finpeel Answers · KSA · updated 2026-08-14
Electronic-money issuance is a regulated payment service under SAMA’s payments framework. A non-bank provider must fit the applicable Electronic Money Institution licence category under the current Implementing Regulations.
The rules distinguish payment-institution and electronic-money-institution categories and also recognise agents and electronic-money distributors. The correct structure depends on who legally issues the e-money and who merely distributes it.
Do not treat prepaid value or a wallet balance as ordinary software functionality when the business is actually the issuer of the monetary value.
Regulator: Saudi Central Bank (SAMA)
Primary sources: SAMA — Law of Payments and Payment Services · SAMA — Implementing Regulations of the Law of Payments and Payment Services
Directional — not legal advice. Verify with the regulator before committing.
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