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Pakistan: fintech & payments regulation

Regulated

SBP-regulated fintech via Exchange Companies and Raast; no standalone VASP license

Lead regulator:
State Bank of Pakistan (SBP)
Key law:
Anti-Money Laundering Act, 2010
Last updated:
2026-07-12

Pakistan regulates digital financial services primarily through the State Bank of Pakistan (SBP) under the framework for Exchange Companies and the Raast instant payment system, rather than a standalone Virtual Asset Service Provider (VASP) license. The SBP mandates that fintech and payment service providers operate as authorized intermediaries or exchange companies, subject to strict capital, audit, and reporting requirements.

The regulatory stance emphasizes anti-money laundering compliance, with the Financial Monitoring Unit (FMU) requiring banks holding customer accounts to file Currency Transaction Reports for interoperable and PSP-mediated transfers. Recent directives have facilitated inward remittances, allowed digital disbursements via Raast, and established a registry of digital service providers to ensure oversight.

While the SBP has launched PRISM+ for real-time interbank settlement and issued guidelines for Islamic banking and primary dealers, there is no explicit legal framework for crypto-asset trading or issuance. Consequently, activities outside the authorized Exchange Company and banking channels remain restricted or unregulated, with the SBP maintaining a cautious, compliance-focused approach to digital finance.

Who regulates

  • State Bank of Pakistan (SBP)

    Primary supervisor for payment systems, exchange companies, and banking/fintech intermediaries

    [1][2][3][4][5][6][7][8][9][10]

  • Financial Monitoring Unit (FMU)

    National FIU responsible for receiving and analyzing suspicious transaction reports and CTRs

    [11]

Core laws & rules

  • Anti-Money Laundering Act, 2010 (2010)

    Establishes the legal basis for AML/CFT compliance, including reporting obligations for financial institutions and designated non-financial businesses and professions (DNFBPs) such as exchange companies.

    [11]

  • Regulatory Framework for Exchange Companies (Undated (Amended 2026))

    Governs the operations of authorized exchange companies, including inward remittances, digital disbursements via Raast, and forward sale transactions.

    [7]

Licensing & registration

  • Exchange Company License

    Required for entities facilitating foreign exchange and remittances; must secure prior departmental approval and complete Raast onboarding for digital disbursements.

    [7]

  • Digital Service Provider Registration

    Entities acting as intermediaries for foreign digital service providers must be listed in the SBP's official registry and meet strict documentation and audit requirements.

    [8][3]

  • Primary Dealer Status

    For government securities trading; requires Board-approved business plans and specific capital/IT infrastructure.

    [12][10]

Restrictions & warnings

  • Interoperable fund transfers and PSP-mediated payments require the bank holding the customer's account to file Currency Transaction Reports (CTRs) with the FMU, placing sole reporting responsibility on the custodian bank.

    [11]

  • Foreign digital service providers' intermediaries are prohibited from engaging in inward remittance-related businesses.

    [3]

  • Remittance of royalty, franchise, and technical service fees is capped at 8% of net local sales for specified sectors, excluding the financial industry.

    [13]

Direction of travel

  • The SBP is actively modernizing payment infrastructure with PRISM+ and promoting digital inclusion through Raast, while maintaining strict AML/CFT oversight via the FMU and Exchange Company framework.

    [5][9][7]

  • Regulatory focus remains on facilitating legitimate cross-border flows for IT freelancers and home remittances, with no indication of a standalone crypto-asset licensing regime.

    [6]

Sources

  1. SBP Guidelines for Facilitating Conversion of Conventional Banking Branches into Islamic Banking Branches · 2026-06-16
  2. Instructions on Islamic Banking Windows Operations · 2026-06-10
  3. Distribution of Services by Intermediaries/Aggregators · 2026-05-22
  4. Instructions for Legacies and other Distributions of Assets of Deceased Persons · 2026-05-12
  5. Operating Rules for PRISM+ (Pakistan Real-time Interbank Settlement Mechanism Plus) · 2026-04-16
  6. Facilitation for IT Companies and Freelancers · 2026-04-06
  7. Amendment in Instructions Related to Business of Exchange Companies · 2026-01-15
  8. Appendix V-147-List of Digital Service Provider Companies · 2026-01-13
  9. Launch of the Pakistan Real-Time Interbank Settlement Mechanism Plus (PRISM+) · 2025-06-11
  10. Selection of Primary, Preliminary Primary, and Special Purpose Dealers for Fiscal Year 2025-26 · 2025-05-07
  11. Clarification on Reporting of Currency Transaction Reports (CTRs) under the Anti-Money Laundering Act, 2010 to the Financial Monitoring Unit (FMU) · 2025-03-21
  12. Guidelines for the Submission of Business Plan by Institutions at the time of Application for Primary Dealer (PD), Preliminary Primary Dealer (PPD) and Special purpose Primary Dealer (SPD) Status · 2026-05-07
  13. Revision in Instructions for Remittance of Royalty, Franchise and Technical Service Fees for Agriculture, Social, Infrastructure and Service Sector Projects · 2025-12-19

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This guide is compiled automatically from 13 primary-source documents published by Pakistan'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.