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title: Nepal Payments Regulation Monitor | World Payments Monitor
canonical: https://payments.gi/jurisdictions/nepal/
date_modified: 2026-10-21
publisher: Asymmetric Intelligence

# Nepal

NP schema world-payments-v1

trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 77 sourced findings · 132 sources in the cumulative register

14 Modules baseline.modules[]

77 Findings modules[].findings[]

16 Tier-1 sources run_metadata.t1_source_count

Confidence mix (sums to 14 rendered modules; click to filter)

No modules moved this cycle.

## Jurisdiction brief

###### Latest update · 18 October 2026

#### Lead Signal

Nepal's payments environment this cycle is defined by a liberalising regulatory move at Nepal Rastra Bank layered against a pending structural reclassification of the non-bank payments sector. Nepal Rastra Bank amended Unified Circular 2082 to double the annual foreign exchange facility limit available through banks and financial institutions, from USD 15,000 to USD 30,000, and separately raised the satellite-service payment limit from USD 100,000 to USD 500,000. These are liberalising moves on cross-border payment access rather than tightening ones. Running alongside this, the Nepal Rastra Bank (Third Amendment) Bill, 2083, which would formally define payment service providers, payment system operators and remittance companies as financial institutions under the Nepal Rastra Bank Act 2058, remains at House committee stage for clause-by-clause discussion. If enacted, this reclassification would be the most structurally significant licensing development for Nepal's non-bank payments sector in the current cycle, since it would bring PSPs and PSOs within a supervisory category previously reserved for banks and deposit-taking institutions.

This licensing-track activity sits against a payment corridor development that pre-dates the anchor window but remains materially relevant: the real-time linkage between Nepal's National Payments Interface and India's Unified Payments Interface, operated jointly by the Nepal Clearing House Limited and the National Payments Corporation of India, went live in June 2026 and targets Nepal's largest and lowest-earning remittance corridor directly.

#### Other Developments

**The NRB Third Amendment Bill would reclassify non-bank payment entities as financial institutions.** The House of Representatives unanimously approved sending the Bill, alongside the unrelated Tourism Bill, to parliamentary committee for clause-by-clause discussion. The proposed reclassification under the Nepal Rastra Bank Act 2058 would extend financial-institution status to payment service providers, payment system operators and remittance companies, a change with direct implications for the prudential and licensing regime those entities currently operate under as non-bank payment institutions.

**An offshore gambling platform integrated with Nepal's two dominant digital wallets.** NPL11, a Curacao-licensed online casino and sports-betting platform, launched in July 2026 and integrated settlement through eSewa and Khalti, giving players payment methods they already use and trust, per the vendor's own announcement. The arrangement is a discrete commercial product-release event; its deal value is not publicly disclosed. It is also a notable counterparty-risk data point for the two payment service providers involved, given Nepal's domestic prohibition on online gambling.

**The Nepal-India digital remittance corridor formalised a historically informal flow.** The NCHL-NPCI linkage enables real-time bank-to-bank peer-to-peer transfers, with India-to-Nepal transfers permitted up to INR 200,000 per transaction with no monthly cap, and Nepal-to-India transfers capped at INR 15,000 per transaction and INR 100,000 per month. The asymmetry in these limits reflects the corridor's primary design purpose of facilitating inbound remittance flow rather than symmetric bidirectional payment.

#### Cross-Monitor Connections

The NPL11 settlement arrangement touching eSewa and Khalti carries a financial-crime dimension that is outside WPM's scope to assess directly but is material context: the use of licensed domestic payment rails to settle funds for a product outside Nepal's online-gambling licensing perimeter is an AML/counterparty-risk question for the PSPs involved, not a WPM compliance conclusion. The pending NRB Third Amendment Bill reclassification, separately, intersects with any financial-integrity assessment of how a binding financial-institution designation would change the supervisory obligations non-bank payment entities face.

#### Outlook

The NRB Third Amendment Bill's progress through committee is the most consequential near-term marker for Nepal's payments licensing architecture; its clause-by-clause discussion stage means the final scope of the financial-institution reclassification for PSPs, PSOs and remittance companies remains unsettled as scheduled. The liberalised foreign-exchange and satellite-payment limits are already in effect and should be expected to support increased transaction volume through formal bank and non-bank channels. The Nepal-India corridor's asymmetric transfer limits may be revisited as transaction volumes on the new linkage become clearer.

_6 earlier updates not shown here._

###### Standing brief · as of 4 July 2026

_Written before the update above. Where they differ, the update is the more recent position._

#### Lead Signal

This cycle establishes the first World Payments Monitor baseline for Nepal, and the picture that emerges is of a payments system pulled in two directions at once. On the infrastructure side, Nepal has just gone live with the most consequential piece of cross-border payments plumbing the corridor has seen in years. On the compliance side, the same banks now carrying that new traffic are operating under intensifying scrutiny tied to Nepal's continuing presence on the Financial Action Task Force grey list. The two threads are not separate stories; they describe a single market trying to modernise its rails while carrying a compliance burden that raises the cost of doing so.

The infrastructure story centres on the India-Nepal corridor. A direct, real-time linkage between India's Unified Payments Interface (UPI) and Nepal's NPI went live 6 June 2026, built via Nepal Clearing House Limited and NPCI International, with a formal announcement following on 9-10 June. The mechanism replaces correspondent-banking-style settlement, which typically takes one to three business days, with instant peer-to-peer transfers routed through Virtual Payment Addresses. It sits alongside an earlier Fonepay-NIPL partnership that enables Indian UPI users to pay Nepali merchants via QR with instant INR-to-NPR conversion, a deployment described as the first full-scale commercial UPI merchant-acceptance rollout outside India. Together, the two initiatives mean Nepal's largest and cheapest remittance corridor - India already ranks among the least costly South Asian channels into Nepal, at roughly 1.9% - now has both a P2P and a P2M real-time rail running in parallel with the correspondent-banking system that has historically carried this traffic.

The compliance story is less celebratory. Nepal remains on the FATF grey list as of the June 2026 plenary, with a 6-point action plan outstanding, having been placed under increased monitoring in February 2025 for the second time in its history (the first stint ran 2008-2014). The consequence for the payments sector is concrete rather than abstract: heightened due diligence and expanded documentation requirements are now attached to the correspondent and trade-finance relationships that Nepali commercial banks depend on, since foreign banks cannot branch directly inside the country. Every Nepali bank's cross-border capability - including, in principle, the new UPI-NPI rail's underlying settlement arrangements - now operates against a backdrop of intensified correspondent-bank de-risking pressure. The juxtaposition is the defining feature of this baseline: a jurisdiction building faster, cheaper cross-border rails at precisely the moment its access to the correspondent-banking system that underpins conventional cross-border settlement is coming under the most sustained pressure it has faced in over a decade.

For payments businesses and their counterparties, the practical read is that Nepal's real-time corridor build-out should not be read as an all-clear signal on country risk. The two dynamics will likely continue to run in parallel for some cycles: infrastructure modernisation proceeding under NRB's active stewardship, while grey-list-driven de-risking continues to shape the correspondent relationships on which the broader banking sector - and, by extension, most PSPs and PSOs plugged into it - ultimately depends.

#### Other Developments

Beneath the corridor and grey-list story, this baseline surfaces a full spine of structural findings across Nepal's licensing, safeguarding, digital-asset, resilience, scheme, market-structure, litigation, merchant-acquiring and consumer-protection domains.

On licensing, Nepal Rastra Bank operates a dual-category regime distinguishing Payment System Operators (PSOs, infrastructure/switching) and Payment Service Providers (PSPs, customer-facing) under the Payment and Settlement Act 2075 (2019), with an exclusivity bar preventing a single entity from holding both licence types except banks and financial institutions. Capital thresholds are tiered by category: PSO Class A requires NPR 500 million, PSO Class B requires NPR 100 million, and PSPs require NPR 50 million minimum paid-up capital, with foreign ownership capped at 80% subject to a minimum FDI contribution and NRB approval. A draft NRB Act amendment now circulating would reclassify PSOs/PSPs into the statutory definition of financial institutions - a horizon issue with unresolved tax and prudential implications that remains at an early, non-final stage.

On conduct and safeguarding, licensed PSPs must enter a formal settlement-bank agreement for clearing/settlement before commencing operations, and this arrangement functions as the core customer-fund-protection mechanism in the absence of a dedicated client-money segregation or trust regime of the kind seen in more developed payments markets - a structural gap this baseline flags as a standing consumer-protection consideration.

On digital assets, Nepal maintains a comprehensive, judicially-upheld prohibition covering trading, holding, mining, membership, investment, ownership, transfer and promotion of any virtual currency/cryptocurrency, including stablecoins, NFTs and DeFi. Separately, NRB is exploring a central bank digital currency ('digital rupee') and has appealed for enabling legislation, but the programme remains at concept/study stage with no live retail pilot as of mid-2026, and any CBDC path would not extend to legalising private crypto or stablecoins.

On operational resilience, NRB's Cyber Resilience Guidelines mandate biennial system audits for all licensed PSPs/PSOs and BFIs alongside vulnerability assessments, penetration testing and disaster-recovery provisioning, aligned to BIS PFMI principles; a Systemically Important Payment Systems framework (September 2025) and AI-specific incident-reporting guidelines (December 2025) have since extended this regime.

On scheme compliance, the NepalQR Standardization Framework mandates EMVCo 4.3-based QR specifications across scheme operators, part of a wider National Payment Switch consolidation of a historically fragmented multi-scheme landscape; separately, the domestic NEPALPAY card scheme is being extended to international acceptance through the Discover Financial Services network.

On market structure, IME Pay and Khalti merged in 2025 to form IME Khalti, a consolidation explicitly aimed at challenging eSewa's roughly 70% share of Nepal's digital-wallet market, approved under NRB's revised settlement bylaw permitting wallet-provider consolidation.

