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Bahrain: fintech & payments regulation

Regulated

CBB regulates fintech via Payment Services Module; BD 2m capital for new entities

Lead regulator
Central Bank of Bahrain (CBB)
Also involved
—
Core law
Law No. (23) of 2025 Amending Provisions of the Law of Commerce
Entry capital
BD 2,000,000 (Retail/Wholesale)
Approval timeline
—
Customer assets
Safeguarded and segregated per Client Money Requirements
Data protection
Personal Data Protection Law 2018 · PDPLRA
Sandbox
Yes - CBB Regulatory Sandbox

The CBB is the primary supervisor for fintech and payments, operating under the CBB Rulebook. A major regulatory shift is underway with the proposed Payment Services Requirements Module, which unifies the licensing of payment service providers, money changers, and open banking participants. Recent consultations propose raising the minimum initial capital for new retail and wholesale licensees to BD 2 million, signaling a tightening of entry barriers to ensure financial stability.

Which licence do you need?

Your activityRequirementCapitalTimelineAuthority
Payment processing / gatewayLicencePayment Service Provider[1][2]

Unified framework under proposed Payment Services Module

BD 2,000,000—CBB
E-money & wallet issuanceLicencePayment Service Provider[1][3]

Includes prepaid cards and electronic instruments

BD 2,000,000—CBB
Domestic money transferLicencePayment Service Provider[1]

Domestic transfers covered under unified payment rules

BD 2,000,000—CBB
Cross-border remittanceLicencePayment Service Provider[1]

Cross-border payments included in payment service scope

BD 2,000,000—CBB
Agent networkLicencePayment Service Provider[1]

Agent networks must operate under licensed PSP umbrella

BD 2,000,000—CBB
Open banking / account informationLicenceAISP/PISP[4][5]

Requires CBB approval; embedded auth flows mandated

——CBB
Foreign-exchange servicesLicenceMoney Changer[6][7]

Money changers regulated under High-Level Controls Module

——CBB

New — what changed recently

  • 2026-06-01Law No. (23) of 2025 Draft Resolutions — Draft resolutions issued to regulate partial cheque payments and standardize credit reporting for returned cheques.[8]
  • 2026-03-10Consultation on Initial Capital Requirements — Proposal to raise minimum initial paid-up capital for new retail and wholesale licensees to BD 2 million.[2]
  • 2026-03-05Proposed Payment Service Requirements Module — Unified regulatory framework established for payment service providers, money changers, and open banking participants.[1]

Market-entry checklist

  1. 1Secure BD 2m initial capitalEnsure paid-up capital meets the proposed BD 2 million minimum for new retail or wholesale licensees.
  2. 2Apply for PSP licenseSubmit application under the new Payment Services Requirements Module for payment processing or e-money.
  3. 3Implement client money safeguardsEstablish segregation and safeguarding protocols for client funds as per the Client Money Requirements.
  4. 4Comply with open banking rulesIf offering AISP/PISP, ensure embedded authentication flows and obtain direct CBB approval.
  5. 5Adhere to high-level controlsImplement unified regulatory standards for internal audit, compliance, and risk management.

Sources

  1. Proposed Payment Service Requirements Module · 2026-03-05
  2. Consultation on Proposed Revision to Initial Capital Requirements · 2026-03-10
  3. Proposed Amendments to the Authorisation Module for Ancillary Service Providers · 2017-01-05
  4. Proposed Requirements for Open Banking Authentication, ASPSP Disclosures and AISP/PISP Reporting on API Performance Statistics · 2023-10-18
  5. Proposed Amendments to Open Banking Regulations · 2021-07-11
  6. Central Bank of Bahrain Consultation on Revised High-Level Controls Module (Module HC) · 2023-07-24
  7. Volume 5 Draft Common Modules and Specific Modules for Money Changers Licensees · 2010-10-01
  8. CBB Draft Resolutions Pursuant to Law No. (23) of 2025 Amending Provisions of the Law of Commerce · 2026-06-01
This guide is compiled automatically from 8 primary-source documents published by Bahrain's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.