P2P Lending Licence in Pakistan: the 2026 Guide

Interest in peer-to-peer lending in Pakistan has grown sharply since the Securities and Exchange Commission of Pakistan (SECP) moved P2P out of its regulatory sandbox and into the NBFC Regulations, 2008. Our firm is regularly approached by fintech and digital-lending groups, many from China, the Gulf and Southeast Asia, asking the same questions: how much capital, how many directors, can foreigners own it, and how long will it take. This guide answers them as the rules stand in November 2026.

1. How P2P lending is regulated in Pakistan

P2P lending is governed by the Non-Banking Finance Companies (Establishment and Regulation) Rules, 2003 and the Non-Banking Finance Companies and Notified Entities Regulations, 2008, as amended. The P2P framework was first notified in 2022 and was substantially revised by S.R.O. 2121(I)/2025 in November 2025.

Under this framework, a P2P Service Provider is a lending NBFC that runs an online platform where lenders and borrowers transact directly. The platform matches them, handles documentation and collections, and must keep participant funds clearly identifiable and separate from its own.

2. Two-stage approval: NBFC licence, then P2P permission

Stage one: lending NBFC licence

The company is incorporated as a public company and applies to the SECP for a licence to carry out lending business, typically Investment Finance Services, as a non-deposit-taking NBFC. The application includes the business plan, fit-and-proper documents for every sponsor, director and the chief executive, and evidence of the minimum equity.

Stage two: P2P Service Provider permission

Once licensed, the NBFC applies for permission to provide P2P services. The SECP looks for:

• additional equity of at least PKR 20 million over the Schedule I minimum;
• demonstrable technological, entrepreneurial and managerial resources;
• a viable business plan for the P2P business;
• a robust and secure IT system, with participant data stored and processed in Pakistan unless the SECP permits otherwise.

3. Capital requirements

This is a minimum equity requirement, not a one-time paid-up capital figure. It must be maintained at all times, so groups should plan for early operating losses and fund above the minimum. Capital brought in from abroad should be routed through the banking channel and registered with the State Bank of Pakistan so that dividends and capital can later be repatriated.

4. Shareholders and directors

• Shareholders: at least three, because an NBFC must be a public company. Foreign individuals and companies may hold up to 100%.
• Directors: at least three. Foreign nationals may be directors and chief executive; directors need not live in Pakistan.
• Board composition: lending NBFCs follow the SECP's code of corporate governance, which requires independent director representation. Independent directors are appointed from the databank maintained under the Companies Act, 2017, so in practice they are usually Pakistan-based professionals. The board should also include members with financial-sector experience.
• Chief executive: a full-time officer of the NBFC. A foreign chief executive is permitted on a work visa.

Every sponsor, director, chairman and the chief executive must meet the SECP's fit-and-proper criteria and receive SECP approval before taking office. Our separate guide explains how foreign directors are cleared after the June 2026 reforms.

5. Operating rules a P2P platform must plan for

• Participant funds must be clearly identifiable and used only for P2P lending.
• Prior explicit consent is needed before accessing a participant's credit information, and reporting to credit bureaus is mandatory for NBFCs.
• Exposure limits apply per borrower and per lender. The November 2025 amendments raised the limits for individual lenders and introduced eligibility criteria for lenders.
• Platforms must build a platform contingent fund from profits as a buffer.
• Secured lending through the platform is now permitted.
• Enhanced disclosures to lenders on fund flows, pricing and risk.

6. Realistic timeline

The biggest causes of delay are incomplete or un-apostilled foreign documents, gaps in fit-and-proper information, and a platform that is not ready to demonstrate to the SECP.

7. Documents to prepare early

• Certified and apostilled constitutional documents and board resolutions of foreign corporate shareholders;
• Passports, CVs and fit-and-proper affidavits of sponsors, directors and the chief executive;
• Group structure chart down to ultimate beneficial owners;
• Five-year business plan and financial projections;
• Platform architecture, data-hosting and information-security documentation;
• Credit, AML/CFT, complaints and recovery policies.

Frequently asked questions

Related: NBFC & Business Finance · Fintech & Digital Payments · Clients from China · Cost to register a company in Pakistan