On litigation and enforcement, Nepal's Supreme Court in 2022 dismissed a Public Interest Litigation challenging NRB's crypto-ban notice, a precedent that continues to underpin the durability of the ban; separately, in FY2023/24 NRB dismissed the licences of two payment operators and froze the accounts of two others for non-compliance, evidencing active supervisory capacity against non-bank PSPs.

On merchant acquiring, the E-commerce Act 2081 requires online sellers to use NRB-licensed payment gateways, with fines for breaches shaping merchant-acquiring economics for e-commerce sellers.

On consumer protection, no dedicated mandatory APP-fraud reimbursement scheme akin to the UK PSR model was identified for Nepal; cyber-enabled fraud response instead runs through Nepal Police's Cyber Bureau and FIU-Nepal's STR/SAR analytical channel rather than a bank-liability redress framework.

#### Cross-Monitor Connections

Nepal's continuing FATF grey-list status and the correspondent-bank de-risking pressure it generates carry illicit-finance significance beyond this monitor's payments-market-structure remit, and are flagged to the Financial Intelligence Monitor for its own AML/CFT analysis; WPM's own treatment is confined to the market-structure and correspondent-access consequences for payments and banking counterparties, not an independent illicit-finance assessment. Separately, the AML/CFT reporting-framework detail carried in this baseline - including FIU-Nepal's STR/SAR guidelines and their coverage of PSPs/PSOs as reporting entities - is sourced from the Sentinel.gi feed and is presented here as payments-sector context rather than original WPM financial-crime analysis.

#### Outlook

The near-term trajectory to watch is whether the draft NRB Act amendment reclassifying PSOs/PSPs as financial institutions advances beyond its current non-final stage; its tax-rate and prudential-regime implications would be material for every non-bank operator in the market. On the corridor side, the operational maturation of the UPI-NPI link - transaction volumes, participating-bank expansion beyond the initial select group, and any read-across to Nepal's other major remittance corridors in the Gulf - is the clearest near-term indicator of whether real-time cross-border rails begin to erode correspondent-banking dependency more broadly. On the compliance side, movement on Nepal's 6-point FATF action plan will be the key signal for whether correspondent de-risking pressure eases or continues to tighten; absent progress, the cost and friction of cross-border banking access is likely to remain the binding constraint on how much of Nepal's payments modernisation can actually be realised in practice.

trust tier: ai_unverified

###### Latest update · 21 September 2026

#### Regulatory Status

Nepal Rastra Bank has published a five-year Fintech Strategy for Digital Financial Services (2026/27-2030/31), a Tier-1 primary-source document setting the medium-term regulatory posture for payment services across infrastructure, policy/regulation/governance, and ecosystem-development pillars. Concrete market-access moves this cycle include a rise in the simplified-KYC threshold for wallet onboarding from NPR 5,000 to NPR 10,000, and the graduation of four participants from NRB's first FinTech regulatory sandbox cohort of eight. NepalPay QR reached 85 percent of registered merchant penetration, with interoperable scans via the National Payment Switch rising to roughly one-third of merchant scans. NRB's wholesale CBDC pilot is underway with a full digital-rupee rollout targeted for 2026. A cross-border digital payment gateway between Nepal and India, via collaboration between NPCI, NCHL and Fonepay, is anticipated but not yet confirmed live.

#### Outlook

Watch for implementing rules under the Fintech Strategy's 'level playing field' sub-pillar, progress of the CBDC pilot toward full rollout, and confirmation of the anticipated Nepal-India cross-border gateway.

_2 earlier updates not shown here._

###### Standing brief · as of 4 July 2026

_Written before the update above. Where they differ, the update is the more recent position._

#### Regulatory Status

This cycle establishes the first comprehensive World Payments Monitor baseline for Nepal, covering all fourteen module areas under Nepal Rastra Bank's single national regulatory authority. Nepal's payments licensing architecture rests on a dual-category PSO/PSP structure with tiered capital requirements and an exclusivity bar for non-bank entities, operationalised through the Payment and Settlement Act 2075, its implementing bylaw, and the 2079 Licensing Policy. Customer-fund protection runs through mandatory settlement-bank agreements rather than a dedicated segregation or trust regime, a structural characteristic distinguishing Nepal from more developed safeguarding models. Nepal's digital-asset posture is unambiguous: a comprehensive, judicially-upheld ban on private cryptocurrency and stablecoin activity coexists with a still-conceptual central bank digital currency exploration that carries no live pilot as of mid-2026.

Operational resilience is governed by an established and actively-extending Cyber Resilience Guidelines regime, reinforced in 2025-26 by a Systemically Important Payment Systems framework and AI-specific incident-reporting guidelines. Scheme-level fragmentation across multiple closed-loop QR and card operators is being addressed through NepalQR standardisation and National Payment Switch consolidation, alongside the first international network extension of a domestic Nepali card scheme. Market structure shows active consolidation, evidenced by the IME Pay-Khalti merger formed to challenge eSewa's dominant wallet share. NRB's litigation and enforcement record includes a settled 2022 Supreme Court precedent upholding the crypto ban and demonstrated FY2023/24 enforcement actions - licence dismissals and account freezes - against non-compliant non-bank PSPs. Merchant-acquiring regulation channels e-commerce payment collection through NRB-licensed gateways under the E-commerce Act 2081, while consumer-protection provision for cyber-enabled fraud runs through investigative and reporting channels rather than a mandatory reimbursement scheme.

The most consequential single development of this cycle is the live launch, on 6 June 2026, of a direct real-time UPI-NPI cross-border link between India and Nepal, complemented by a Fonepay-NIPL UPI merchant-acceptance deployment - together marking a structural shift in Nepal's largest and cheapest remittance corridor away from correspondent-banking-dependent settlement. This sits alongside Nepal's continuing FATF grey-list status as of the June 2026 plenary, which has intensified correspondent-bank de-risking pressure on the domestic banking sector that underpins most cross-border payments activity, including, indirectly, the settlement arrangements behind newer real-time rails.

#### Outlook

Three items anchor Nepal's forward trajectory. First, the draft NRB Act amendment reclassifying PSOs/PSPs as financial institutions remains an unresolved horizon issue with material tax and prudential implications should it advance. Second, the operational maturation of the UPI-NPI corridor - participating-bank expansion, transaction-volume growth, and any extension of similar real-time linkages to Nepal's larger-volume Gulf remittance corridors - will determine how far real-time infrastructure displaces correspondent-banking dependency in practice. Third, and most consequentially for the banking sector broadly, progress against Nepal's outstanding 6-point FATF action plan will determine whether correspondent-bank de-risking pressure eases or continues to tighten; absent such progress, elevated due-diligence costs are likely to remain the binding constraint on how much of Nepal's payments-infrastructure modernisation can be fully realised.

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### W1a Licensing, Authorisation & Market Access limited signal Confirmed confirmed 2026-07-04

The Payment and Settlement (First Amendment) Bill, 2083 -- introducing a fintech regulatory sandbox, mandatory National Payment Switch integration, a 30-day wallet-refund guarantee on licence revocation, and provision for foreign/global digital payment providers to enter the market -- was unanimously passed by the House of Representatives on 2026-09-23 and referred to the Finance Committee for clause-by-clause discussion (reported 2026-10-01/02). The bill has not yet been authenticated into law; NRB's existing Unified Payment System Directive and PSO/PSP licensing regime remain in force pending enactment.

Standing sub-brief · as of 4 July 2026 362 words · last cycle 2026-10-18

#### Licensing, Authorisation & Market Access

Nepal's market-access architecture is anchored in the Payment and Settlement Act 2075 (2019), operationalised through the Payment and Settlement Bylaw 2077 and the Licensing Policy for Institutions that Perform Payment-Related Work 2079. Nepal Rastra Bank licenses two distinct categories: Payment System Operators (PSOs, infrastructure/switching) and Payment Service Providers (PSPs, customer-facing), with a bar on any single entity holding both licence types simultaneously - an exclusivity rule that does not apply to banks and financial institutions, which may hold either or both. This split forces non-bank entrants to make an early architectural choice between infrastructure and customer-facing roles, a choice banks are not required to make.

Capital requirements are tiered by category and, within PSOs, by class: PSO Class A requires NPR 500 million, PSO Class B requires NPR 100 million, and PSPs require NPR 50 million minimum paid-up capital. Foreign investors may own up to 80% of a licensed entity, subject to a minimum FDI contribution of NPR 20 million and case-by-case NRB approval. Together, the licence-category bar and the tiered capital thresholds function as the two principal gatekeeping mechanisms shaping who can enter Nepal's payments market and in what corporate form - a materially more prescriptive market-entry architecture than a single-licence regime, and one that any prospective non-bank entrant must navigate before it can begin operating.

The most consequential horizon issue in this module is a draft NRB Act amendment, now circulating, that would reclassify PSOs and PSPs into the statutory definition of 'financial institutions.' This remains at an early, non-final stage with no confirmed implementation date, but its tax-rate and prudential-regime implications are significant enough that it is treated here as a standing watch item rather than a settled development.

#### Outlook

The reclassification proposal is the single most important item to track in this module going forward: if it advances, it would fold PSOs/PSPs into a heavier prudential and tax regime historically reserved for deposit-taking financial institutions, materially changing the economics of non-bank market entry. Absent that shift, the current PSO/PSP dual-category structure, capital tiers and foreign-ownership cap are likely to remain the stable baseline against which any new entrant's market-access strategy must be built.

