Fintech is transforming how Pakistan handles money. From mobile wallets to instant transfers, the financial landscape is moving toward cashless innovation.
However, before a company can legally issue E-money or operate a digital wallet, it must obtain an Electronic Money Institution (EMI) licence from the State Bank of Pakistan (SBP).
This licence ensures compliance, consumer protection, and stability in the digital payments sector. Without it, your fintech cannot legally store or transfer funds for users.
If you’re a startup, digital wallet provider, or payment app developer, this guide will show you how to get an EMI licence in Pakistan step by step plus the key requirements, costs, and benefits.
An Electronic Money Institution is a company authorized by the SBP to issue and manage electronic money (E-money).
E-money represents a digital equivalent of cash stored electronically and used for payments, remittances, or value transfers.
Digital wallets (e.g., Easypaisa, SadaPay, NayaPay)
Prepaid cards and payment apps
Peer to peer transfer platforms
Mobile banking applications with stored value
EMIs are not banks they can’t offer loans or savings accounts but they can act as intermediaries in digital transactions, helping people and businesses make secure payments.
You need an EMI licence from SBP if your company.
Provides digital wallets or prepaid cards to users.
Stores funds electronically on behalf of customers.
Offers payment processing or peer to peer transfer services.
Wants to build fintech or neobank applications.
This guide is meant for:
Fintech startups and entrepreneurs entering the payments sector.
Established companies expanding into digital wallets or EMI operations.
Legal and compliance officers managing SBP regulatory submissions.
The SBP EMI Regulations (2019, updated 2023) outline a three stage licensing process.
You must apply to SBP’s Payment Systems Department (PSD) with the following.
Company incorporation certificate (from SECP)
Feasibility and business plan
Risk management and cybersecurity framework
Capital adequacy proof (minimum PKR 200 million for full EMI)
AML/CFT compliance policy
Details of directors, shareholders, and system architecture
SBP reviews your documents and grants an In Principle Approval (IPA) if all requirements are met.
After getting IPA, your company must.!
Launch a pilot project (typically for 3 to 6 months).
Test systems, security, and KYC/AML compliance.
Report pilot results to SBP for validation.
SBP monitors this stage closely to ensure your systems handle real world users securely.
Once SBP is satisfied with your pilot’s success, it grants the Final EMI Licence.
You can now.!
Offer full scale services to the public.
Issue E-money, manage wallets, and facilitate transfers.
Partner with banks, telecoms, or other payment service providers.
Minimum Paid Up Capital: PKR 200 million
Corporate Registration: Must be an SECP registered company
Governance: Fit & Proper criteria for directors and management
Compliance: AML/CFT, consumer protection, and data privacy frameworks
Technology: Secure IT systems with real time monitoring
Auditing: Annual independent audits
While the EMI licence unlocks opportunity, the process can be complex.
Legal recognition from SBP
Easier funding from investors
Access to partnerships with local and global banks
High capital requirement (PKR 200 million minimum)
Lengthy approval timeline (6 to 12 months)
Complex regulatory documentation
Need for ongoing compliance audits
SadaPay and NayaPay, two of Pakistan’s top fintech startups, both went through the SBP EMI process successfully.
SadaPay focused on financial inclusion and simplified digital banking for freelancers.
NayaPay integrated payment gateways and wallets for individuals and businesses.
Both startups highlighted compliance, data security, and transparent reporting as key success factors in earning SBP’s trust.
At MAH&CO., our corporate and fintech lawyers specialize in SBP regulatory licensing.
We help startups and enterprises.
Incorporate under SECP with correct capital structure.
Draft and submit EMI applications to SBP.
Prepare AML/CFT and compliance manuals.
Represent clients during the SBP inspection process.
Expertise: Deep understanding of SBP regulations and fintech law.
Experience: Assisted multiple clients in obtaining SBP related licences.
Trust: Transparent legal process and client confidentiality.
Assistance: End to end documentation, submission, and follow up.
Contact MAH&CO. today for professional guidance in securing your EMI licence in Pakistan.
To get an Electronic Money Institution (EMI) licence in Pakistan, you must apply to the State Bank of Pakistan’s Payment Systems Department (PSD). The process includes submitting your company’s feasibility report, risk management framework, paid-up capital proof, IT and cybersecurity plan, and compliance manuals. Once approved, you’ll enter a pilot phase before getting the final EMI licence from SBP.
The EMI licence approval process in Pakistan generally takes between 6 to 12 months, depending on how complete and compliant your application is. The timeline includes SBP’s in-principle approval, pilot testing, and final authorization stages. Fintech startups that submit a strong compliance and cybersecurity framework often experience faster approval.
Under SBP’s latest Electronic Money Institutions Regulations, applicants must maintain a minimum paid-up capital of PKR 200 million. This capital ensures that your fintech has the financial stability to manage customer funds securely and meet SBP’s prudential and risk management standards.
No, individuals or sole proprietors cannot apply for an EMI licence. The State Bank of Pakistan only accepts applications from SECP-registered private or public limited companies that meet the minimum capital and compliance requirements. If you plan to launch a digital wallet or fintech startup, you must first register your company under the Companies Act, 2017.
Getting an EMI licence from SBP allows fintech companies to legally issue e-money, operate digital wallets, and provide secure payment services. It builds trust among customers and investors, enhances regulatory credibility, and opens doors for partnerships with banks, telecoms, and international payment networks. It’s also a gateway to innovation in Pakistan’s digital payments ecosystem.
Fintechs must adopt robust cybersecurity frameworks, follow KYC (Know Your Customer) and AML/CFT (Anti-Money Laundering / Counter Financing of Terrorism) standards, and submit detailed governance and technology audit reports. Partnering with experienced corporate lawyers or compliance consultants helps ensure all SBP EMI licensing requirements are met accurately.
Yes MAH&CO. specializes in SBP regulatory licensing and fintech compliance. Our team assists with everything from company incorporation and documentation drafting to submission, liaison, and final SBP approval. We help fintech startups and digital wallet providers streamline the EMI licence process with full legal compliance and confidentiality.
