Fintech regulation in the GCC, MENA, and emerging markets has matured from a patchwork of exemptions and sandboxes into a coherent set of licensing regimes covering payment institutions, electronic money, open banking, lending platforms, and digital banks. Esquare Legal advises fintech founders, payment service providers, EMI applicants, and traditional financial institutions launching digital products across UAE, Bahrain, KSA, Pakistan, Brazil, and the offshore centres.
What “Fintech Law” Actually Covers in Practice
Fintech is a category broad enough to include almost any technology-enabled financial service. The regulatory work breaks down into distinct workstreams that vary by jurisdiction and by the specific product being built.
Payment services and EMI licensing
Electronic Money Institution licensing, payment service provider authorisation, and stored value facility licensing are the foundational regulatory categories for fintech operations that move funds. The UAE Central Bank, the State Bank of Pakistan, the Central Bank of Bahrain, and the Central Bank of Brazil each operate distinct frameworks with different capital requirements, governance expectations, and operational restrictions. Choosing the right primary licence is the structural decision that defines everything downstream.
Digital banking and BaaS
Full digital bank licensing is a multi-year undertaking with capital requirements in the tens of millions of dollars in most jurisdictions. The more common path for fintech operators is Banking-as-a-Service partnerships with licensed banks, where the fintech operates the user-facing product and the licensed bank provides the underlying regulated infrastructure. The legal work is the BaaS agreement architecture, regulatory delineation of responsibilities, and the AML and consumer protection compliance that sits on the fintech side.
Open banking and account information services
Open banking frameworks are now operational in the UAE, Bahrain, and KSA, with Pakistan following. Account information service providers and payment initiation service providers require specific authorisation, ongoing compliance with technical security standards, and operational integration with the central bank's open banking infrastructure.
Lending platforms, P2P, and consumer credit
Lending fintech requires authorisation under consumer credit, peer-to-peer lending, or non-bank financial institution frameworks depending on jurisdiction. The work includes interest rate and disclosure compliance, AML and KYC architecture appropriate to lending risk, and structural questions about whether the platform is a balance-sheet lender, a marketplace, or a peer-to-peer facilitator.
Crypto-fiat on-ramps and stablecoin payments
For fintech operators bridging traditional finance and crypto, the regulatory work spans both fintech licensing (the fiat side) and virtual asset regulation (the crypto side). Stablecoin issuance, in particular, increasingly sits at the intersection of payment regulation and virtual asset law, with the UAE Central Bank, MAS, MiCA, and the GENIUS Act in the US all building specific frameworks for stablecoin issuers.
The Jurisdictions We Cover
United Arab Emirates. UAE Central Bank Stored Value Facility licensing, Retail Payment Services licensing, the SVF and RPS frameworks, ADGM FSRA digital banking and payment services authorisation, and DIFC DFSA fintech licensing. The choice between mainland, ADGM, and DIFC has material consequences for the operating model.
Bahrain. CBB Payment Services Provider licence, CBB Crypto-Asset module, Bahrain Open Banking Framework. Bahrain has been an early mover on crypto-fintech convergence and offers a regulatory sandbox that has hosted several first-in-region deployments.
Saudi Arabia. SAMA fintech regulation, Open Banking Framework, Digital Riyadh policy environment. The KSA fintech market is structurally significant given the size of the underlying economy and the Vision 2030 commitment to digital infrastructure.
Pakistan. SBP Electronic Money Institution licensing, Payment Service Provider/Payment System Operator framework, branchless banking. With the launch of PVARA in 2026, the convergence of Pakistani fintech and virtual asset regulation has become more substantive.
Brazil. BCB payment institution licensing across the four payment institution categories (electronic money issuer, payment issuer, acquirer, and credit issuer), Pix integration, and the rapidly maturing BCB virtual asset framework.
Malaysia, Indonesia, and Singapore. LFSA Labuan licensing, OJK Indonesian payment authorisation, and MAS Payment Services Act licensing.
How Esquare Legal Works on Fintech
We advise on the full lifecycle — from pre-incorporation regulatory strategy through licensing application, through licensed operations and into the cross-border expansion that most successful fintech operations eventually pursue. The work includes corporate structuring of the entity to fit the regulatory regime, the licensing application itself (capital, governance, AML/CFT, technology), commercial documentation including BaaS agreements and payment processor contracts, ongoing supervisory engagement, and at scale, the international expansion work to add jurisdictions to the operational footprint.
For founders, we operate fixed-fee engagement letters for defined licensing scopes, hybrid structures for sandbox or novel work, and retainer-based fractional general counsel for ongoing in-house support. Several of our fintech clients use Esquare Legal as their general counsel function rather than building an internal legal team in the early stages.
Email safighauri@esquarelegal.com with the subject line “Fintech Enquiry” and a one-paragraph description of your operation. We respond within 48 hours.
This page provides general legal information about fintech regulation and is not legal advice. Clients should obtain specific legal advice on their particular circumstances before taking any action in reliance on the content herein.