Periodic update · new data 2026-10-18

#### Licensing, Authorisation & Market Access

Nepal's licensing and market-access environment this cycle shows movement on two separate tracks: an immediate liberalisation of foreign-exchange and payment transaction limits, and a pending structural reclassification of the non-bank payments sector. Nepal Rastra Bank amended Unified Circular 2082 to double the annual limit for foreign exchange facilities provided by banks and financial institutions, from USD 15,000 to USD 30,000, and separately raised the limit applicable to satellite-service payments from USD 100,000 to USD 500,000. Both changes expand the volume of cross-border payment activity individuals and businesses can conduct through licensed bank and non-bank channels without additional authorisation, and represent a liberalising rather than restrictive regulatory posture at the central bank this cycle.

The more structurally significant development remains unresolved. The Nepal Rastra Bank (Third Amendment) Bill, 2083 would define payment service providers, payment system operators and remittance companies as financial institutions under the Nepal Rastra Bank Act 2058. The House of Representatives unanimously approved sending the Bill to the relevant parliamentary committee for clause-by-clause discussion, alongside the separate Tourism Bill, but the reclassification itself has not been enacted and its final scope remains to be settled in committee. A reclassification of this kind would bring non-bank payment entities within a supervisory category previously associated with deposit-taking institutions, with implications for prudential requirements, capital treatment, and the regulatory relationship between Nepal Rastra Bank and the payment service providers and remittance companies operating under it. Because this item pre-dates the current anchor window and because no independent confirmation of the Bill's eventual enacted form exists yet, confidence in how the reclassification will ultimately apply is held at the probable tier.

Taken together, these two developments point toward a Nepal Rastra Bank posture of expanding payment-access limits for consumers and businesses in the near term, while simultaneously working through a longer-horizon structural question of how non-bank payment entities should be classified and supervised. The two tracks are not directly linked in the available material, but both bear on the same underlying question of how far Nepal's payments market access regime extends beyond traditional banking channels.

#### Outlook

The Third Amendment Bill's progress through committee stage is the item to track most closely for market-access implications: enactment would represent the most significant licensing-architecture change for Nepal's non-bank payments sector identified this cycle. The foreign-exchange and satellite-payment limit increases are already in effect and should be expected to show up in transaction-volume reporting in subsequent cycles as businesses and individuals take advantage of the higher thresholds.

**5 earlier distinct update(s)**

Periodic update · new data 2026-09-28

#### Licensing, Authorisation & Market Access

Nepal Rastra Bank has put forward a draft amendment to Section 2(chha) of the Nepal Rastra Bank Act, 2058 that would formally define payment system operators, payment service providers, remittance companies and digital banks as "financial institutions" under Nepali law for the first time. This is currently at consultation stage, and two significant questions remain open: the applicable corporate tax rate, with debate between 25 and 30 percent, and the share-classification and lock-in rules that would apply to these newly reclassified entities. The reclassification carries real weight for market access: formal financial-institution status typically brings both stricter prudential obligations and clearer legal standing, and how the tax and share-structure questions are resolved will materially affect the cost of establishing or operating a non-bank payment institution in Nepal going forward.

Separately, NRB circulars reported this period raised the simplified-KYC onboarding threshold for wallet accounts from NPR 5,000 to NPR 10,000 in monthly turnover, and mandated real-time settlement, replacing a previous T+1 standard, for interoperable QR merchant payouts. These are drawn from a single, less-corroborated source this period and should be read with that caveat, but if accurate they represent a loosening of onboarding friction for smaller wallet users paired with a tightening of settlement speed expectations for merchant-facing QR transactions.

#### Outlook

The consultation outcome on the draft NRB Act amendment, expected toward the fourth quarter of 2026 on a half-year uncertainty band, is the key event to watch for this module. Its resolution of the tax-rate and share-classification questions will determine the practical licensing and market-access calculus for payment service providers, remittance companies and digital banks operating, or seeking to operate, in Nepal.

Periodic update · new data 2026-09-21

#### Licensing, Authorisation & Market Access

Nepal Rastra Bank published a Strategic Framework for a five-year Fintech Strategy for Digital Financial Services, covering 2026/27 through 2030/31 and structured around infrastructure, policy/regulation/governance, and ecosystem-development pillars. This is a Tier-1 primary-regulator publication and it sets the medium-term regulatory posture for payment-services licensing and market access, though the framework document itself does not announce a new numeric rule at publication.

Alongside the strategic framework, two concrete market-access developments materialised this cycle. NRB circulars issued in March and July 2026 (Circular 02/2026 and 07/2026, per secondary reporting) raised the simplified-KYC threshold for wallet onboarding from NPR 5,000 to NPR 10,000 monthly turnover, loosening onboarding friction for lower-value wallet use cases. Separately, NRB opened its first FinTech regulatory sandbox in early 2026; an inaugural cohort of eight participants was admitted and four graduated over a six-month window, testing payments, remittances, credit-scoring and financial-inclusion use cases. This evidences an active rather than purely announced supervisory-innovation mechanism.

The bank-PSP versus non-bank-PI/EMI distinction is directly engaged by NRB's Fintech Strategy, which names a 'level playing field' sub-pillar intended to address fair-competition treatment between bank-owned and non-bank payment applications -- a response to a long-standing structural friction point in Nepal's payments market access regime, discussed further under Industry Structure below.

#### Outlook

Watch for implementing directives that translate the Fintech Strategy's pillars into specific licensing rules, and for the second sandbox cohort's composition and outcomes as a signal of whether NRB's regulatory-innovation posture continues at the current pace. The KYC-threshold change should also be watched for further upward revision given the current strategy's inclusion focus.

Periodic update · new data 2026-09-14

#### Licensing, Authorisation & Market Access

Nepal's payment-licensing framework is well-established and actively enforced. The Payment and Settlement Act, 2075 (2019) requires all payment-related activity in Nepal to be conducted under a Payment System Operator or Payment Service Provider licence issued by Nepal Rastra Bank; operating without NRB approval is illegal under Section 5 of the Act. This core licensing requirement applies uniformly across both bank-affiliated and non-bank payment providers, and there is no carve-out for smaller or app-based digital-wallet operators: digital-wallet operation without NRB approval is explicitly illegal, underscoring that Nepal draws no meaningful distinction between traditional bank-linked payment rails and standalone non-bank payment-institution/e-money-institution models for licensing purposes -- both fall under the same PSO/PSP licensing umbrella.

The licensing policy itself was refreshed in 2079 (2023), when Nepal Rastra Bank's Licensing Policy for institutions performing payment-related work replaced the prior 2076 (2019) policy. A notable market-access feature of the 2079 policy is its extraterritorial application: it extends to foreign entities performing payment-related work in Nepal, meaning offshore payment providers targeting the Nepali market cannot rely on operating outside NRB's licensing perimeter simply by virtue of being domiciled abroad. As of this cycle, over 10 payment system operators and 27 payment service providers are licensed under this framework, indicating an established and reasonably populated non-bank payment sector operating alongside bank-affiliated payment rails.

A development with direct bearing on this licensing architecture, though not yet resolved, is a draft amendment to the Nepal Rastra Bank Act currently under stakeholder discussion. The amendment proposes including payment system operators and payment service providers within the statutory definition of 'financial institution,' a category that today applies only under the Bank and Financial Institutions Act (BAFIA). If enacted, this would fold non-bank payment institutions into a regulatory category historically reserved for deposit-taking banks and financial institutions, and stakeholders have flagged the risk that this could create conflict between BAFIA's financial-institution framework and the Payment and Settlement Act's own separate licensing regime for PSOs/PSPs. The amendment remains at the discussion stage and has not been enacted.

#### Outlook

The key market-access question to watch is whether the draft NRB Act amendment proceeds to enactment in its current form, and if so, how the resulting BAFIA/Payment and Settlement Act interaction is resolved for licensed non-bank payment providers. A resolution that preserves the existing PSO/PSP licensing pathway as the operative regime for payment institutions, while clarifying rather than duplicating BAFIA obligations, would minimise market-access disruption; an unresolved overlap could create compliance uncertainty for both incumbent and prospective foreign payment-institution entrants.

Periodic update · new data 2026-09-05

#### Licensing, Authorisation & Market Access

Nepal Rastra Bank is actively reworking two structural pillars of payments market access this cycle. A draft amendment to the Nepal Rastra Bank Act proposes reclassifying payment system operators and payment service providers as financial institutions, a change stakeholders have warned could create conflicting-provision risk against the separate Payment and Settlement Act 2075 (2018) framework under which these entities are currently licensed and supervised. This is a genuine structural legal-clarity concern: if the reclassification proceeds without careful sequencing, market entrants and existing licensees alike would face ambiguity over which statute, and which prudential regime, ultimately governs their obligations.

Alongside this, Nepal Rastra Bank's Payment Systems Department continues to maintain its roster of licensed payment system operators and payment service providers, most recently republished on 16 April 2026 and currently including eSewa, Khalti, IME Pay, PrabhuPay and CellPay, all licensed under the Payment Systems Act 2075 (2018) and the Payment Systems Regulation 2076 (2019). This non-bank payment-institution roster is distinct from bank-channel payment licensing, and the reclassification debate above bears specifically on this non-bank population's regulatory home.

#### Outlook

Watch whether the draft NRB Act amendment advances to enactment, and if so, whether transitional provisions are included to resolve the overlap with the Payment and Settlement Act rather than leaving licensed non-bank payment institutions to navigate two potentially competing statutory regimes.

Periodic update · new data 2026-08-11

#### Licensing, Authorisation & Market Access

Nepal Rastra Bank tightened the licensing and ongoing-authorisation conditions attached to payment institutions this cycle through amendments to the Integrated Directive on Payment Systems, 2082. Payment service providers must now verify national ID details for wallet creation and updates, with compliance required by Ashwin 2083 (BS), and licensed payment institutions must retroactively collect and submit prescribed information for all existing shareholders, directors, beneficial owners and senior management — a screening obligation applied to an already-operating population rather than only to new licensees, with heavy corporate fines or licence suspension as the stated consequence of failure. Read together, these two amendments represent a shift from point-in-time licensing checks toward continuous KYC and beneficial-ownership monitoring of payment institutions, a structural conduct-supervision upgrade rather than a one-off circular. This obligation sits squarely on the non-bank payment-institution and e-money-institution side of the regulatory perimeter, distinct from bank-channel conduct rules addressed separately under Conduct, Safeguarding & Financial Promotions.

