services.

For an EMI with a Pakistan licence and a partner arrangement or separate licence in Gulf countries, the Pakistan remittance corridor represents a recurring, high-volume payment flow with established consumer demand and favourable regulatory direction from both the SBP and Gulf regulators (who have been actively promoting formal remittance channels).

Key challenge: Pakistan's macroeconomic volatility, currency depreciation, and periodic foreign exchange restrictions create operational complexity. EMI operators must maintain adequate capital buffers and understand SBP foreign exchange management rules before committing to the market.

Process

Step-by-Step SBP EMI Licensing

Incorporate Pakistan Company

Register a private limited company or public limited company with the Securities and Exchange Commission of Pakistan (SECP). Obtain certificate of incorporation, NTN (National Tax Number), and company bank account for capital deposit.

3–5 weeks

Deposit Capital & Prepare Technology

Deposit PKR 200M minimum in company bank account. Begin technology procurement or development — SBP requires a certified e-money platform meeting SBP's technology standards. Engage IT security consultants for gap assessment.

Weeks 4–12

Prepare Application Package

Draft SBP application: business plan, financial projections, AML/CFT programme, technology description (SBP IT standards compliance), governance framework, agent network plan, personal questionnaires for directors and 5%+ shareholders.

8–12 weeks

Submit to SBP Payment Systems Department

File application with SBP's Payment Systems Department. The SBP will review completeness and assign case handler. Expect formal acknowledgment within 2–3 weeks.

Month 3–4

SBP Due Diligence

SBP conducts fit-and-proper tests on founders/directors, evaluates business model viability, reviews technology plan, and assesses AML programme. May require on-site inspection of proposed technology setup.

Months 4–10

Licence Issuance & RAAST Integration

SBP issues EMI licence. Connect to RAAST real-time payment system. Integrate NADRA Verisys for biometric KYC. Complete agent network setup. Launch services under SBP regulatory supervision.

Month 6–12

◆ KEY METRICS

Pakistan EMI License Requirements

PKR 50 Million

Minimum Capital Requirement

90–120 Days

Processing Timeline

0.5–1.0%

Main Transaction Fee

29%

Corporate Tax Rate (2026)

State Bank of Pakistan

Regulatory Authority

US$27B Remittance Market

Access to High-Growth Corridor

◆ PROCESS FLOW

License Application Timeline

Week 1–2

Preliminary Documentation & Company Formation

Establish legal entity, prepare memorandum, articles of association, and shareholder details for SBP submission

Week 3–6

Application Submission & Completeness Review

Submit formal application to SBP with compliance framework, AML/CFT policies, and risk management structure

Week 7–10

Technical & Compliance Assessment

SBP evaluates business model, IT infrastructure, governance, and financial projections; may request clarifications

Month 4–5

On-Site Inspection & Final Due Diligence

SBP conducts facility inspection, interviews management, and verifies capital deposit in designated bank account

Month 5–6

License Issuance & Operational Approval

Receipt of SBP EMI License certificate; begin regulated electronic money operations and customer onboarding

FAQ

Frequently Asked Questions

The SBP EMI Regulations 2019 provide a framework for non-bank electronic money institutions. They define permissible activities (e-wallet issuance, payment services), capital requirements (PKR 200M minimum), technology standards, and governance requirements for licensed EMIs.

A Pakistan EMI can issue electronic money (digital wallets), provide domestic funds transfer services, facilitate bill and merchant payments, and offer agent-based cash-in/cash-out. They cannot accept deposits or provide credit. International remittance requires additional SBP authorisation.

The SBP requires a minimum paid-up capital of PKR 200,000,000 (approximately US$700,000) for an EMI licence. Capital must be maintained at all times and reported quarterly to SBP.

Pakistan receives over US$27 billion in annual remittances, primarily from Gulf countries and the UK. With 9M+ overseas Pakistanis, the inbound remittance corridor is one of the world's largest. Licensed EMIs serving last-mile disbursement access a high-volume, recurring payment flow.

The SBP typically requires 90-120 days for initial review and approval of a complete EMI license application, though this can extend to 6 months if additional documentation or clarifications are requested. The timeline begins after submission of all required documents, including shareholders' information, business plan, compliance framework, and IT security audit reports. Applicants should budget for potential follow-up queries from the regulator, which can add 4-8 weeks to the overall process.

Initial licensing costs typically range from PKR 5-10 million (approximately US$18,000-36,000) including application fees, legal and compliance advisory, and IT security certifications required by the SBP. Annual compliance and regulatory costs average PKR 3-5 million (US$11,000-18,000), covering mandatory audits, AML/CFT training, and regulatory reporting obligations. These figures exclude the mandatory PKR 200 million paid-up capital requirement, which must be maintained in approved bank accounts at all times.

EMIs must establish and maintain relationships with at least one Tier-1 bank in Pakistan for settlement and customer fund custody, as per SBP guidelines. The designated bank acts as the custodian for customer electronic money balances and must maintain separate accounts to segregate customer funds from operational accounts. Banks typically conduct enhanced due diligence on EMI applicants and may require personal guarantees from shareholders or directors, with onboarding taking 4-8 weeks.

EMIs in Pakistan are subject to standard corporate income tax rates (29% in 2026), but may qualify for preferential treatment under the Special Technology Zones Authority (STZA) if registered in designated zones, which can reduce rates to 0% for 5-10 years. Value-added tax (17%) applies to most financial services, though e-money issuance may receive exemptions under certain conditions—consultation with the FBR (Federal Board of Revenue) is essential. Additionally, EMIs must file quarterly financial reports with the SBP and maintain detailed transaction records for tax audit purposes.

The SBP requires that an EMI be incorporated and registered as a private limited company under Pakistani law—foreign companies cannot hold an EMI license directly and must establish a local Pakistani subsidiary. However, foreign entities can be majority shareholders (up to 100%) of the Pakistani company, though at least one Pakistani resident director is typically required. The application must demonstrate local governance structures, Pakistani bank accounts, and compliance with Pakistani corporate registration requirements.

The SBP conducts on-site inspections every 12-18 months, with particular focus on AML/CFT controls, customer fund segregation, cybersecurity protocols, and transaction monitoring systems; non-compliance findings can result in fines up to PKR 10 million or license suspension. Pakistan's financial sector faces heightened scrutiny from international bodies (FATF grey-list status as of 2024), requiring EMIs to implement advanced know-your-customer (KYC) procedures and real-time reporting of suspicious transactions to the FMU. Operational risks include potential changes to SBP regulations, restrictions on cryptocurrency integration, and periodic mandatory security audits by approved third-party auditors.

Pakistan's EMI framework is more restrictive than European PSD2 regulations—Pakistan requires higher minimum capital (PKR 200M vs. EUR 350K-1M in Europe), permits fewer cross-border services, and prohibits cryptocurrency-related activities entirely. European EMI licenses enable passporting across the EU/EEA with a single authorization, while Pakistan EMIs are limited to domestic operations within Pakistan unless specific bilateral agreements exist with other regulators. However, Pakistan's licensing process is typically faster (3-6 months vs. 6-12 months in Europe) and the regulatory framework is less complex, making it more accessible for regional players targeting South Asian remittance corridors.

Pakistan EMIs must comply with the Anti-Money Laundering Act 2010 and SBP AML/CFT regulations. Suspicious transactions are reported to the Financial Monitoring Unit (FMU Pakistan). Biometric KYC using NADRA's Verisys system is required for customer onboarding.

Pakistan EMI Licence (SBP)