Service overview
An EMI is an SBP-regulated non-bank issuer of electronic money and digital payment instruments.
An IT-sector registration is not equivalent to telecom or payments regulatory permission. Any exemption or incentive must be tested against its own statutory conditions; registration alone does not establish tax eligibility.
Who is eligible for Electronic Money Institution (EMI) Licensing?
The applicant must satisfy SBP's current EMI Regulations, ownership and capital requirements, governance, safeguarding and technology readiness.
An EMI applicant must be an eligible legal entity with required paid-up capital, independent governance and safeguarding of customer float. A business offering merely software to a bank may not need an EMI licence.
Documents and information for Electronic Money Institution (EMI) Licensing
Prepare the following information for electronic money institution (emi) licensing. The relevant regulator may require further forms or certified evidence, depending on the applicant and chosen procedure.
- Wallet/e-money business model
- Source of capital and ownership
- Directors and management
- Customer-fund safeguarding
- AML/CFT, cyber and operational policies.
How can I obtain Electronic Money Institution (EMI) Licensing in Pakistan? — step-by-step guide
- 01Identify the appropriate application route and eligibility
First determine whether the proposed applicant and activity fall within this procedure. The applicant must satisfy SBP's current EMI Regulations, ownership and capital requirements, governance, safeguarding and technology readiness. Review the separate conditions and exclusions in the eligibility section before submitting any form or payment.
- 02Prepare the application documents and evidence
Start with the particulars listed for this service: Wallet/e-money business model; Source of capital and ownership; Directors and management; Customer-fund safeguarding; AML/CFT, cyber and operational policies.. Ensure the names, applicant identity and documents are consistent. The authority may require further supporting material under its current checklist.
- 03Check the current regulator instructions before filing
Refer to the regulator resource identified on this page (SBP three-stage EMI authorisation ↗). Reconfirm the currently prescribed forms, online or physical submission method, supporting evidence, fee and any current amendments. Do not assume that historic processing times or fees remain applicable.
- 04Classify the proposed e-money product under SBP rules
Confirm wallet/prepaid instrument model, float safeguarding, customer redemption and eligible Pakistani applicant entity.
- 05Seek EMI in-principle approval from SBP
Submit business plan, ownership/management fitness, capital and technical/cybersecurity and AML/CFT controls under the EMI Regulations.
- 06Apply for pilot operations permission
Following SBP's initial approval and conditions, complete systems testing and run the authorised controlled pilot.
- 07Obtain commercial operations approval
Submit pilot readiness/performance and consumer safeguards for full EMI authorisation; in-principle or pilot status alone is insufficient.
- 08Keep the approval record and track ongoing obligations
After the authority has made its decision, retain the acknowledgement, correspondence, evidence of approval and any conditions attached to it. Maintain float safeguarding, consumer and data protection, financial controls and SBP reporting; an in-principle approval is not full authorisation. Check whether separate approvals, renewals or reporting duties apply to the actual business.
Use the current regulator checklist to confirm that every listed item is still required and that any activity-specific conditions have been met. The items below are drawn from the document requirements identified on this page, not a representation that the checklist is exhaustive.
- Wallet/e-money business model
- Source of capital and ownership
- Directors and management
- Customer-fund safeguarding
- AML/CFT, cyber and operational policies.
Before signing or paying, reconcile the particulars across Wallet/e-money business model and Source of capital and ownership; check the applicant and business classification, identify the person authorised to submit, and retain a copy of the final application and official correspondence. Official instructions control if the portal or law has changed.
Regulator resource: SBP three-stage EMI authorisation
After registration or approval
Maintain float safeguarding, consumer and data protection, financial controls and SBP reporting; an in-principle approval is not full authorisation.
EMI licensing: SBP handbook, safeguarding and approval stages
Primary-source research. The following procedural analysis is based on the identified government or regulator sources. Confirm enacted amendments, applicable forms, fees and filing requirements on the date of submission. A consultation draft is not operative law merely because it has been published. This note does not represent final legal-editor certification of the entire guide.