Separately, NRB has directed payment-related companies to adopt settlement-guarantee-fund-type credit-risk mechanisms and has encouraged — though not yet mandated — the integration of AI/ML tools into fraud-risk management systems. The encouragement language is explicitly non-binding at this stage, distinguishing it from the hard national-ID and BO-screening requirements that carry fine and suspension consequences.

#### Outlook

The Ashwin 2083 compliance deadline for wallet national-ID verification is the near-term marker to watch: whether PSPs complete verification at scale by that date will determine whether NRB's shift toward continuous KYC/BO monitoring translates into effective market-access friction for non-compliant institutions or remains a paper requirement. Whether NRB moves from encouraging to mandating AI/ML fraud-risk integration is a second marker for the following cycle.

**Sources and findings (7)**

1. T1 [https://www.nrb.org.np/contents/uploads/2025/09/Frameowrk-for-Identifying-Systemically-Important-Payment-Systems_01-09-2025-1.pdf](https://www.nrb.org.np/contents/uploads/2025/09/Frameowrk-for-Identifying-Systemically-Important-Payment-Systems_01-09-2025-1.pdf) retrieved 2026-07-04
2. T2 [https://pradhanlaw.com/publications/licensing-policy-for-institutions-that-perform-payment-related-work-2079-2023-ad](https://pradhanlaw.com/publications/licensing-policy-for-institutions-that-perform-payment-related-work-2079-2023-ad) retrieved 2026-07-04
3. T3 [https://corporatenp.com/post/fintech-psp-registration-nepal](https://corporatenp.com/post/fintech-psp-registration-nepal) retrieved 2026-07-04
4. T1 [https://www.nrb.org.np/contents/uploads/2025/02/2024-Report_BOK-KPP.pdf](https://www.nrb.org.np/contents/uploads/2025/02/2024-Report_BOK-KPP.pdf) retrieved 2026-07-04
5. T3 [https://ekantipur.com/business/2026/03/01/en/draft-amendment-to-the-nepal-rastra-bank-act-proposal-to-include-payment-system-operators-and-service-providers-in-financial-institutions-41-52.html](https://ekantipur.com/business/2026/03/01/en/draft-amendment-to-the-nepal-rastra-bank-act-proposal-to-include-payment-system-operators-and-service-providers-in-financial-institutions-41-52.html) retrieved 2026-07-04
6. T3 [https://www.lawimperial.com/registration-of-payment-service-provider/](https://www.lawimperial.com/registration-of-payment-service-provider/) retrieved 2026-07-04
7. T1 [https://www.nrb.org.np/contents/uploads/2025/01/Payment-Oversight-Report-2023-24.pdf](https://www.nrb.org.np/contents/uploads/2025/01/Payment-Oversight-Report-2023-24.pdf) retrieved 2026-07-04

### W1b Conduct, Safeguarding & Promotions Probable confirmed 2026-07-04

NRB issued a directive under Payment and Settlement Act 2019 s.45 requiring retroactive collection of shareholder/director/senior-management background and beneficial-ownership information for all licensed payment institutions; no corporate insider is exempt.

Standing sub-brief · as of 4 July 2026 250 words · last cycle 2026-09-28

#### Conduct, Safeguarding & Financial Promotions

Nepal's approach to customer-fund protection departs structurally from the segregation/trust-account model common in more developed payments markets. Rather than requiring licensed PSPs to ring-fence customer funds in a dedicated trust or segregated account, the regime requires PSPs to enter a formal settlement-bank agreement for clearing/settlement before commencing operations, and this arrangement functions as the core customer-fund-protection mechanism in lieu of a dedicated segregation regime. In practice, this means the protection of customer balances is mediated through the commercial relationship between a PSP and its settlement bank, rather than through a standalone legal segregation requirement enforceable independently of that banking relationship.

This is flagged in this baseline as a structural safeguarding gap relative to jurisdictions - the UK and EU among them - that mandate dedicated client-money segregation or trust arrangements as a condition of e-money or payment-institution licensing. It is not, on the evidence available this cycle, a gap that has produced a documented consumer-harm event; it is a structural design characteristic of the Nepali regime rather than an active incident.

#### Outlook

Watch for whether any future NRB rulemaking - potentially bundled with the pending NRB Act reclassification exercise - moves toward a more formal segregation or trust requirement for PSP-held customer funds. Absent such a move, the settlement-bank-agreement model is likely to remain the operative safeguarding mechanism, and counterparties assessing Nepali PSPs should treat the strength of a given PSP's settlement-bank relationship, rather than a standalone legal segregation guarantee, as the relevant customer-protection variable.

Periodic update · new data 2026-09-28

#### Conduct, Safeguarding & Financial Promotions

Nepal Rastra Bank's Unified Payment System Directive, 2082 imposes a National ID linkage mandate on digital-wallet accounts, with a hard deadline of end-Ashwin 2083, corresponding to mid-October 2026, for existing NID holders to link their identification to their wallet accounts. Non-resident Nepali citizens are given additional flexibility, with a linkage window measured from the date of their return to the country rather than the fixed deadline. This is a firm, dated conduct and KYC-linkage obligation rather than a proposal, and it sits within the current in-force-pending horizon window.

The same Directive is also reported, on a single less-corroborated source this period, to impose specific wallet transaction and balance limits: wallet-to-wallet transfers capped at NPR 50,000 per day and NPR 500,000 per month, bank-to-wallet transfers capped at NPR 200,000 per day and NPR 1,000,000 per month, and an overnight wallet-balance cap of NPR 50,000. These figures should be read with appropriate caution given the single-source basis, but if accurate they represent a concrete, quantified conduct-and-safeguarding ceiling on wallet usage that sits alongside the NID-linkage requirement as part of the same Directive's broader tightening of digital-wallet conduct rules.

#### Outlook

The mid-October 2026 NID-linkage deadline is a fixed, near-term compliance date for wallet providers and their customers, independent of how the broader NRB Act classification debate resolves. Confirmation of the specific transaction and balance-cap figures from an additional source would strengthen confidence in the numeric detail of this module's findings.

**2 earlier distinct update(s)**

Periodic update · new data 2026-09-05

#### Conduct, Safeguarding & Financial Promotions

Nepal Rastra Bank has issued a directive under Section 45 of the Payment and Settlement Act 2019 requiring all licensed payment institutions to retroactively collect background and beneficial-ownership data covering every shareholder, director and member of senior management. No corporate insider is exempt from this screening regardless of the size of their direct or indirect ownership, control, or ultimate-beneficial-owner interest. This is a materially tightening conduct-and-safeguarding measure: it converts beneficial-ownership visibility from a point-in-time licensing check into an ongoing, retroactively applied fit-and-proper standard covering the full population of already-licensed payment institutions, not only new market entrants.

The practical effect falls specifically on the non-bank payment-institution and e-money-issuer population supervised under the Payment and Settlement Act, distinct from bank-channel conduct supervision, and represents a distinct tightening relative to Nepal's prior, licensing-stage-only ownership disclosure practice.

#### Outlook

The operational question for the next cycle is implementation timeline and evidentiary standard: how quickly licensed institutions can complete retroactive collection across their full shareholder, director and senior-management population, and what documentation standard Nepal Rastra Bank will accept as satisfying the directive.

Periodic update · new data 2026-08-11

#### Conduct, Safeguarding & Financial Promotions

Nepal Rastra Bank amended the Government Transaction Directive, 2076 this cycle to tighten government-account cheque payment conduct: government-account payments must now be made only via the formal financial payment system or account-payee cheques, and cheque writers and protectors are now mandatory. This is a bank-channel conduct amendment — distinct from the non-bank PSP/EMI-focused wallet-KYC and beneficial-ownership amendments tracked under Licensing, Authorisation & Market Access this cycle — and is logged here as a dated conduct-rule entry rather than a standing explainer, consistent with its dashboard-tier evidentiary weight this cycle.

#### Outlook

No further conduct, safeguarding, or financial-promotions development beyond this cheque-conduct amendment was evidenced for Nepal this cycle.

**Sources and findings (5)**

1. T3 [https://www.lawimperial.com/registration-of-payment-service-provider/](https://www.lawimperial.com/registration-of-payment-service-provider/) retrieved 2026-07-04
2. T3 [https://techlekh.com/digital-payment-providers-interoperability-nepal/](https://techlekh.com/digital-payment-providers-interoperability-nepal/) retrieved 2026-07-04
3. T3 [https://ictframe.com/nrbs-notice-on-eps/](https://ictframe.com/nrbs-notice-on-eps/) retrieved 2026-07-04
4. T3 [https://jkeconomicassociation.com/consumer-protection-in-the-digital-marketplace-legal-frameworks-courts-and-enforcement-practices/](https://jkeconomicassociation.com/consumer-protection-in-the-digital-marketplace-legal-frameworks-courts-and-enforcement-practices/) retrieved 2026-07-04
5. T3 [https://www.fiscalnepal.com/2025/03/20/19895/digital-wallet-leaders-ime-pay-and-khalti-merge-to-rival-esewa-begin-dda/](https://www.fiscalnepal.com/2025/03/20/19895/digital-wallet-leaders-ime-pay-and-khalti-merge-to-rival-esewa-begin-dda/) retrieved 2026-07-04

### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-04

Nepal maintains a comprehensive, judicially-upheld ban on all private cryptocurrency and stablecoin activity, grounded in the Foreign Exchange (Regulation) Act 1962/2019 and NRB Act 2058 Sections 4, 5(d) and 113. NRB is separately exploring a CBDC but has no live retail pilot as of mid-2026; a CBDC would not legalise private crypto.

