Buy now, pay later licence

Where BNPL sits in Saudi law

BNPL is licensed as a finance activity, separate from the payments regime. The amended Implementing Regulation of the Finance Companies Control Law defines it as financing a borrower to buy goods or services from stores with no term cost payable by the borrower. A BNPL provider therefore applies under the finance rules, even though its product sits inside a checkout.

Three documents set the requirements: the Rules for Regulating BNPL Companies (circular 450360390000, 17 December 2023), the License Application Guidelines for BNPL (24 January 2024), and the FCCL Implementing Regulation as amended by Governor's Decision 179/MFC, which repeats the SAR 5 million capital figure in Article 8. SAMA amended the consumer limit in December 2025, covered below.

The core requirements

What a BNPL company may not do

Article 20 of the BNPL Rules limits the product. A BNPL company may not charge consumers any fee apart from the delay or collection fees allowed under the Debt Collection Regulations. The rules once allowed an administrative fee of up to the lower of 1% or SAR 50, but SAMA suspended it by decision on 14/02/1446H. New products need SAMA's non-objection before launch.

Customers must be at least 18 in Hijri years. Serving non-resident foreigners, or financing purchases in currencies other than the riyal, needs SAMA's non-objection. Combined with the SAR 10,000 cap and the 12-instalment maximum, these limits shape the credit model, the onboarding flow and the merchant contract, so settle them before writing policies.

How the application runs

1. Submit by email

   Send the application and supporting documents to SAMA by email, following the BNPL License Application Guidelines, including fit and proper forms for management and the bank guarantee.

2. Completeness and questions

   SAMA confirms when the file is complete. Answer any request for more information within 30 working days.

3. Initial approval

   SAMA gives initial approval, or a reasoned rejection, within 60 working days of the completeness notice.

4. Incorporate

   Incorporate the joint stock company, or update the commercial registration, within six months of initial approval, or the approval lapses.

5. LEI and licensing visit

   Obtain a Legal Entity Identifier from the Saudi GLEIF-accredited operating unit, then host SAMA's licensing visit.

6. Licence decision

   SAMA issues the licence decision. The fee is SAR 5,000.

Bank guarantee and renewal: two open points

The bank guarantee at application is one of the places where the documents differ. Article 4(8) of the BNPL Rules asks for a guarantee equal to the full minimum capital for a company under establishment. The BNPL Licence Guidelines and Article 7(8) of the amended FCCL Implementing Regulation both say 20%. The later documents point to 20%, but neither text has been withdrawn, so ask SAMA which figure applies.

Renewal timing also differs. The BNPL Rules (Article 10) ask for a renewal application at least three months before expiry, while the general rule in the amended FCCL Implementing Regulation (Article 18) is six months. Filing six months ahead satisfies both.

Ongoing obligations after licensing

• Written policies on governance, merchant onboarding, credit, risk, compliance, security, outsourcing and HR
• Records kept for 10 years
• AML/CTF compliance and a CDD and KYC programme, including phone token verification and national address checks
• Outsourcing under SAMA's Rules on Outsourcing for Finance Companies, and an external auditor approved by SAMA
• A complaints function, SAMA's Responsible Lending Principles, and credit bureau checks and reporting with customer consent
• SAMA's Advertising Rules, a conflict-of-interest policy, licence disclosure, and the contract contents the rules prescribe for consumers and merchants
• The Senior Positions Requirements, Cyber Security Framework, Business Continuity Management Framework and Financial Consumer Protection Principles, which the BNPL Rules cross-reference

People: Saudization and senior roles

BNPL companies start at 50% Saudi staff across all departments and levels and add 5% a year until they reach 75%. Non-Saudis in control functions need SAMA's non-objection. Separately, the Senior Positions Requirements reserve the Chief Compliance Officer and AML/CTF Director roles for Saudi nationals, and those appointments need SAMA's written non-objection. The English text of those requirements says it is not the latest version, so use the Arabic. An outsourced MLRO does not replace either role. See compliance function.

SAMA continues to license BNPL companies. Its news releases announced new BNPL licences in April, May, July and August 2026.

Common questions