A year on, these amendments now shape every new lending NBFC application we prepare. Below is what changed, what did not, and what it means if you are planning to enter Pakistan's digital-lending market.
1. Easier entry for fintech founders
The experience requirement for founders and chief executives of lending NBFCs was relaxed. The SECP's stated aim is to let younger entrepreneurs enter the regulated digital-lending ecosystem rather than operate outside it. Fit-and-proper review and prior SECP approval of directors and the chief executive still apply.
2. P2P lending rebuilt
- Secured lending allowed on P2P platforms, which were previously limited in practice to unsecured loans.
- Higher prudential limits for individual lenders, making platforms more attractive to serious lenders.
- Lender eligibility criteria introduced to define who may lend through a platform.
- Platform contingent fund: platforms must set aside part of their profits as a buffer.
- Stronger disclosure and fund-flow transparency to protect lenders.
For a full walk-through of the licensing route, see our P2P Lending Licence in Pakistan (2026 Guide).
3. Buy Now Pay Later formally defined
BNPL arrangements now have an official definition inside the NBFC lending framework. Retailers and platforms offering instalment credit should check whether their model falls within it and therefore needs to run through a licensed lending NBFC.
4. New Credit Guarantee Institutions
A new class of NBFC activity, the Credit Guarantee Institution (CGI), was introduced to share credit risk with lenders and widen access to finance for underserved borrowers. CGIs carry their own exposure limits and sustainability standards.
5. Mandatory credit bureau reporting
Reporting to credit bureaus became mandatory for all NBFCs, not just some. New lenders must budget for bureau onboarding and data-quality controls from day one.
6. Microfinance companies
For non-bank microfinance companies, microenterprise and housing loan limits doubled from PKR 1.5 million to PKR 3 million. Boards must now have at least two female directors, one of them independent.
7. What did not change
| Item | Position after S.R.O. 2121(I)/2025 |
|---|---|
| Lending NBFC minimum equity (non-deposit-taking) | PKR 50 million under Schedule I |
| Additional equity for P2P permission | PKR 20 million on top |
| Two-stage route: NBFC licence, then P2P permission | Unchanged |
| Fit-and-proper review and prior SECP approval | Unchanged |
What this means for new entrants
The 2025 package, together with the SECP's June 2026 easing of security clearance for foreign directors, makes Pakistan noticeably easier to enter for foreign fintech groups than it was two years ago. The capital bar is unchanged, but the operating model is more flexible and the approval path is faster.
Frequently asked questions
What is S.R.O. 2121(I)/2025?
The SECP notification of 14 November 2025 amending the lending part of the NBFC Regulations, 2008.
Did minimum equity change?
No. The SECP's announcement left the Schedule I minimum and the PKR 20 million P2P add-on in place.
What changed for P2P platforms?
Secured lending, higher lender limits, lender eligibility criteria, a platform contingent fund and stronger disclosures.
Is BNPL regulated?
Yes, it now has a formal definition within the NBFC lending framework.
We advise local and foreign groups on NBFC licensing and ongoing SECP compliance.
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Related: NBFC & Business Finance · Fintech & Digital Payments · International clients