Standing sub-brief · as of 4 July 2026 252 words · last cycle 2026-07-04

#### Stablecoins & Digital Money

Nepal maintains one of the most comprehensive private-crypto prohibitions in the region. The ban covers trading, holding, mining, membership, investment, ownership, transfer and promotion of any virtual currency or cryptocurrency, including stablecoins, together with NFTs and DeFi activity, grounded in the Foreign Exchange (Regulation) Act 1962/2019 and several sections of the NRB Act 2058. The prohibition is not merely administrative guidance; it was tested and upheld by the Supreme Court in 2022 (see W7), giving it a judicial durability that distinguishes Nepal's ban from softer, guidance-only restrictions seen elsewhere.

Separately, and without any read-across to the private-crypto ban, Nepal Rastra Bank is exploring a central bank digital currency ('digital rupee') and has appealed for an NRB Act amendment to permit issuance. The programme remains at concept/study stage, with no live retail pilot as of mid-2026 and no confirmed forward pilot date sourced this cycle. It is worth stating plainly what this baseline found no evidence for: a CBDC path, were it to materialise, would not legalise private stablecoins or cryptocurrency - the two tracks are legally and institutionally separate.

#### Outlook

The crypto/stablecoin ban should be treated as durable and unlikely to shift absent a change in the underlying statutes or a fresh judicial challenge; the 2022 Supreme Court precedent raises the bar for any future legal challenge. The CBDC track is the item to watch, though its concept-stage status and the absence of a confirmed pilot date mean no near-term operational change should be assumed on current evidence.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T3 [https://lawfirmnepal.com.np/publications/cryptocurrency-in-nepal](https://lawfirmnepal.com.np/publications/cryptocurrency-in-nepal) retrieved 2026-07-04
2. T3 [https://notarynepal.com/blog/legal-provisions-on-cryptocurrency-in-nepal](https://notarynepal.com/blog/legal-provisions-on-cryptocurrency-in-nepal) retrieved 2026-07-04
3. T3 [https://lawbhandari.com/publication/crypto-currency-law-in-nepal-prosecution-of-crypto-cases](https://lawbhandari.com/publication/crypto-currency-law-in-nepal-prosecution-of-crypto-cases) retrieved 2026-07-04
4. T3 [https://sic.gov.lb/en/newsletter/nepal-central-bank-plans-cbdc-within-two-years-crypto-and-stablecoin-still-excluded-says](https://sic.gov.lb/en/newsletter/nepal-central-bank-plans-cbdc-within-two-years-crypto-and-stablecoin-still-excluded-says) retrieved 2026-07-04
5. T3 [https://notarynepal.com/blog/punishment-for-cryptocurrency-in-nepal](https://notarynepal.com/blog/punishment-for-cryptocurrency-in-nepal) retrieved 2026-07-04

### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-04

NRB operates the RTGS system under the Payment System Related Unified Directives, 2081 and has published a Framework for Identifying Systemically Important Payment Systems (SIPS), formalising a systemic-risk-based oversight tier aligned to PFMI-style standards.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/nepal/)

Standing sub-brief · as of 4 July 2026 187 words · last cycle 2026-09-05

#### Operational Resilience & Critical Infrastructure

Nepal's operational-resilience regime is anchored in NRB's Cyber Resilience Guidelines 2023, enforced since August 2023, which require vulnerability assessments, penetration testing, red-team exercises, disaster-recovery sites, and mandatory biennial system audits for all licensed PSPs/PSOs and BFIs, aligned to BIS Principles for Financial Market Infrastructures. This is a substantive baseline requirement set, placing recurring, independently-verifiable resilience testing obligations on both bank and non-bank payments entities.

The regime has continued to extend rather than stand still: a Systemically Important Payment Systems (SIPS) framework issued in September 2025 adds a systemic-risk identification layer on top of the existing cyber-resilience baseline, and AI-specific incident-reporting guidelines issued in December 2025 extend the resilience regime to cover artificial-intelligence-related operational risk - an area few comparable emerging-market payments regulators have yet formally addressed.

#### Outlook

This module is trending toward tighter, more codified oversight rather than looser enforcement. The SIPS framework's practical bite will depend on which payment systems NRB formally designates as systemically important; that designation process, once it produces named outcomes, is the next concrete data point to track for firms assessing their own resilience-compliance exposure in Nepal.

Periodic update · new data 2026-09-05

#### Operational Resilience & Critical Infrastructure

Nepal Rastra Bank published a Framework for Identifying Systemically Important Payment Systems, operationalising a mandate under the Payment and Settlement Act 2019 and aligning Nepal's oversight of critical payment infrastructure with international, PFMI-style standards. This formalises a distinct systemic-risk-based oversight tier for payment systems whose disruption could pose broader financial-stability consequences, where none existed as a named supervisory category before this cycle.

This is a structural, rather than incident-driven, development: the framework itself, not any specific designation made under it, is this cycle's finding. Nepal Rastra Bank has not yet, on the evidence reviewed, named any specific payment system as systemically important under the new framework.

#### Outlook

The first concrete test of this framework will be whichever payment system Nepal Rastra Bank first designates as systemically important under it; that designation, whenever it occurs, will be the practical signal of how the oversight tier is applied rather than merely described.

**Sources and findings (5)**

1. T3 [https://n1r4j.medium.com/key-highlights-of-nepal-rastra-banks-new-cyber-resilience-guidelines-4e50aefc3fd3](https://n1r4j.medium.com/key-highlights-of-nepal-rastra-banks-new-cyber-resilience-guidelines-4e50aefc3fd3) retrieved 2026-07-04
2. T3 [https://kathmandupost.com/money/2025/09/03/nepal-rastra-bank-rolls-out-framework-to-identify-systemically-important-payment-systems](https://kathmandupost.com/money/2025/09/03/nepal-rastra-bank-rolls-out-framework-to-identify-systemically-important-payment-systems) retrieved 2026-07-04
3. T3 [https://www.fiscalnepal.com/2024/02/19/15663/central-bank-strengthens-cyber-resilience-guidelines-amid-rising-cybercrime-concerns/](https://www.fiscalnepal.com/2024/02/19/15663/central-bank-strengthens-cyber-resilience-guidelines-amid-rising-cybercrime-concerns/) retrieved 2026-07-04
4. T1 [https://www.nrb.org.np/contents/uploads/2025/12/AI-Guidelines.pdf](https://www.nrb.org.np/contents/uploads/2025/12/AI-Guidelines.pdf) retrieved 2026-07-04
5. T1 [https://www.nrb.org.np/contents/uploads/2025/02/2024-Report_BOK-KPP.pdf](https://www.nrb.org.np/contents/uploads/2025/02/2024-Report_BOK-KPP.pdf) retrieved 2026-07-04

### W4 Scheme & Network Compliance Probable confirmed 2026-07-04

Nepal runs a multi-scheme, closed-loop payments landscape (Fonepay, SCT, Nepal Payment Solutions, NEPS/NCHL, plus international VISA/Mastercard/UnionPay as licensed PSOs) that NRB is consolidating via the National Payment Switch (NPS) and mandatory NepalQR (EMVCo-based) standardisation, with a domestic NEPALPAY card scheme gaining international acceptance through Discover Financial Services.

Standing sub-brief · as of 4 July 2026 203 words · last cycle 2026-07-04

#### Scheme & Network Compliance

Nepal's scheme landscape has historically been fragmented across multiple closed-loop QR and card schemes operated by different providers, including Fonepay, SCT and Nepal Payment Solutions. NRB's structural response has been twofold: the NepalQR Standardization Framework mandates EMVCo 4.3-based QR specifications across scheme operators, and the National Payment Switch is being built out to consolidate interoperability across this multi-scheme landscape. The direction of travel here is consolidation rather than continued fragmentation, with NRB acting as the active architect of interoperability rather than leaving it to individual scheme operators to negotiate bilaterally.

A further scheme development this cycle is the international extension of the domestic NEPALPAY card scheme, which is being extended to international acceptance through the Discover Financial Services (DFS) network - the first instance of a Nepali domestic card scheme securing cross-border network acceptance of this kind.

#### Outlook

The consolidation trajectory here is well-established and is likely to continue; the National Payment Switch build-out is the structural project to track, since its completion would materially reduce the fragmentation costs currently borne by merchants and consumers navigating multiple closed-loop schemes. The NEPALPAY-Discover extension is worth monitoring for whether it is followed by further international-network tie-ups for other domestic Nepali schemes.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T1 [https://www.nrb.org.np/psd/nepalqr-standardization-framework-and-guidelines/](https://www.nrb.org.np/psd/nepalqr-standardization-framework-and-guidelines/) retrieved 2026-07-04
2. T1 [https://www.nrb.org.np/contents/uploads/2025/10/National-Payment-Switch-NPS-and-the-National-Payment-Ecosystem-Master-Reference-Document-2025.pdf](https://www.nrb.org.np/contents/uploads/2025/10/National-Payment-Switch-NPS-and-the-National-Payment-Ecosystem-Master-Reference-Document-2025.pdf) retrieved 2026-07-04
3. T2 [https://nchl.com.np/wp-content/uploads/2023/02/1.pdf](https://nchl.com.np/wp-content/uploads/2023/02/1.pdf) retrieved 2026-07-04
4. T3 [https://estartupnepal.com/article/electronic-payment-system-in-nepal](https://estartupnepal.com/article/electronic-payment-system-in-nepal) retrieved 2026-07-04
5. T3 [https://techlekh.com/digital-payment-providers-interoperability-nepal/](https://techlekh.com/digital-payment-providers-interoperability-nepal/) retrieved 2026-07-04

### W5 Payment Corridor Dynamics limited signal Confirmed confirmed 2026-07-04

Remittances (~a quarter of GDP) dominate Nepal's cross-border payment dynamics, concentrated in Gulf/GCC, India and Malaysia corridors. A landmark structural shift occurred in June 2026 with the live launch of a direct UPI(India)-NPI(Nepal) real-time linkage via NCHL and NPCI International (go-live 6 June 2026), alongside an earlier Fonepay-NIPL UPI merchant-QR acceptance deal.

