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Electronic Money Institution (EMI) Licensing

An EMI is an SBP-regulated non-bank issuer of electronic money and digital payment instruments.

PAKISTAN BUSINESS REGISTRATION & LICENSING GUIDESDRAFT UPDATED 11 OCTOBER 2026State Bank of Pakistan
01

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.

02

Who is eligible for Electronic Money Institution (EMI) Licensing?

Statutory eligibility

The applicant must satisfy SBP's current EMI Regulations, ownership and capital requirements, governance, safeguarding and technology readiness.

Conditions and exclusions for this application

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.

03

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.
04

How can I obtain Electronic Money Institution (EMI) Licensing in Pakistan?

  1. 01
    Classify the proposed e-money product under SBP rules

    Confirm wallet/prepaid instrument model, float safeguarding, customer redemption and eligible Pakistani applicant entity.

  2. 02
    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.

  3. 03
    Apply for pilot operations permission

    Following SBP's initial approval and conditions, complete systems testing and run the authorised controlled pilot.

  4. 04
    Obtain commercial operations approval

    Submit pilot readiness/performance and consumer safeguards for full EMI authorisation; in-principle or pilot status alone is insufficient.

Regulator resource: SBP three-stage EMI authorisation

05

After registration or approval

Maintain float safeguarding, consumer and data protection, financial controls and SBP reporting; an in-principle approval is not full authorisation.

07

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.

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