Getting an EMI licence in Pakistan: a guide for fintechs
Digital wallets and payment apps in Pakistan operate under the State Bank's Electronic Money Institution framework. The licence comes in stages, and each stage has its own legal deliverables.
Published 26 October 2026
What an EMI can do
An Electronic Money Institution issues e-money — wallets, prepaid instruments and payment accounts — and provides payment services against it. It cannot lend or take deposits like a bank; customer funds must be safeguarded in trust or escrow arrangements with a bank.
The three stages
In-principle approval: SBP reviews the business plan, ownership, governance and technology; no operations are allowed yet. Pilot approval: limited live operations under transaction and customer caps, to prove systems and controls. Commercial licence: full operations once the pilot shows compliance and readiness.
Capital and corporate requirements
The applicant must be a company registered with SECP. Minimum paid-up capital has been set at PKR 200 million, with ongoing capital requirements and possible security deposits linked to expected volumes. Directors, sponsors and senior management face fit-and-proper scrutiny.
Compliance build-out
SBP expects AML/CFT and KYC frameworks, transaction monitoring, IT security and data protection policies, a risk management framework, trust-account arrangements for customer funds and regular reporting. Foreign-owned applicants also need to plan foreign investment and repatriation filings.
How we help
We incorporate the applicant, draft the regulatory policy suite, prepare SBP submissions and negotiate bank trust and partnership agreements. See our Fintech & Digital Payments practice.
Frequently asked questions
Who regulates EMIs in Pakistan?
The State Bank of Pakistan; the company itself is registered with SECP.
What is the minimum capital?
PKR 200 million paid-up capital, plus ongoing capital requirements.
Can an EMI start operating after in-principle approval?
No — only after pilot approval, and full operations need the commercial licence.
This article is general information as of October 2026, not legal advice. Rules change; contact the firm about your specific matter.