Standing sub-brief · as of 4 July 2026 245 words · last cycle 2026-10-18

#### Payment Corridor Dynamics

Remittances account for roughly a quarter of Nepal's GDP, making corridor dynamics one of the most economically consequential modules in this baseline. Inflows are concentrated in Gulf/GCC corridors (roughly half of transfers, with Qatar alone accounting for 17.7%), India (14.2%) and Malaysia (9.7%). Within this mix, the India-Nepal corridor is already among the cheapest in South Asia, at a 1.9% average transfer cost - a materially lower cost base than Nepal's dominant Gulf corridors, which continue to operate primarily through the 56-plus licensed remittance service providers governed by the Remittance Bylaws 2023 approved-country list.

The defining development of this cycle is the launch of a direct, real-time UPI-NPI linkage between India and Nepal, built via Nepal Clearing House Limited and NPCI International, which went live 6 June 2026 with a select group of participating banks (formal announcement following 9-10 June). This is a structural shift rather than an incremental one: it moves P2P remittance settlement on the corridor away from correspondent-banking-dependent processing and toward real-time, API-based transfer.

#### Outlook

The key variables to track are the pace at which participating banks expand beyond the initial select group, transaction-volume growth on the new rail relative to existing correspondent-banking-based remittance flows, and whether a comparable real-time linkage is pursued with any of Nepal's larger-volume Gulf corridors. Absent such an extension, the Gulf corridors - which carry the largest share of inflows - will likely continue to rely on conventional remittance-service-provider channels for the foreseeable future.

Periodic update · new data 2026-10-18

#### Payment Corridor Dynamics

The Nepal-India remittance corridor is the dominant payment-corridor development for Nepal this cycle, notwithstanding that the underlying launch pre-dates the current anchor window. The Nepal Clearing House Limited and the National Payments Corporation of India launched a real-time digital remittance service in June 2026 linking Nepal's National Payments Interface with India's Unified Payments Interface, enabling real-time bank-to-bank peer-to-peer transfers between the two systems. This targets what is described as the single largest and lowest-earning corridor in Nepal's remittance system, a corridor historically served disproportionately by cash and informal transfer mechanisms.

The transfer limits built into the corridor are notably asymmetric. Transfers from India to Nepal are permitted up to INR 200,000 per transaction with no stated monthly cap, while transfers from Nepal to India are capped at INR 15,000 per transaction and INR 100,000 per month. This asymmetry indicates the corridor's design is oriented primarily toward facilitating inbound remittance flow into Nepal, consistent with Nepal's position as a net recipient of remittances from Indian-based Nepali workers and the broader Nepal-India labour migration relationship, rather than toward symmetric bidirectional commercial payment capacity.

The structural significance of this corridor lies in its formalisation effect. By linking two national real-time payment interfaces directly, the NCHL-NPCI arrangement offers a lower-friction, bank-rail alternative to informal and cash-based transfer channels that have historically dominated this corridor, with the implication of greater transaction traceability and reduced reliance on informal networks for a large share of Nepal's inbound remittance volume. No public transaction-volume data is available yet to indicate how much of the corridor's flow has migrated to the new linkage since its June 2026 launch.

#### Outlook

Transaction-volume migration from informal to formal channels on this corridor is the key indicator to watch going forward, though no such data has been published yet. The asymmetric transfer limits, particularly the Nepal-to-India monthly cap, may face pressure for revision if commercial or trade-related payment demand in that direction proves significant, a question the available material does not yet address.

**2 earlier distinct update(s)**

Periodic update · new data 2026-09-28

#### Payment Corridor Dynamics

A new cross-border payment corridor between Nepal and India has been operationalised this period. An arrangement between Fonepay and India's NPCI allows Indian UPI users to pay Nepali merchants directly, and a separate cross-border remittance linkage between NPCI International Payments Limited and Nepal Clearing House Limited went live on 6 June 2026. Together these represent a concrete expansion of inbound cross-border payment capability into Nepal's merchant-payment ecosystem.

The corridor is structurally asymmetric, however: outward scan-and-pay transactions by Nepali residents into India remain restricted under Nepal's existing foreign-exchange rules. This means the liberalisation runs in one direction only, inbound from India to Nepal, while outbound consumer-initiated cross-border payment activity from Nepal remains constrained by capital-control considerations that have not been relaxed alongside the inbound corridor's launch. This asymmetric posture is itself the analytically significant feature: Nepal is simultaneously opening its market to inbound foreign payment flow while maintaining tight control over outbound flow, a combination that reflects continued forex-control caution even as merchant-payment infrastructure integration proceeds.

#### Outlook

Whether and when the outward scan-and-pay restriction is eased is the key item to watch for this corridor going forward. Its continuation would keep the corridor structurally asymmetric; any relaxation would mark a more significant liberalisation of Nepal's cross-border consumer payment posture than what has been operationalised so far.

Periodic update · new data 2026-09-05

#### Payment Corridor Dynamics

Nepal's 2026 nationwide shutdown of online betting applications was partly justified on capital-outflow and illegal-financial-transaction grounds, implicating payment-corridor exposure alongside the separate gambling-policy dimension of the same enforcement action. This is a dated, narrowly scoped entry: the payment-infrastructure angle noted here is limited to the corridor and transaction-flow justification cited for the shutdown, not an independent assessment of the underlying gambling-policy question, which is tracked elsewhere.

#### Outlook

Watch for any further detail on the specific payment corridors or channels implicated, which would sharpen this entry beyond its current dated, single-justification framing.

**Sources and findings (5)**

1. T3 [https://www.daayitwa.org/storage/archives/1704262558.pdf](https://www.daayitwa.org/storage/archives/1704262558.pdf) retrieved 2026-07-04
2. T3 [https://migrantmoney.uncdf.org/wp-content/uploads/2023/02/Nepal-Country-Assessments.pdf](https://migrantmoney.uncdf.org/wp-content/uploads/2023/02/Nepal-Country-Assessments.pdf) retrieved 2026-07-04
3. T3 [https://www.medianama.com/2026/06/223-india-nepal-upi-payments-live/](https://www.medianama.com/2026/06/223-india-nepal-upi-payments-live/) retrieved 2026-07-04
4. T2 [https://fonepay.com/blogs/upi-in-nepal](https://fonepay.com/blogs/upi-in-nepal) retrieved 2026-07-04
5. T3 [https://www.companydartanepal.com/remittance-company-registration-in-nepal/](https://www.companydartanepal.com/remittance-company-registration-in-nepal/) retrieved 2026-07-04

### W6 Industry Structure & Commercial Probable confirmed 2026-07-04

Nepal's fintech market is led by eSewa (~70% market share), with Khalti and IME Pay merging in 2025 to form IME Khalti in a bid to challenge that dominance, while Fonepay remains the dominant PSO/QR network backbone. Consolidation among BFIs (e.g., NCHL's acquisition of NEPS) and a regulatory shift permitting wallet-provider mergers are reshaping industry concentration.

Standing sub-brief · as of 4 July 2026 151 words · last cycle 2026-09-21

#### Industry Structure & Commercial Dynamics

Nepal's digital-wallet market has long been dominated by eSewa, which holds an estimated 70% wallet market share. The most significant structural response to that dominance came in 2025, when IME Pay and Khalti merged to form IME Khalti, a consolidation explicitly aimed at challenging eSewa's position and approved under NRB's revised Transaction and Settlement Bylaw 2077, which permits wallet-provider consolidation. The merger predates this cycle's trailing-twelve-month commercial-event window for W13 purposes but is recorded here as the market-structure context against which any current or future wallet-sector commercial activity should be read.

#### Outlook

The key question for this module is whether IME Khalti's combined scale translates into a durable erosion of eSewa's share, or whether eSewa's incumbency advantage proves resilient to a single competitor-merger response. Any further wallet-sector consolidation, or a competitive response from eSewa itself, would be the next material development to track in this module.

Periodic update · new data 2026-09-21

#### Industry Structure & Commercial Dynamics

NRB's newly-published Fintech Strategy explicitly flags a 'level playing field' sub-pillar targeting fair-competition treatment between bank-owned and non-bank payment applications. This directly addresses a structural fault line in Nepal's payments industry: the differing regulatory and commercial treatment historically applied to bank-affiliated payment products versus independent non-bank wallet and payment-service providers. Secondary commentary singles this sub-pillar out as 'the one to watch' within the broader strategy document, suggesting industry observers regard it as the most commercially consequential element of the framework for incumbent competitive dynamics.

This development sits alongside continuing growth in QR-based payment interoperability: NepalPay QR reached 85 percent of registered merchant penetration by August 2026, with interoperable scans routed through the National Payment Switch rising to roughly one-third of merchant scans, up from approximately 15 percent a year earlier. This growth trajectory is commercially significant for industry structure because it reflects increasing convergence toward a shared interoperable rail rather than fragmented, provider-specific QR ecosystems, which tends to reduce switching costs and lower barriers for non-bank entrants relative to a fragmented-scheme environment.

Read together, the 'level playing field' commitment and the interoperability growth trend point toward a market structure that may be becoming more contestable for non-bank payment providers relative to bank-owned incumbents, though the practical effect of the 'level playing field' sub-pillar will depend on implementing rules not yet published.

