Saudi firms should reassess practices following update to payment system framework

The updated supervisory framework for payment systems and operators replaces the previous framework, introduced in April 2021. It creates clearer classification of payment systems, enhanced supervisory tools for SAMA and more detailed obligations for payment system operators to meet.

By tightening rules while incorporating feedback from a 2025 public consultation, the changes will encourage competition and innovation without compromising consumer protection or financial stability, according to SAMA.

Marie Chowdhry, a financial regulation expert at Pinsent Masons, said: “The updated supervisory framework marks a nuanced shift in how payment systems are regulated in KSA.”

“By anchoring supervisory expectations directly to the Payments and Services Law and its executive regulations, SAMA has moved from a largely principles‑based approach to a more structured and prescriptive supervisory regime,” she said.

“For payment system operators, this means greater regulatory certainty but also heightened accountability. The framework contemplates independent supervisory evaluation and, where needed, SAMA can require an independent third‑party assessment of the system. In my opinion, that’s a signal that assurance and evidence are central to the regime.

Operators labelled ‘systemically important’ must now carry out mandatory self‑assessments, while SAMA will conduct independent oversight using standardised tools and benchmarks.

Jessa White, an expert in fintech at Pinsent Masons, said: “What has changed is not the concept of classification, but its consequences. Systemically important operators now face mandatory self‑assessments, potential public disclosure, and heightened supervisory scrutiny, embedding transparency and accountability at the core of the regime.”

“The framework also reflects Saudi Arabia’s broader policy objective of aligning its financial market infrastructure with international standards while supporting innovation and competition in the payments sector,” she said.

“Early engagement with the regulator and proactive compliance planning will be key for firms seeking to scale payment services in the Kingdom while managing regulatory risk.”

The changes highlight the importance of firms reviewing both their current operating models and future growth strategies in the Saudi payments market, the experts said.