We advise founders and businesses building or adding digital payment, wallet or lending products on licences, customer terms and agreements with banks and vendors.
Overview
Fintech, short for financial technology, covers digital payments, wallets, online lending, money transfer and other financial services delivered through technology. Because these services involve other people’s money and data, they are regulated more closely than many other types of business.
The first legal question is usually what your product actually does. The same app may be a payment service, a lending platform or neither, depending on how money moves and who holds it. That answer determines which regulator is involved and whether a licence or approval is needed.
We help founders and established businesses understand that position early, so that design decisions are made with the regulatory picture in mind. We also prepare and review the agreements that digital finance depends on, such as terms with customers, banks and technology partners.
The rules in this area change, so we check the current position when we advise, and we say so clearly if a point is uncertain.
Who we help
- Founders building a digital payment, wallet or lending product.
- Established businesses adding a financial feature to their service.
- Technology providers working with banks and financial institutions.
- In-house counsel who need support on a regulatory or contractual question.
How we work
- We map what the product does and how money and data move.
- We identify the regulators and rules likely to be relevant, and the open questions.
- We agree the scope and fee approach, including alternative fee arrangements where suitable.
- We draft or review the agreements and policies you need and advise on next steps.
What to bring to a first conversation
Bring a short description of what the product does, who the customers are, how money or data moves through it, and which partners, such as banks or payment providers, are involved. Existing terms of use, privacy notices and partner agreements are useful. Say which stage you are at, whether idea, pilot or live, since the questions to ask differ. Whether a licence or approval applies depends on the activity, and we will flag it as an open question.
Typical work
Assessment of which licences and approvals a product may need
Read the related questionCustomer terms and conditions and a privacy policy
Read the related questionAgreements with banks, payment partners and technology vendors
Read the related questionStructure and documents for an investment round
Read the related questionCompliance policies for a financial technology business
Read the related question
How a digital finance product is usually launched
Every product differs. This is a general outline, not advice on your product.
Describe the product
We map what the product does, how money moves and who holds customer funds.
Identify the rules and regulators
We work out which licences, registrations and approvals may apply.
Set up the company and partners
The business is structured, and agreements with banks, payment partners and vendors are signed.
Prepare customer documents and policies
Customer terms, a privacy policy and internal compliance policies are written.
Apply, launch and keep compliant
Applications are made where required. After launch, records and reporting are kept current.
Frequently asked questions
Information on this website is general in nature and is not legal advice. Anything that depends on the law is marked until a lawyer has checked it.
What counts as fintech in legal terms?
Fintech means technology used to deliver or improve financial services, such as digital payments, wallets, online lending and money transfer. The law looks at what the service actually does with money and customers, not at the label. So two similar apps can face different rules.
Do I need a licence to run a fintech product in Pakistan?
Some financial activities need a licence or another approval, and operating without one can have serious consequences. Whether your product needs one depends on exactly how it works, who holds customer money and what you offer. Get advice before launch, not after.
More detail
We start by mapping what your product does, then identify the regulator and the approvals that may apply.
Which regulator oversees digital payments?
Several bodies can be involved. The State Bank of Pakistan oversees payment systems and many financial institutions, while the Securities and Exchange Commission of Pakistan oversees companies and parts of the capital markets. Which applies depends on your product, so it must be confirmed case by case.
What should I prepare before launching a digital finance product?
Prepare a clear description of how the product works and how money moves. Have your company documents, draft customer terms, a privacy policy, partner agreements and internal policies ready. Check the licensing position first, since it can shape the rest of your timeline and plans.
What do I need to tell customers about their data?
You should explain in plain language what data you collect, why, how it is stored and who sees it. A privacy policy is the usual place. The rules on personal data in Pakistan have been developing, so the current position must be checked when you launch.
How do I work with a bank or payment partner?
You normally sign an agreement that sets out what each side does, the fees, how money and data move, and who is responsible if something goes wrong. Partners often have their own due diligence checks. Have the draft reviewed before you sign, as terms are hard to change later.
How long does a regulatory approval take?
It varies with the approval, the regulator and how complete your application is. We cannot promise a time, because the regulator decides. A clear application and early preparation usually help. We tell you what we know about the process at the start and update you as it moves.
What terms should a fintech app’s user agreement include?
It should say who the provider is, what the service does, fees, how accounts can be used or closed, and how disputes and complaints are handled. It should also explain privacy, security and customer responsibilities. The exact terms depend on the product and the rules that apply.
Do I need a lawyer at the idea stage?
It is not required, but it often helps. At the idea stage, a short discussion can show whether a licence might be needed, how to structure the company and which risks to plan for. Changing course early is much cheaper than after launch.
Glossary
- Fintech
- Technology used to deliver or improve financial services, such as payments, lending or money transfer.
- Digital wallet
- An app or account that stores money electronically so the holder can pay or transfer it.
- Payment service provider
- A business that helps move money between customers and merchants. Rules on these businesses may apply.
- Licence
- Official permission to carry on a regulated activity. Operating without one when it is needed can be unlawful.
- KYC (know your customer)
- Checks a financial business carries out to confirm who its customers are.
- AML (anti-money laundering)
- Rules and controls aimed at stopping criminal money moving through the financial system.
- Personal data
- Information that identifies a person, such as a name, phone number or account details.
Sources
Official bodies named for reference. Check the current text of any law with the body itself or with a lawyer.
- State Bank of PakistanCentral bank and regulator of payment systems. Check its current rules.
- Securities and Exchange Commission of Pakistan (SECP)Regulator for companies and parts of the financial sector.
- Payment Systems and Electronic Fund Transfers Act, 2007A law on payment systems. Check the current text.
- Pakistan Code (Ministry of Law and Justice)Official federal law database.
Questions about your own matter? Send us a message.
General information. Not yet reviewed by a lawyer.
How we write and check this content: editorial policy.
Information on this website is general in nature and is not legal advice.