Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the SBP licence, including banking and payment rails.
Get a payment license in Pakistan.
The State Bank of Pakistan licenses electronic money institutions in four stages under regulations rewritten on 21 June 2023: initiation, in-principle approval, pilot operations, then the commercial licence. Startup capital is PKR 200 million, climbing to PKR 1.25 billion plus 10% of any outstanding e-money balance above PKR 20 billion, with a security deposit of 10% lodged at SBP Banking Services Corporation. The float goes into a trust account at a bank rated 'A' or better, wallets run to PKR 400,000 a month on biometric verification and up to PKR 1,000,000 enhanced, and no institution pays interest. The application fee is PKR 200,000 and the in-principle decision is due in sixty days.
27 yrs
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Licenses obtainedlicenses obtained
Updated
Pakistan in brief
Four stages, a capital ladder tied to float, and a pilot before you go live.
The State Bank of Pakistan licenses electronic money institutions under regulations first issued in April 2019 and rewritten on 21 June 2023, sitting on the Payment Systems and Electronic Fund Transfers Act, 2007. The 2023 text is the one to read. It widened what an institution may do, adding payment aggregation, bill and invoice aggregation, payment initiation, account information services and e-commerce escrow, and it raised wallet limits. Licensing runs in four stages under Regulation 8: approval of the initiation phase, in-principle approval, pilot operations, and the commercial licence at go-live. Capital starts at PKR 200 million and climbs with the average daily outstanding e-money balance - PKR 200 million plus 5% of the balance above PKR 4 billion, PKR 500 million plus 7.5% above PKR 10 billion, and PKR 1.25 billion plus 10% above PKR 20 billion. On top sits a security deposit of at least 10% of the required capital at SBP Banking Services Corporation, half in a non-remunerative current account and half in government securities under lien.
Customer money is held apart. Regulation 16 bars co-mingling and puts the float into a trust account at a bank rated 'A' or better, with no more than half of e-money balances at any one trustee once outstanding balances exceed PKR 300 million; up to 75% of the last three months' daily average may be invested in government securities maturing within a year. Wallets are capped by verification method: PKR 50,000 a month on CNIC, PKR 400,000 on biometric, and up to PKR 1,000,000 on an enhanced wallet backed by income proof, SIM pairing and monitoring. No interest, no returns, and redemption at par on demand without charges. The application fee is PKR 200,000 and Regulation 8.III(b) gives the regulator sixty days to decide an in-principle approval on a complete file; the pilot and commercial stages carry no published clock, which is where the calendar actually goes. Raast, the instant rail owned by the central bank, carried 742.1 million transactions worth PKR 23,267.4 billion between January and March 2026 across 2.6 million merchants. Six institutions held commercial licences at that date. Plan on twelve to eighteen months through all four stages.
The State Bank licenses electronic money institutions in four stages under the regulations revised on 21 June 2023: initiation, in-principle approval, pilot, commercial. Startup capital PKR 200 million, rising with float to PKR 1.25 billion plus 10% above PKR 20 billion, plus a 10% security deposit at SBP-BSC.
Float in a trust account at an A-rated bank, no single trustee above 50% past PKR 300 million. Wallets PKR 50,000 on CNIC, PKR 400,000 biometric, PKR 1,000,000 enhanced. No interest, redemption at par. Fee PKR 200,000, sixty days on in-principle. Raast is the rail.
The routes
Electronic money institution, or payment system operator and provider.
The difference is custody. An electronic money institution holds customer funds and issues wallets; a payment system operator or provider runs infrastructure and never becomes custodian of consumer money. We fix the route first, then build once.
Electronic money institution, or payment system operator and provider.
01 - ELECTRONIC MONEY INSTITUTION
EMI licence in four stages
The licence under the regulations revised on 21 June 2023 to issue, distribute and redeem e-money, acquire payment instruments, route and switch transactions, and run payment aggregation, bill aggregation, payment initiation and account information services.