#### Outlook

The key indicator to track is whether the 'level playing field' sub-pillar is translated into concrete rule changes -- for example, equalised access to settlement infrastructure or licensing-fee parity between bank-owned and non-bank payment applications. Continued QR-interoperability growth toward higher merchant-scan shares would further support a more contestable market-structure reading.

**1 earlier distinct update(s)**

Periodic update · new data 2026-09-14

#### Industry Structure & Commercial Dynamics

A draft amendment to the Nepal Rastra Bank Act, currently under stakeholder discussion, proposes including payment system operators and payment service providers within the statutory definition of 'financial institution' -- a category that today exists only under the Bank and Financial Institutions Act (BAFIA). This is a structurally significant proposal for Nepal's payment-industry architecture: it would collapse a distinction that has, to date, kept non-bank payment institutions operating under a separate licensing and supervisory track (the Payment and Settlement Act, 2075) from deposit-taking banks and financial institutions governed by BAFIA. Stakeholders participating in the discussion have flagged the risk that reclassification could create a direct conflict between the two statutory frameworks, since BAFIA imposes financial-institution-specific prudential and governance requirements that were not designed with non-bank payment providers in mind.

The practical stakes of this proposal for industry structure are significant precisely because Nepal's payment sector already has a meaningfully developed non-bank component: over 10 licensed payment system operators and 27 licensed payment service providers currently operate under the existing PSO/PSP licensing framework, a structure that has developed specifically because payment institutions were treated as a distinct category from banks. Folding these entities into the BAFIA 'financial institution' definition would represent the most significant structural change to Nepal's payment-industry categorisation since the 2079 (2023) Licensing Policy refresh, and its outcome will shape whether non-bank payment providers continue to operate under a payments-specific regulatory logic or are drawn toward bank-equivalent prudential treatment.

This proposal remains at the stakeholder-discussion stage; it has not been enacted, and its final scope, including whether it applies uniformly to all PSOs/PSPs or is calibrated by size or systemic significance, has not been settled.

#### Outlook

Watch for whether the draft amendment advances from stakeholder discussion toward formal legislative process, and whether its eventual scope distinguishes between systemically significant payment institutions and smaller non-bank providers. The resolution of the BAFIA/Payment and Settlement Act interaction question will materially shape the commercial calculus for both incumbent and prospective non-bank payment entrants into the Nepali market.

**Sources and findings (5)**

1. T3 [https://www.fiscalnepal.com/2025/03/20/19895/digital-wallet-leaders-ime-pay-and-khalti-merge-to-rival-esewa-begin-dda/](https://www.fiscalnepal.com/2025/03/20/19895/digital-wallet-leaders-ime-pay-and-khalti-merge-to-rival-esewa-begin-dda/) retrieved 2026-07-04
2. T3 [https://www.simpaisa.com/blogs/nepals-digital-payment-boom-2025-market-landscape-and-the-road-ahead/](https://www.simpaisa.com/blogs/nepals-digital-payment-boom-2025-market-landscape-and-the-road-ahead/) retrieved 2026-07-04
3. T1 [https://www.nrb.org.np/contents/uploads/2025/01/Payment-Oversight-Report-2023-24.pdf](https://www.nrb.org.np/contents/uploads/2025/01/Payment-Oversight-Report-2023-24.pdf) retrieved 2026-07-04
4. T3 [https://tracxn.com/d/explore/fintech-startups-in-nepal/qo4iDQXalIFuCA3IWeUyRKA1wbtlrLoEqyealiLmpzA](https://tracxn.com/d/explore/fintech-startups-in-nepal/qo4iDQXalIFuCA3IWeUyRKA1wbtlrLoEqyealiLmpzA) retrieved 2026-07-04
5. T3 [https://english.onlinekhabar.com/fintech-innovations-transforming-nepals-banking-landscape.html](https://english.onlinekhabar.com/fintech-innovations-transforming-nepals-banking-landscape.html) retrieved 2026-07-04

### W7 Legal & Litigation Probable confirmed 2026-07-04

Payments-related litigation in Nepal centres on the 2022 Supreme Court dismissal of a PIL challenging NRB's crypto ban, active NRB enforcement actions (licence dismissals, account freezes) against non-compliant PSPs, and an emerging legal-ambiguity dispute over the draft NRB Act amendment that would reclassify PSPs/PSOs as "financial institutions" (with knock-on tax-rate implications).

Standing sub-brief · as of 4 July 2026 210 words · last cycle 2026-07-04

#### Legal & Litigation

The key litigation anchor for Nepal's payments and digital-asset regime remains the Supreme Court's 2022 dismissal of a Public Interest Litigation that had challenged NRB's crypto-ban notice; the Court held that NRB acted within its statutory competence under specific sections of the NRB Act. This precedent underpins the durability of the crypto/stablecoin ban discussed in W2 and forecloses, absent a change in the underlying statute, straightforward domestic legal challenges to that prohibition.

On the enforcement side, NRB's supervisory record shows active use of its licensing powers against non-bank PSPs. In FY2023/24, NRB dismissed the licences of Mohar Digital Pvt. Ltd. and E-net Payment Pvt. Ltd., and froze the accounts of Paywell Nepal Pvt. Ltd. and Sajilo Pay Payment Services Pvt. Ltd. for non-compliance. This is a demonstrable data point on NRB's willingness and capacity to act against licensed non-bank entities, not merely a paper-based supervisory framework.

#### Outlook

Both threads point toward continuity rather than change: the 2022 precedent is settled and unlikely to be revisited absent new legislation, and the FY2023/24 enforcement actions suggest NRB will continue to exercise active supervisory discretion against non-compliant non-bank PSPs. Firms operating in or servicing this market should treat NRB's demonstrated enforcement willingness as a standing feature of the operating environment.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T3 [https://notarynepal.com/blog/legal-provisions-on-cryptocurrency-in-nepal](https://notarynepal.com/blog/legal-provisions-on-cryptocurrency-in-nepal) retrieved 2026-07-04
2. T1 [https://www.nrb.org.np/contents/uploads/2025/01/Payment-Oversight-Report-2023-24.pdf](https://www.nrb.org.np/contents/uploads/2025/01/Payment-Oversight-Report-2023-24.pdf) retrieved 2026-07-04
3. T3 [https://ekantipur.com/business/2026/03/01/en/draft-amendment-to-the-nepal-rastra-bank-act-proposal-to-include-payment-system-operators-and-service-providers-in-financial-institutions-41-52.html](https://ekantipur.com/business/2026/03/01/en/draft-amendment-to-the-nepal-rastra-bank-act-proposal-to-include-payment-system-operators-and-service-providers-in-financial-institutions-41-52.html) retrieved 2026-07-04
4. T3 [https://jkeconomicassociation.com/consumer-protection-in-the-digital-marketplace-legal-frameworks-courts-and-enforcement-practices/](https://jkeconomicassociation.com/consumer-protection-in-the-digital-marketplace-legal-frameworks-courts-and-enforcement-practices/) retrieved 2026-07-04
5. T3 [https://nepaldivorce.com/blog/anti-money-laundering-law-in-nepal](https://nepaldivorce.com/blog/anti-money-laundering-law-in-nepal) retrieved 2026-07-04

### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-04

Merchant acquiring runs through NRB-licensed PSPs/PSOs under the NepalQR framework, with acquirers responsible for merchant enrolment, ID assignment and settlement; a 2026 E-commerce Act mandates use of NRB-licensed payment gateways, and a zero-additional-fee rule on domestic card/QR/wallet transactions structurally shapes acquiring economics for the roughly 1.2 million QR-accepting merchants.

Standing sub-brief · as of 4 July 2026 124 words · last cycle 2026-07-04

#### Merchant Acquiring & Risk

The E-commerce Act 2081 requires online sellers to use NRB-licensed payment gateways or methods, with fines of NPR 50,000 to 300,000 applying for breaches, including unregistered operation or unresolved consumer complaints. This is a structural constraint on merchant-acquiring economics for online sellers in Nepal: it effectively forecloses the use of unlicensed or informal payment-collection arrangements for e-commerce, channelling all online merchant acquiring through NRB-licensed gateway infrastructure.

#### Outlook

This is a stable, established requirement rather than an area of active change this cycle. The item to watch is enforcement intensity - specifically, whether NRB or e-commerce regulators begin publishing enforcement data on gateway-licensing breaches in a manner comparable to the licence-dismissal and account-freeze actions already documented in W7 for non-bank PSPs.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T1 [https://www.nrb.org.np/psd/consultative-review-document-for-qr-code-guidelines-and-framework-and-qr-code-specifications/](https://www.nrb.org.np/psd/consultative-review-document-for-qr-code-guidelines-and-framework-and-qr-code-specifications/) retrieved 2026-07-04
2. T3 [https://www.karsansar.com/e-commerce-act-2081-nepal-guide/](https://www.karsansar.com/e-commerce-act-2081-nepal-guide/) retrieved 2026-07-04
3. T2 [https://nchl.com.np/wp-content/uploads/2023/02/1.pdf](https://nchl.com.np/wp-content/uploads/2023/02/1.pdf) retrieved 2026-07-04
4. T3 [https://ictframe.com/nrbs-notice-on-eps/](https://ictframe.com/nrbs-notice-on-eps/) retrieved 2026-07-04
5. T3 [https://corporatenp.com/post/fintech-psp-registration-nepal](https://corporatenp.com/post/fintech-psp-registration-nepal) retrieved 2026-07-04

### W9 Product Innovation & Market Development Probable confirmed 2026-07-04

Nepal's domestic retail-payments infrastructure runs on NRB's RTGS system alongside private fast-payment operators (fonepay, Nepal Payment Solution's InstaFund) and NCHL clearing. A new NRB directive restricting cash transactions of NPR500,000+ to banking-channel settlement is actively pushing volume toward these digital/account-based rails, and manual cheque clearing is now confined to a narrow high-value band (NPR300m+).

