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Payment System Operator / Service Provider Authorisation

PSO/PSP authorisation applies to payment networks, switching, gateways and related infrastructure; it differs from issuing customer e-money.

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

PSO/PSP authorisation applies to payment networks, switching, gateways and related infrastructure; it differs from issuing customer e-money.

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.

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Who is eligible for Payment System Operator / Service Provider Authorisation?

Statutory eligibility

Assess whether the business model is a payment system operator/service provider and meets the applicable SBP rules and capital/technical requirements.

Conditions and exclusions for this application

PSO/PSP operations involve payment network or processing infrastructure, not automatically customer e-money issuance. Eligibility depends on SBP category, settlement/technical controls and requisite capital.

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Documents and information for Payment System Operator / Service Provider Authorisation

Prepare the following information for payment system operator / service provider authorisation. The relevant regulator may require further forms or certified evidence, depending on the applicant and chosen procedure.

  • Payments infrastructure design
  • Security and resilience plan
  • Ownership and capital
  • Governance and operational team
  • Settlement and interbank arrangements.
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How can I obtain Payment System Operator / Service Provider Authorisation in Pakistan? — step-by-step guide

  1. 01
    Identify the appropriate application route and eligibility

    First determine whether the proposed applicant and activity fall within this procedure. Assess whether the business model is a payment system operator/service provider and meets the applicable SBP rules and capital/technical requirements. Review the separate conditions and exclusions in the eligibility section before submitting any form or payment.

  2. 02
    Prepare the application documents and evidence

    Start with the particulars listed for this service: Payments infrastructure design; Security and resilience plan; Ownership and capital; Governance and operational team; Settlement and interbank arrangements.. Ensure the names, applicant identity and documents are consistent. The authority may require further supporting material under its current checklist.

  3. 03
    Check the current regulator instructions before filing

    Refer to the regulator resource identified on this page (SBP three-stage PSO/PSP 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.

  4. 04
    Determine whether company is a PSO/PSP or EMI

    PSOs/PSPs provide switching, payment gateway, clearing or processing infrastructure but cannot simply hold customer funds as EMIs.

  5. 05
    Apply for PSO/PSP in-principle approval

    Provide governance/capital, technology architecture, settlement and risk controls, and operator business plan to SBP.

  6. 06
    Undertake authorised pilot operations

    Address SBP findings and arrange system testing, operational resilience, agreements and security arrangements.

  7. 07
    Obtain full commercial authorisation

    After pilot assessment receive SBP commercial operations approval before general provision of the proposed payment-system service.

  8. 08
    Keep 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. Comply with technology audits, transaction reporting, cybersecurity, operational and permitted-scope restrictions. Check whether separate approvals, renewals or reporting duties apply to the actual business.

Before you submit: application file check

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.

  • Payments infrastructure design
  • Security and resilience plan
  • Ownership and capital
  • Governance and operational team
  • Settlement and interbank arrangements.

Before signing or paying, reconcile the particulars across Payments infrastructure design and Security and resilience plan; 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 PSO/PSP authorisation

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After registration or approval

Comply with technology audits, transaction reporting, cybersecurity, operational and permitted-scope restrictions.

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PSO/PSP authorisation: payment infrastructure, not electronic-money issuance

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.

Determine PSO versus PSP activities

Under the Payment Systems and Electronic Fund Transfers Act, 2007, an applicant operating payment infrastructure, switching, clearing or payment services must assess the PSO/PSP rules and exact SBP category. A payment technology vendor, merchant aggregator and issuer of e-money may face different regimes. An authorisation for payment-system operations does not itself permit custody or issuance of customer balances.

The new SBP application rule

BPRD Circular No. 03 of 2026 places new PSO/PSP authorisation applications under SBP's consolidated licensing/authorisation handbook. The SBP payments operations page describes three stages: in-principle approval, pilot operation and commercial approval. The applicant should review the updated handbook and PSO/PSP Rules before relying on historic templates.

Operational evidence and client funds

Provide ownership, Pakistani entity and management details, governance, transaction and settlement architecture, connectivity, operational security, resilience, financial resources and contracts with banks and other participants. SBP's official page states PSOs/PSPs cannot act as custodians of customer money or undertake banking functions; avoid a business plan that assumes they can collect customer deposits without a distinct authorisation.

Pilot, capital and continuing duties

SBP's payments page states a baseline of PKR 200 million or another amount prescribed by SBP from time to time; verify any updated handbook thresholds rather than treating it as an irrevocable figure. Commercial launch follows readiness testing and SBP approval. Track cybersecurity, settlement risk, outsourcing, dispute management and future regulatory reporting against the actual issued authorisation.

Official legal and regulatory sources

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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 Payment System Operator / Service Provider Authorisation

Who is eligible for Payment System Operator / Service Provider Authorisation in Pakistan?

Assess whether the business model is a payment system operator/service provider and meets the applicable SBP rules and capital/technical requirements.

What documents are needed for Payment System Operator / Service Provider Authorisation?

Payments infrastructure design; Security and resilience plan; Ownership and capital; Governance and operational team. Additional requirements can apply to the actual business or regulator.

How can I obtain Payment System Operator / Service Provider Authorisation in Pakistan?

Determine whether company is a PSO/PSP or EMI: PSOs/PSPs provide switching, payment gateway, clearing or processing infrastructure but cannot simply hold customer funds as EMIs. Apply for PSO/PSP in-principle approval: Provide governance/capital, technology architecture, settlement and risk controls, and operator business plan to SBP. Undertake authorised pilot operations: Address SBP findings and arrange system testing, operational resilience, agreements and security arrangements. Obtain full commercial authorisation: After pilot assessment receive SBP commercial operations approval before general provision of the proposed payment-system service.

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.

KNOWLEDGE / REGULATORY INTELLIGENCE

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SBP / 5 Oct 2026SBP announces Pakistan Express Clearing System rolloutREAD BRIEF ↗

Source-linked preliminary briefings; verify current requirements against the original publication.