The licence under the regulations revised on 21 June 2023 to issue, distribute and redeem e-money, acquire payment instruments, route and switch transactions, and run payment aggregation, bill aggregation, payment initiation and account information services.
- ✓Four stages: initiation, in-principle, pilot, commercial
- ✓Startup capital PKR 200,000,000
- ✓Ladder to PKR 1.25bn plus 10% above PKR 20bn of float
- ✓Security deposit of 10% lodged at SBP-BSC
- ✓Trust account at a bank rated 'A' or better
- ✓Wallets to PKR 400,000 · PKR 1,000,000 enhanced
02 - PAYMENT SYSTEM OPERATOR / PROVIDER
PSO / PSP - PKR 200 millionPSO and PSP authorisation
The 2014 rules cover electronic payment gateways, payment schemes, clearing houses, ATM switches and point-of-sale gateways. An operator or provider under them holds no consumer money, and may later upgrade to the EMI licence.
PSO and PSP: gateways, schemes, clearing houses and ATM switches on PKR 200 million paid-up capital, with no custody of consumer money.
- ✓Gateways, schemes, clearing houses, ATM switches
- ✓Paid-up capital PKR 200 million free of losses
- ✓Plus 25% for each additional PSO or PSP business
- ✓No custody of consumer money under the 2014 rules
- ✓Security deposit of 10% on the same basis
- ✓Upgrade to an EMI licence is permitted
Costs and timelines are confirmed for your case before any work begins. The application processing fee is PKR 200,000 deposited at SBP-BSC Karachi; annual and licence fees are not published by the regulator, so they are confirmed in writing before they enter the budget.
Why Pakistan
A 241-million market, six licensed institutions, and a rail the central bank owns.
Pakistan licenses slowly and deliberately, and the register shows it. Six reasons the file is worth the four stages, including the one that costs you time.
✓
Raast
The instant rail is operated by Raast Payments Pakistan, a wholly-owned subsidiary of the central bank, and moved 742.1 million transactions worth PKR 23,267.4 billion in the January to March 2026 quarter across 2.6 million merchants.Central-bank rail, 2.6 million merchants.
✓
Six institutions
Six electronic money institutions and six payment system operators or providers held commercial licences at the end of the March 2026 quarter, against 44 banks and 14 branchless-banking providers.Commercially licensed at March 2026.
✓
A licence widened in 2023
The revised regulations added payment aggregation, bill and invoice aggregation, payment initiation, account information services and e-commerce escrow to the permissible list.Aggregation, initiation, escrow added.
✓
A clock on the first gate
Regulation 8.III(b) gives the regulator sixty days to decide an in-principle approval where the file is complete. The later stages carry no published period.In-principle decision on a complete file.
✓
Wallet headroom
PKR 400,000 a month on biometric verification, and up to PKR 1,000,000 on an enhanced wallet with income proof and SIM pairing - room most regional regimes do not give.Up to PKR 1,000,000 enhanced.
✓
A pilot before you commit
Commercial launch follows a live pilot inside lower limits, so the model is tested with the regulator watching rather than after go-live.Model tested before commercial launch.
How it compares
How Pakistan differs from the alternatives.
Pakistan asks less capital than India at entry but stages the licence over four gates and adds a security deposit nobody else in the group charges. The honest comparison is below.
