When a wallet needs an EMI licence
Article 6 of the Implementing Regulations of the Law of Payments and Payment Services lists issuing electronic money, including e-wallets, as a regulated payment service. The payment institution categories exclude it, so a stored-value product that holds customer balances needs an EMI licence even if it also does things a payment institution could do.
Some stored-value products fall outside the law. Article 7 excludes limited-network instruments, which are usable only within a defined network. Their providers register with SAMA instead of applying for a licence, and must notify SAMA if transactions pass SAR 5 million in 12 months or SAR 2 million in any month (Article 49), at which point SAMA may require a licence. On our reading, a card usable only inside one defined network may fit there; a general-purpose wallet will not.
Micro or Major e-money institution
| Micro EMI | Major EMI | |
|---|---|---|
| Average outstanding e-money | SAR 10m or less | No aggregate ceiling stated |
| Average monthly payment value | SAR 10m or less | No aggregate ceiling stated |
| Per-user holding cap | SAR 20,000 | SAR 100,000 |
| Per-user monthly transaction cap | SAR 20,000 | SAR 100,000 |
| Initial capital (Art 44) | SAR 2,000,000 | SAR 10,000,000 |
| Ongoing capital (Art 45) | The initial amount | The higher of SAR 10m or 2% of average outstanding e-money |
| Legal form (Art 14) | Joint stock company | Joint stock company |
| Licence fee (Art 23) | SAR 20,000 | SAR 50,000 |
| Term (Art 17) | Up to 5 years | Up to 5 years |
Implementing Regulations Arts 14, 17, 23 and 42 to 45. An EMI becomes Major once it exceeds any Micro limit. SAMA may raise the per-user limits for either category on application.
Planning for the jump to Major
A Micro EMI moves into the Major category as soon as it passes any one of the Micro limits: outstanding e-money, monthly payment value, or the per-user caps. For a consumer wallet the SAR 20,000 per-user holding cap is often the first to bite, especially for salary or remittance use cases. SAMA may raise the per-user limits on application, so build the case into the business plan if your users need more headroom.
Major EMI capital grows with the float. At SAR 750 million of average outstanding e-money, 2% is SAR 15 million, so the requirement rises above the SAR 10 million floor. Model it alongside safeguarding: the float itself is ring-fenced, so the capital has to come from shareholders.
Safeguarding customer float
Customer funds must be safeguarded as soon as they are received. Funds still held at the end of the business day after receipt go into a segregated account at a licensed bank named "Deposit and Safeguard of Funds of a Payment Service Provider's Clients", or into secure liquid assets SAMA approves, held with an authorised custodian. The float cannot be used for any other purpose, including lending, and the licensee reports on safeguarding compliance to SAMA.
The application must include a safeguarding policy and the agreement with the safeguarding bank. For a wallet business, the bank relationship is often the longest lead item in the file, so start that conversation before the business plan is final.
Agents and distributors
Many wallets grow through agents and distributors. Appointing an agent needs SAMA's non-objection (Article 24). An e-money distributor arrangement needs a business plan filed 30 days before it starts and a notification to SAMA within 10 days (Article 25). The EMI stays liable for its agents and files an annual agent report (Article 26). Because the licensee is liable for its agents, the AML programme has to cover agent onboarding and monitoring.
AML, fraud and security for wallet flows
- A risk-based AML/CTF programme under Article 36, written to the AML Law (Royal Decree M/20), the CTF Law (M/21) and SAMA's AML/CTF Guide
- Targeted financial sanctions screening under SAMA's Rules for the Implementation of Targeted Financial Sanctions (7 December 2025)
- Beneficial ownership checks, including SAMA's March 2026 circular on UBO verification through the Wathq service
- Integration with the Security Council Resolutions Notification System, the subject of SAMA circular 482028988 of 1 October 2026
- Fraud detection within the risk and compliance function (Article 28)
- SAMA's Cyber Security Framework (Article 34), the Business Continuity Management Framework (Article 33), and data protection and confidentiality rules (Article 37)
How the application runs
Incorporate as a joint stock company, or plan to
Both EMI categories must be JSCs. Commercial registration and articles must be completed within 180 days of approval in principle. See incorporation.
Submit the in-principle file
The License Application Form, fit and proper forms, feasibility study, three-year business plan with ICAAP and liquidity assessment, bank guarantee, safeguarding policy with the bank agreement, and the full policy set, sent to NBFI-LIC@SAMA.GOV.SA.
Answer SAMA's questions
Additional information is due within 30 calendar days of a request.
Decision
SAMA decides within 90 calendar days of confirming the file is complete, or notifies a revised timeline. Approval in principle lasts up to one year, extendable by 180 days, and does not authorise operations.
Licence
Meet the conditions, pay the fee and receive the licence. The licence appears on SAMA's public register.
Common questions
Can a Micro EMI be a limited liability company?
No. Article 14 requires Micro and Major e-money institutions to be joint stock companies. Only a Micro payment institution may be an LLC or simplified JSC.
Can we raise the SAR 20,000 per-user limit?
SAMA may raise the Micro EMI per-user holding and monthly transaction limits on application, and the same applies to the Major EMI limits of SAR 100,000. Make the case in the business plan, with the controls that go with higher limits.
Can we lend out or invest the wallet float?
No. Safeguarded funds may not be used for any other purpose, including lending. They sit in a segregated account at a licensed bank, or in secure liquid assets SAMA approves with an authorised custodian.
Who must be Saudi in the senior team?
The Chief Compliance Officer and the AML/CTF Director must be Saudi nationals under the Senior Positions Requirements, and both need SAMA's written non-objection. The English text of those requirements is not the latest version, so work from the Arabic. See compliance function.
Primary sources
- SAMA Rulebook: Implementing Regulations of the Law of Payments and Payment Services
- SAMA Rulebook: Guidelines to Apply for Payment Service Providers License
- SAMA Rulebook: AML/CTF Guide
- SAMA Rulebook: Rules for the Implementation of Targeted Financial Sanctions
- SAMA Rulebook: Cyber Security Framework
- SAMA Rulebook: Requirements for Appointments to Senior Positions (Arabic, current version)
Last reviewed: 11 October 2026
General information, not legal advice. Saudi rules change; we confirm every requirement against the regulator's current text before you file.
