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SBP2026-10-28BPRD Circular No. 03 of 2026, dated 28 October 2026

SBP makes consolidated licensing handbook applicable to new regulated-entity applications

Operative circularLicensing and authorisation

SBP has consolidated and updated its licensing instructions into one handbook. Every new application for the seven identified categories of regulated entities is to be processed under that handbook; the circular does not expressly determine treatment of applications already pending.

REGULATORY INTELLIGENCE / PRIMARY SOURCE REVIEW

BPRD Circular No. 03 of 2026, dated 28 October 2026 · Reviewed 29 October 2026. The original instrument and subsequent amendments govern.

SBP has consolidated and updated its licensing instructions into one handbook. Every new application for the seven identified categories of regulated entities is to be processed under that handbook; the circular does not expressly determine treatment of applications already pending.

01 / REGULATORY ANALYSIS

Exactly what changes

BPRD Circular No. 03 of 2026, issued on 28 October 2026, announces that SBP's existing licensing and authorisation instructions have been consolidated and updated in the Handbook for Licensing/Authorization of Regulated Entities. The circular invokes section 4C(h) of the State Bank of Pakistan Act, 1956 as the regulatory authority. Its operative direction is that all new applications received for the specified types of licence or authorisation will henceforth be processed under the handbook.

The affected categories are banks, digital banks, microfinance banks, exchange companies, electronic money institutions (EMIs), payment system operators/payment service providers (PSOs/PSPs), and private credit bureaus. The announcement is not a general licence to undertake regulated financial activity, nor is it a SECP licensing circular for NBFCs.

02 / REGULATORY ANALYSIS

Timing, legal status and transitional issues

The circular is final and dated 28 October 2026. It uses the word henceforth for new applications and does not specify a separate future commencement date. It does not expressly say that every pending application is retrospectively governed by the consolidated handbook, nor does it set out transitional treatment in the short circular text.

Applicants should obtain and review the full handbook, including the provisions specific to their proposed licence category, before submitting an application. The circular confirms the governing document but does not itself reproduce every eligibility criterion, capital threshold, shareholding test or checklist. No unverified threshold should be inferred from the announcement.

03 / REGULATORY ANALYSIS

Practical implications for sponsors and advisers

Prospective sponsors should first classify their proposed regulated activity correctly, then map the applicable handbook chapter against the proposed legal entity, ownership, governance, technology, funding and operational plan. This is a recommended preparation exercise, not a claim that each listed item is newly mandated by the circular.

Legal and compliance teams should retain the version of the handbook relied on at filing, record application receipt dates, reconcile any earlier SBP guidance with the consolidated text, and seek written clarification where an existing application is affected. A new handbook can materially change application preparation even where the business model itself has not changed.

CHAMBERS / PRACTICAL VIEW

Why this development matters

The operative change is a single updated reference document for new applications across seven SBP-regulated entity categories. Sponsors should verify the handbook's actual detailed requirements before committing to a licensing timetable.

Specific steps for affected organisations

  • Identify the precise licence or authorisation category before drafting the application.
  • Obtain the current SBP handbook and check the relevant chapter, annexures and application checklist.
  • For pending applications, confirm transitional treatment directly with SBP rather than assuming retrospective application.
  • Keep a dated compliance matrix and preserve evidence of the handbook version used.

Timing and legal status

Issued 28 October 2026; operative according to its terms without a later commencement date specified in the circular.

The official circular announces the consolidated handbook; this briefing does not claim to reproduce the handbook's unverified annexes, capital requirements or application fees.

PRIMARY REFERENCEBPRD Circular No. 03 of 2026, dated 28 October 2026

SBP BPRD Circular No. 03 of 2026 (original circular)

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