Pakistan vs other jurisdictions
| Feature |  Pakistan | Other jurisdictions |
|---|---|---|
| Capital | PKR 200M, ladder to PKR 1.25bn | Flat floors or net-worth tests |
| Licensing | Four stages including a live pilot | One decision |
| Security deposit | 10% of required capital at SBP-BSC | Rare |
| Wallet cap | PKR 400,000 · 1,000,000 enhanced | Lower or absent |
Capital
PakistanPKR 200M, ladder to PKR 1.25bn
Other jurisdictionsFlat floors or net-worth tests
Licensing
PakistanFour stages including a live pilot
Other jurisdictionsOne decision
Security deposit
Pakistan10% of required capital at SBP-BSC
Other jurisdictionsRare
Wallet cap
PakistanPKR 400,000 · 1,000,000 enhanced
Other jurisdictionsLower or absent
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Pakistan | EMI (SBP) | Dividends 15% filers · 30% non-filers | PKR 200M startup · trust account |
 India | PPI issuer / payment aggregator (RBI) | 25% or 30% · GST 18% | INR 5cr to 25cr net worth · escrow |
 UAE | RPS Cat I-IV (CBUAE) | 9% · 0% band | AED 0.1-3M by volume |
 Bahrain | PSP / AISP / PISP (CBB) | 0% · 15% DMTT large | BD 25k-250k by tier |
PakistanLicense typeEMI (SBP)
TaxationDividends 15% filers · 30% non-filers
RequirementsPKR 200M startup · trust account
IndiaLicense typePPI issuer / payment aggregator (RBI)
Taxation25% or 30% · GST 18%
RequirementsINR 5cr to 25cr net worth · escrow
UAELicense typeRPS Cat I-IV (CBUAE)
Taxation9% · 0% band
RequirementsAED 0.1-3M by volume
BahrainLicense typePSP / AISP / PISP (CBB)
Taxation0% · 15% DMTT large
RequirementsBD 25k-250k by tier
Before you apply
Requirements for the SBP licence.Requirements for the licence.
Regulation 8 sets the stages, Regulation 11 the money, Regulation 16 the trust account and Regulation 14 the wallet limits. The checklist below is what a passing file contains.
01
A public or private company registered with the Securities and Exchange Commission of Pakistan, with its head office or registered office in Pakistan.
02
Startup capital of PKR 200 million, with the ongoing figure driven by the average daily outstanding e-money balance: plus 5% above PKR 4 billion, PKR 500 million plus 7.5% above PKR 10 billion, and PKR 1.25 billion plus 10% above PKR 20 billion.
03
A security deposit of at least 10% of the required capital lodged at an office of SBP Banking Services Corporation, half in a non-remunerative current account and half in government securities under lien.
04
A trust account at a bank rated 'A' or better, with no more than 50% of e-money balances at a single trustee once outstanding balances pass PKR 300 million, and no co-mingling of company funds with customer funds.
05
An investment policy that keeps any placement inside the permitted band - up to 75% of the last three months' daily average outstanding balance in government securities maturing within one year.
06
Fit-and-proper clearance for sponsor shareholders, directors, the chief executive and key executives, with the chief executive holding at least five years of senior-level experience.
07
A compliance officer appointed by the board and reporting directly to the chief executive, and a separate internal audit department approved by the board.
08
Wallet limits built into the product: PKR 50,000 a month on CNIC verification, PKR 400,000 on biometric verification, and up to PKR 1,000,000 on an enhanced wallet with income proof, SIM pairing and transaction monitoring.
09
A system audit by an auditor approved by the regulator before launch and every year afterwards, with documentation to the Technology Risk Management Framework issued in October 2025.
10
No function outsourced outside Pakistan without prior written approval, and agents used only under a one-time written approval and a board-approved agent network management policy.
01
SECP-registered company, head office in Pakistan.
02
Startup capital PKR 200 million.
03
Ladder to PKR 1.25bn plus 10% above PKR 20bn.
04
Security deposit of 10% at SBP-BSC.
05
Trust account at a bank rated 'A' or better.
06
Up to 75% in government securities under a year.
07
Fit and proper: sponsors, directors, CEO.
08
Compliance officer and internal audit department.
09
Wallet limits built into the product.
10
System audit before launch and annually.
Reflects the Payment Systems and Electronic Fund Transfers Act 2007, the Regulations for Electronic Money Institutions as revised on 21 June 2023, the 2014 Rules for PSOs and PSPs and the Technology Risk Management Framework of October 2025, as of 2026.PSEFT Act 2007; EMI Regulations as revised 21 June 2023; PSO/PSP Rules 2014; TRM Framework of October 2025.
How it works
From first call to the commercial licence.
