Saudi Arabia licensing and functions
Live licensing is function-based; crypto, stablecoin, and tokenized-deposit routes remain unsettled or unavailable.
Licensing route map
Function matrix
| Function | Authority / rule | Operational note |
|---|---|---|
| Issue electronic money | SAMA under the LPPS and Implementing Regulation. | Major or micro EMI route; safeguarding and user-limit rules attach. |
| Provide payment services | SAMA under the LPPS and Implementing Regulation. | Major or micro PI route; AML/CFT, data, cyber, and reporting controls attach. |
| Provide payment initiation | SAMA under the payment-services regime and open-banking framework. | PIS route with consent and secure access controls. |
| Provide account information | SAMA under the payment-services regime and open-banking framework. | AIS route; account-information licences announced in 2026. |
| Operate a payment system | SAMA under the LPPS, Implementing Regulation, and payment-system oversight framework. | Operator duties, PFMI-aligned oversight, finality, self-assessment, and assessment controls. |
| Deal, arrange, manage, advise | CMA under Securities Business Regulations. | Requires CMA authorization unless exempt. |
| Provide securities custody | CMA under securities and capital-market-institution rules. | Security-side custody; not native-crypto custody. |
| Offer securities in the Kingdom | CMA under Offer Rules. | Public, private, exempt, direct listing, and continuing-obligation analysis. |
| Use SPE for debt, sukuk, or fund structures | CMA under SPE Rules and related offer/fund rules. | Sponsor, trustee, custodian, auditor, bank-account, and record obligations. |
| Test securities fintech | CMA under ExPermit Instructions. | Testing within parameters; production requires authorization. |
| Test payments fintech | SAMA sandbox. | Letter of Acceptance and safeguards; not a full production licence. |
| Issue stablecoin | No public Saudi issuer class identified. | Not a live route absent regulator confirmation. |
| Run native-crypto exchange or custody | No public Saudi licence class identified. | Outside cited public routes. |
Licensing overlays
Saudi licensing turns on function rather than product label. Payment execution, stored-value issuance, payment initiation, account-information access, and payment-system operation require SAMA analysis. Securities dealing, arranging, managing, advising, custody, offers, funds, and SPE structures require CMA analysis.
A dual-leg structure can cross both perimeters. A tokenized sukuk, note, or fund unit with a Saudi-cash subscription or redemption leg can require a CMA basis for the instrument and a SAMA basis for the money movement.
Testing routes are not production permissions. SAMA sandbox acceptance and CMA ExPermit approval should be treated as controlled testing status, not as a standing permission to scale a regulated service.
Marketing and client nexus are part of the route. Payment services marketed to persons in the Kingdom and securities business conducted with or for persons in the Kingdom can trigger Saudi licensing analysis even when technology or issuance infrastructure sits outside Saudi Arabia.