Skip to main content

Insight article

April 6, 2022

The State Bank’s Digital Banking Framework

Pakistan

The State Bank of Pakistan (SBP) introduced the framework for digital services in January 2022. In terms of this framework, the SBP has sought to establish a separate licensing and regulatory regime for digital banks. The set up of a digital bank will require a separate license. The intention is to create a category of banks which will provide financial solutions through digital and electronic means, with limited physical presence such that any physical channels or access points will require a prior approval from the SBP. 

The framework has been designed for setting-up of new digital banks, but traditional banks (including micro finance banks) can, subject to meeting certain requirements, request a conversion of their institution to that of a digital bank.  

Within the framework, the SBP has created two categories of licenses, one more limited in scope than the other – there is the Digital Retail Bank (DRB) which will provide financial solutions to retail customers, and then the Digital Full Bank (DFB) which may provide financial solutions to retail customers as well as corporate and commercial entities. As a further categorization, each of DRB and DFB can either operate as conventional digital banks or as Islamic digital banks, although conventional DRB and DFB may, with the prior approval of the SBP, offer Islamic window operations. 

The digital banking regime is not however immediately effective – the application process will be followed by a no objection, an in-principle approval, demonstration of operational readiness by prospective licensees, and a pilot stage under a restricted license before the commercial operations of a digital bank will commence. Based on available news, the SBP has limited the number of entities who will be given the license to five (5) with the number of applicants exceeding forty (40), but without further clarity on whether the number of licenses is restricted within the broad categories considered above. This may therefore mean that the market for digital banking will be highly competitive, but concentrated between a few key players.  

The intent behind the digital banking framework is to promote inclusion, innovation, and modernization and follows a long trail of regulatory innovations over the last few years which have included branchless banking by traditional financial institutions in participation with other market players such as telecom companies and technology service providers, the electronic money institutions i.e. non-banking entities who are authorized to issue means of payment in the form of electronic money, and a framework for digital onboarding of customers. A more recent addition to these innovations from the SBP which requires mention is RAAST, being “Pakistan’s first instant payment system that will enable end-to-end digital payments among individuals, businesses and government entities instantaneously”.

The innovative regulations implemented by the SBP are expected to make banking more accessible and convenient for both individuals and businesses.

Stay in touch

Subscribe to our newsletter

Stay in touch
Sending

News/Insight

  • Importance of a name – RIAA wins dismissal of PKR 425 million suit

    The concept of legal personality lies at the heart of the law. Legal persons are the subjects of legal relationships, which confer rights and impose obligations. Most obviously, the law recognizes individuals as natural perso


    Read more
  • RIAA Defends Leading Battery Manufacturer in Tax Fraud FIRs

    We are representing a leading automotive battery manufacturer in tax fraud FIRs filed by the Federal Board of Revenue (FBR). The automotive battery sector is one of the five industries Read more

  • Sindh High Court grants injunction in shipping shortage claim case

    The Sindh High Court recently granted an interim injunction restraining the civil court from passing judgment in suits alleging short landing of imported edible oil cargoes. The injunction, secured by RIAA Barker Gillette on


    Read more
  • RIAA challenges denial of concessional customs duty for pharma industry

    We represent a global consumer healthcare and pharmaceutical industry leader in a complex customs duty dispute before the Sindh High Court. The case challenges the denial of concessionary customs duty rates on materials requi


    Read more
  • Pakistan Public Private Partnership Laws 2025

    We authored the Read more

What clients say...

  • Chambers Asia Pacific 2022
    "RIAA are responsive, professional and polite in explaining their advice, well researched in their opinions, and reliable in their response time… they also share commercial and operational consequences of the options presented in their advice. We are very happy with their support…." - Chambers Asia Pacific 2022

  • The Legal 500 2022
    “RIAA has an excellent litigation practice that advises on the full range of contentious issues as well as international arbitrations. The practice regularly handles all forms of civil, commercial, corporate, regulatory and white-collar crime matters before all the courts in Pakistan. It has extensive experience in a diverse range of industry sectors …” – The Legal 500 2022

  • Chambers Asia Pacific 2022
    "We find them to be extremely professional and responsive. They are meticulous in raising all the right legal points but at the same time are very solution-oriented in helping to structure the transactions in the right way to fully protect our legal rights." – Chambers Asia Pacific 2022

  • The Legal 500 2022
    “The team has an excellent track record of working on some of the most significant projects in Pakistan throughout the years.” – The Legal 500 2022 

  • Legal 500 2021
    We have worked with RIAA Barker Gillette for many years on a number of matters, including regulatory issues, labor, general corporate, competition law, and tax matters…..We have found high-quality lawyers across disciplines, who are able to balance the requirement for technically sound advice while also being practical and solution-orientated - Legal 500 2021

Read more
Send this to a friend