01
Initiation phase
The business case put to the regulator, the PKR 200,000 processing fee lodged at SBP-BSC Karachi, and the corporate route settled.Business case and fee lodged.
02
In-principle approval
The full submission filed, with sixty days to a decision on a complete file and sponsors and directors carried through fit and proper.Sixty days on a complete file.
03
Capital, deposit and trust
PKR 200 million paid in, the 10% security deposit lodged at SBP-BSC, the trust account opened at a bank rated 'A' or better.Paid in, lodged, account opened.
04
Pilot operations
A live pilot inside the lower wallet limits, with the system audit completed by an auditor the regulator approves.Lower limits; system audit done.
05
Commercial licence
Go-live approval, the full wallet limits switched on, Raast participation live and the annual audit calendar running.Go-live; full limits; Raast.
Quick facts
RegulatorState Bank of Pakistan
LawPSEFT Act 2007 · EMI Regulations 2023
LicenceEMI in four stages · PSO / PSP
CapitalPKR 200M startup · to PKR 1.25bn
Security deposit10% at SBP-BSC
Client fundsTrust account, A-rated bank
Decision60 days on in-principle approval
FeePKR 200,000 application
Only the first gate has a published clock. The pilot and the commercial approval run to the regulator's own pace, so the schedule is built around how fast the pilot produces clean data and how fast the system auditor can be booked.
Your Pakistan desk
Run from our Gulf and South Asia desk.
Prifinance - Gulf and South Asia desk
Dubai · coordinating Pakistani mandates
33 Level, Al Saqr Business Tower, Dubai
01
Pakistani company formation
A company registered with the SECP with its head office in Pakistan, capital of PKR 200 million paid in and the sponsor shareholders documented for the fit-and-proper test.SECP registration, capital, sponsors.
02
The SBP file
The four-stage submission from initiation to go-live, with the PKR 200,000 fee lodged at SBP-BSC Karachi and the in-principle decision tracked against its sixty-day clock.Four stages; PKR 200,000 fee lodged.
03
Trust account and deposit
The trust account opened at a bank rated 'A' or better and the 10% security deposit lodged at SBP-BSC, half in cash and half in government securities.A-rated bank; 10% at SBP-BSC.
04
Substance in Pakistan
A chief executive with five years at senior level, a board-appointed compliance officer reporting directly to the chief executive, an internal audit department and the pre-launch system audit booked.CEO, compliance officer, internal audit.
We also have offices in
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Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Pakistan.
Dividends turn on whether the recipient is on the Active Taxpayers List, super tax changed for 2026-27, and one headline rate the tax authority does not print on the pages we can reach.
Dividends 15% or 30%
Section 150 withholds 15% from persons on the Active Taxpayers List and 30% from those who are not, per the withholding rate card for tax year 2027.30% for non-filers.
Payments to non-residents
Section 152(1) withholds at 15%, section 152(1A) at 7% and section 152(1BA) at 20%. Which subsection catches a payment is fixed with the contract, not after it.15%, 7% or 20% by subsection.
Super tax from 2026-27
Abolished for persons with income up to PKR 500 million and cut from 10% to 8% above that. The concession is not available to banking, exploration and production, and fertilizer.8% above PKR 500M from 2026-27.
The corporate rate
The standard corporate income tax rate is not printed on the reachable Federal Board of Revenue pages; the First Schedule sits inside a consolidated document whose schedules are not machine-readable. We confirm the rate in writing for your structure.Not printed on reachable FBR pages.
Sales tax on services
Provincial, not federal. The federal authority points to the Islamabad Capital Territory ordinance for the capital, and the rate on your services is confirmed province by province.Provincial, confirmed by province.
Payroll
Income tax and contributions on Karachi, Lahore or Islamabad salaries, priced with the compliance officer, the internal audit department and the annual system audit.Income tax + contributions.
