Central Bank of Lebanon issues new licensing and operating regime for non-bank electronic payment services providers

The Central Bank of Lebanon (BDL) published a comprehensive framework governing non-bank Electronic Payment Services Providers, setting out licensing requirements and ongoing rules for five service categories: e-money, local money transfers, cross-border money transfers, money collection and payment, and payment facilitation. The decision defines “payment accounts” as non-deposit accounts outside deposit-guarantee protection, introduces governance, risk, compliance, audit, IT security, customer protection and reporting expectations, and provides for fines and licence revocation for breaches. Licensing is limited to Lebanese joint-stock companies with simplified ownership, activity restrictions to the licensed payment services, and prior BDL approval for key bylaw changes and share acquisitions above 5%, alongside a ban on borrowing. Minimum paid-in capital is set at LBP 50 billion per category for services A to D and LBP 25 billion for category E, with requirements that are cumulative across categories, subscription at BDL within three months of licensing, and 15% of capital frozen at BDL subject to USD-equivalent floors. Providers also face an annual fee of LBP 3,000,000,000 per authorised category and must meet local data hosting requirements, specific outsourcing limits, independent audit and AML/CFT controls, and customer-protection disclosures and complaint handling. Product-level rules include caps such as USD 3,000 maximum e-wallet balance for natural persons and USD 30,000 for eligible businesses and professionals, monthly e-wallet funding ceilings of USD 10,000 and USD 50,000 respectively, a 0.5% cap on e-wallet P2P commissions, and monthly local transfer sending limits of USD 10,000 for natural persons and USD 100,000 for commercial companies. E-money safeguarding includes maintaining 100% coverage of e-wallet balances, with 90% placed in segregated bank accounts and a 50% onward placement into non-interest-bearing accounts at BDL, plus limits on cash holdings. Previously licensed non-banking institutions are brought under the new regime and given six months to comply and obtain the necessary licences for their activities. The decision also suspends submission of new licensing requests for categories A to D until further notice, enters into force upon issuance, and provides for BDL to publish an annual official list of licensed providers and amendments to that list.