Define e-money rather than generic payment processing
Under the Payment Systems and Electronic Fund Transfers Act, 2007, SBP's revised 2023 EMI Regulations address non-bank electronic money issuers offering wallets, prepaid instruments and related permitted payment services. An EMI is not automatically a bank, deposit-taking institution or a PSO/PSP. Map whether the applicant will actually issue monetary value backed by received funds or only facilitate payment technology.
Apply the October 2026 licensing handbook
SBP BPRD Circular No. 03 of 2026, dated 28 October 2026, states that all new EMI and PSO/PSP authorisation applications are now processed under its consolidated Handbook for Licensing/Authorization of Regulated Entities. This newer instruction must be reviewed together with the operative EMI Regulations (revised 2023), including the electronic submission and ownership requirements, before preparing a first application.
Stage-specific application and safeguards
SBP's EMI regime describes in-principle, pilot and final commercial operating approval, with an optional initiation phase for applicants following the designated route. Prepare a credible product and float-flow diagram, Pakistani incorporation, sponsors' fitness and funds, technology controls, cybersecurity, customer onboarding, transaction monitoring, disaster recovery, safeguarding/trust arrangements and appropriate capital evidence. An in-principle approval does not entitle unrestricted commercial operations.
Pilot testing and go-live
Meet the conditions attached to the actual SBP in-principle and pilot approvals, document testing outcomes, customer fund safeguards, reconciliation, dispute handling and security audits. Commercial operation requires final SBP approval, not a successful mobile-app launch or pilot acceptance. Confirm current fees and minimum capital from the Handbook and operative regulatory schedules before quoting figures.
Official legal and regulatory sources
Governing law & official references
Payment Systems and Electronic Fund Transfers Act, 2007 and SBP Regulations for Electronic Money Institutions, revised in 2023, as amended.
The links below lead to government or official regulatory sources relevant to this service. Use the currently consolidated Act, regulations, statutory checklist and official portal when making an application.
How Chambers can assist
Chambers can review the legal route, identify regulatory constraints, prepare or review the supporting corporate and legal documents, manage the prescribed submission and correspond with the competent authority where instructed. The scope of the engagement will be determined by the applicant’s particular circumstances.
For an initial enquiry, identify the proposed activity, applicant entity and current stage, and provide the available documents indicated above. Please avoid sending confidential or identity-sensitive records through an unencrypted first contact.
Common questions about Electronic Money Institution (EMI) Licensing
Who is eligible for Electronic Money Institution (EMI) Licensing in Pakistan?
The applicant must satisfy SBP's current EMI Regulations, ownership and capital requirements, governance, safeguarding and technology readiness.
What documents are needed for Electronic Money Institution (EMI) Licensing?
Wallet/e-money business model; Source of capital and ownership; Directors and management; Customer-fund safeguarding. Additional requirements can apply to the actual business or regulator.
How can I obtain Electronic Money Institution (EMI) Licensing in Pakistan?
Classify the proposed e-money product under SBP rules: Confirm wallet/prepaid instrument model, float safeguarding, customer redemption and eligible Pakistani applicant entity. Seek EMI in-principle approval from SBP: Submit business plan, ownership/management fitness, capital and technical/cybersecurity and AML/CFT controls under the EMI Regulations. Apply for pilot operations permission: Following SBP's initial approval and conditions, complete systems testing and run the authorised controlled pilot. Obtain commercial operations approval: Submit pilot readiness/performance and consumer safeguards for full EMI authorisation; in-principle or pilot status alone is insufficient.
This guide is general information, not advice on your facts. Check the applicable law, notifications, updated regulator checklists and jurisdiction before acting. The authority alone determines eligibility, acceptance and approval; no outcome or processing period is guaranteed.