Tax summary
Dividends15% filers · 30% non-filers
Non-resident payments15% · 7% · 20% by subsection
Super tax8% above PKR 500M from 2026-27
Corporate rateNot printed on reachable FBR pages
Sales tax on servicesProvincial
PayrollIncome tax + contributions
*Figures as of 2026 per the FBR withholding tax rate card for tax year 2027 and the Budget 2026-27 salient features. The standard corporate rate is confirmed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Pakistani company registered with the SECP, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed institution.
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Pakistan · SBP
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Full-service assistance - from company registration to the SBP licence, the trust account, Raast participation and ongoing compliance.
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The Pakistani payment licence, answered.
What licence does a payment business need in Pakistan?+
An electronic money institution licence from the State Bank of Pakistan if you hold customer funds and issue wallets, or authorisation as a payment system operator or provider under the 2014 rules if you run infrastructure and never take custody of consumer money. An operator may upgrade to the institution licence later.
How does the four-stage licence work?+
Regulation 8 sets it out: approval of the initiation phase, then in-principle approval, then pilot operations under reduced wallet limits, then the commercial licence at go-live. The system audit sits between the pilot and commercial launch.
How much capital is required?+
PKR 200 million of startup capital. After that the figure follows the average daily outstanding e-money balance: PKR 200 million plus 5% above PKR 4 billion, PKR 500 million plus 7.5% above PKR 10 billion, and PKR 1.25 billion plus 10% above PKR 20 billion. A security deposit of at least 10% of the required capital is lodged at SBP Banking Services Corporation.
How long does it take?+
Regulation 8.III(b) gives the regulator sixty days to decide an in-principle approval where the file is complete. No period is published for the pilot or the commercial stage. Through all four gates, plan on twelve to eighteen months.
How is customer money held?+
Regulation 16 bars co-mingling and puts the float into a trust account with a licensed bank rated at least 'A'. No more than 50% of e-money balances may sit with one trustee once outstanding balances exceed PKR 300 million, and up to 75% of the last three months' daily average may be invested in government securities maturing within a year.
What are the wallet limits?+
In commercial operations, PKR 50,000 a month on CNIC verification and PKR 400,000 on biometric verification, with cash withdrawal of PKR 10,000 a day on CNIC. An enhanced wallet reaches PKR 1,000,000 against income proof, SIM pairing, transaction monitoring and risk profiling.
Can an institution pay interest on a wallet?+
No. Regulation 7.V bars paying interest or returns and bars anything else that adds to the monetary value of e-money. Redemption is at par value at any time on the holder's request, without charges.
What does it cost to apply?+
A non-refundable application processing fee of PKR 200,000, deposited at SBP Banking Services Corporation in Karachi. Annual and licence fees are not published by the regulator, so we confirm them in writing before they enter the budget.
What is Raast?+
The national instant payment rail, operated by Raast Payments Pakistan, a wholly-owned subsidiary of the central bank. It carried 742.1 million transactions worth PKR 23,267.4 billion in the January to March 2026 quarter across 2.6 million merchants.
Why Pakistan rather than India or the UAE?+
Pakistan is a 241-million market with six licensed institutions, a central-bank-owned instant rail and wallet headroom to PKR 1,000,000. India gives more scale, UPI and a perpetual certificate but asks a higher net worth; the UAE decides faster, taxes profit at 9% and carries no security deposit. Groups serving Pakistani consumers or remittance corridors license here.
Which licence?+
SBP electronic money institution, or PSO/PSP.
How many stages?+
Four: initiation, in-principle, pilot, commercial.
Capital?+
PKR 200M, ladder to PKR 1.25bn.
How long?+
60 days in-principle; 12-18 months overall.
Client funds?+
Trust account at a bank rated 'A' or better.
Wallet limits?+
PKR 400,000 biometric; 1,000,000 enhanced.
Interest?+
None; redemption at par without charges.
Fee?+
PKR 200,000 at SBP-BSC Karachi.
Raast?+
Central-bank instant rail, 2.6M merchants.
vs India / UAE?+
Lower entry capital; four gates to pass.
Client notes
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the State Bank of Pakistan or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.