Do I need a licence to run a payments company in Saudi Arabia?

What this means

The old 2020 Payment Services Provider Regulations should not be used as the current primary framework: SAMA states that they were superseded by the Implementing Regulations of the Law of Payments and Payment Services. Current licensing guidance distinguishes payment-institution and electronic-money-institution models, including different licence levels within those types.

The starting point is to map the exact service: whether the business issues electronic money, provides payment accounts, executes or transfers payments, acquires transactions, or provides another regulated payment service. The legal entity and service combination then determine the authorisation path.

A software or infrastructure provider is not automatically a licensed payment service provider merely because its technology is used in a payment flow. The analysis should identify which entity actually provides the regulated payment service to the customer or merchant.

Article 44 distinguishes initial capital by category: Micro Payment Institution SAR 1 million; Major Payment Institution SAR 3 million; Micro Electronic Money Institution SAR 2 million; and Major Electronic Money Institution SAR 10 million. A licence route also has activity and scale conditions. Article 45 imposes ongoing capital tests, including the higher of initial capital or the applicable volume-based requirement for major institutions.