Standing sub-brief · as of 4 July 2026 118 words · last cycle 2026-09-21

#### Product Innovation & Market Development

The standout product development this cycle is the Fonepay-NIPL partnership, which enables Indian UPI users to pay Nepali merchants via QR with instant INR-to-NPR conversion, described in reporting as the first full-scale commercial UPI person-to-merchant deployment outside India. This is distinct from, but complementary to, the bank-channel UPI-NPI person-to-person linkage covered in W5: together, the two initiatives give the India-Nepal corridor both a consumer remittance rail and a merchant-acceptance layer running on real-time infrastructure.

#### Outlook

The key indicator to track is merchant-adoption breadth for the Fonepay-NIPL UPI acceptance product - specifically, how far it extends beyond early-adopter merchants into mainstream retail and tourism-sector acceptance, given Nepal's reliance on Indian visitor and remittance-linked commerce.

Periodic update · new data 2026-09-21

#### Product Innovation & Market Development

Nepal's payments-innovation trajectory accelerated materially this cycle across three fronts. First, Nepal Rastra Bank's wholesale central bank digital currency pilot is underway, with a full digital-rupee rollout targeted for 2026, according to remarks by the NRB governor reproduced in a Bank for International Settlements publication -- a Tier-1 source describing the CBDC programme as proceeding in a phased manner toward that full-rollout target.

Second, NepalPay QR reached 85 percent of registered merchant penetration by August 2026, with interoperable QR scans routed through the National Payment Switch rising to roughly one-third of merchant scans, up from approximately 15 percent a year earlier. This reflects a substantial shift toward interoperable, switch-routed QR payments away from closed-loop, single-provider QR ecosystems.

Third, NRB opened its first FinTech regulatory sandbox in early 2026, admitting an inaugural cohort of eight participants of which four graduated over a six-month testing window, covering payments, remittances, credit-scoring and financial-inclusion product concepts. The sandbox mechanism is itself a product-innovation enabler, providing a supervised pathway for novel payment and credit-scoring products to reach limited-scale testing ahead of full licensing.

These three developments -- CBDC, QR interoperability, and the sandbox -- collectively represent the most significant product-innovation activity identified for Nepal this cycle, and they are mutually reinforcing: sandbox-tested innovations may eventually plug into the same National Payment Switch interoperability rail that is already driving QR-scan growth, while the CBDC pilot represents a parallel, centrally-driven innovation track.

#### Outlook

The principal marker to watch is whether NRB's CBDC pilot progresses from its current phased/wholesale stage toward the targeted full 2026 rollout, and whether QR-interoperability continues its upward trajectory beyond the current roughly one-third merchant-scan share. The second sandbox cohort's composition, once announced, will also indicate whether the regulatory-innovation pace observed in the first cohort is sustained.

**2 earlier distinct update(s)**

Periodic update · new data 2026-09-05

#### Product Innovation & Market Development

Nepal Rastra Bank's Payment Systems Department finalised its Guidelines on Regulatory Sandbox, in effect since 14 May 2026, following a draft-consultation period that incorporated stakeholder and international-practice feedback. The guidelines give fintech startups, alongside licensed banks, payment system operators and payment service providers, a controlled environment in which to test new digital-financial-service products ahead of full market launch. This is a concrete, dated product-innovation-policy development rather than a structural market-access change: it creates a testing pathway, not a new licensing category.

#### Outlook

The practical signal to watch for next cycle is uptake: which institutions, if any, enter the sandbox under the finalised guidelines, and whether any sandbox-tested product graduates to full licensed deployment.

Periodic update · new data 2026-08-11

#### Product Innovation & Market Development

Nepal Rastra Bank's new cap on cash transactions of NPR500,000 or more, requiring settlement via account-payee cheque or bank transfer from Magh (mid-January 2026), is the most consequential product-development-adjacent signal for Nepal's payments market this cycle. By closing off large cash settlement as an option, the cap is likely to materially increase digital-rail transaction volumes in the near term, benefiting the bank-transfer and account-payee-cheque channels over informal cash settlement, and by extension benefiting the formal rails through which that volume must now pass.

Nepal's domestic retail-payments ecosystem, as documented in NRB's own Payment Oversight Report 2024/25, comprises fonepay direct/IBFT and Nepal Payment Solution's InstaFund as the named fast-payment systems operating alongside NRB's own RTGS and NCHL infrastructure. Both are privately operated systems sitting within the domestic retail-payments layer, and no evidence of consolidation, new entrant activity, or product launch among them was identified this cycle — the ecosystem's structure appears stable even as the cash-cap policy shift is likely to route incremental volume through it. A distinct legacy carve-out persists in cheque clearing: cheques of NPR300 million and above remain manually cleared through NRB rather than through automated rails, an explicit structural exception to full rail automation that the Payment Oversight Report documents as still in place.

#### Outlook

The principal marker to watch is whether the NPR500,000 cash-transaction cap produces a measurable, quantifiable shift in transaction volume toward fonepay, InstaFund, RTGS, or NCHL channels in reporting following implementation. Whether the NPR300 million manual-clearing carve-out is itself revisited, and whether any new entrant or product launch appears in Nepal's fast-payment layer, are the two further developments to track. No private-company PSP/fintech funding or M&A signal was located for Nepal this cycle, a standing under-indexed vector for emerging-market rails.

**Sources and findings (5)**

1. T3 [https://english.onlinekhabar.com/fintech-innovations-transforming-nepals-banking-landscape.html](https://english.onlinekhabar.com/fintech-innovations-transforming-nepals-banking-landscape.html) retrieved 2026-07-04
2. T3 [https://estartupnepal.com/article/electronic-payment-system-in-nepal](https://estartupnepal.com/article/electronic-payment-system-in-nepal) retrieved 2026-07-04
3. T1 [https://www.nrb.org.np/psd/retail-payment-strategy-2019/](https://www.nrb.org.np/psd/retail-payment-strategy-2019/) retrieved 2026-07-04
4. T3 [https://techobserver.in/news/egov/india-nepal-upi-npi-cross-border-payments-launch-325089/](https://techobserver.in/news/egov/india-nepal-upi-npi-cross-border-payments-launch-325089/) retrieved 2026-07-04
5. T3 [https://sic.gov.lb/en/newsletter/nepal-central-bank-plans-cbdc-within-two-years-crypto-and-stablecoin-still-excluded-says](https://sic.gov.lb/en/newsletter/nepal-central-bank-plans-cbdc-within-two-years-crypto-and-stablecoin-still-excluded-says) retrieved 2026-07-04

### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-04

Consumer protection rests on the general Consumer Protection Act, 2075 (2018) - enforced via a new Consumer Court (established March 2025) - layered with NRB's sector-specific Financial Consumer Protection and Grievance Management Procedure, 2020 and an NRB grievance portal (Gunaso). No dedicated mandatory APP-fraud reimbursement scheme (akin to the UK PSR model) was identified; cyber-enabled fraud (CEF) response instead runs through Nepal Police's Cyber Bureau and FIU-Nepal's STR/SAR analysis.

Standing sub-brief · as of 4 July 2026 161 words · last cycle 2026-07-04

#### Consumer Protection & APP Fraud

No dedicated mandatory APP-fraud reimbursement scheme akin to the UK PSR model was identified for Nepal this cycle. Cyber-enabled fraud response instead runs through Nepal Police's Cyber Bureau and FIU-Nepal's STR/SAR analysis - an investigative and reporting-based response model rather than a bank-liability redress framework that would compel reimbursement to defrauded customers. This represents a consumer-protection gap relative to the Anglosphere and EU norm of mandatory or presumptive APP-fraud reimbursement, though it should be read as a structural feature of the current regime rather than evidence of any specific unaddressed fraud episode.

#### Outlook

This is an area flagged in this baseline as under-indexed relative to more developed redress regimes, and it is the kind of gap that tends to attract regulatory attention only after a high-profile fraud episode. Absent such a trigger, no near-term move toward a mandatory reimbursement scheme should be assumed; the current investigative/STR-based response model is likely to remain the operative consumer-recourse channel.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T3 [https://commonlaw.com.np/publications/consumer-protection-law-in-nepal](https://commonlaw.com.np/publications/consumer-protection-law-in-nepal) retrieved 2026-07-04
2. T3 [https://jkeconomicassociation.com/consumer-protection-in-the-digital-marketplace-legal-frameworks-courts-and-enforcement-practices/](https://jkeconomicassociation.com/consumer-protection-in-the-digital-marketplace-legal-frameworks-courts-and-enforcement-practices/) retrieved 2026-07-04
3. T1 [https://www.nrb.org.np/contents/uploads/2024/11/FIU-Nepal-Strategic-Analysis-Report-2024.pdf.pdf](https://www.nrb.org.np/contents/uploads/2024/11/FIU-Nepal-Strategic-Analysis-Report-2024.pdf.pdf) retrieved 2026-07-04
4. T3 [https://www.nepallawyer.com/blog/social-media-scams-and-online-shopping-scams-in-nepal-lack-of-legislation-on-scams-in-nepal](https://www.nepallawyer.com/blog/social-media-scams-and-online-shopping-scams-in-nepal-lack-of-legislation-on-scams-in-nepal) retrieved 2026-07-04
5. T1 [https://gunaso.nrb.org.np/complain](https://gunaso.nrb.org.np/complain) retrieved 2026-07-04

### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/nepal/#sec-dom-D7) Confirmed confirmed 2026-07-04

sentinel.position: Nepal was placed on the FATF grey list on 21 February 2025 following an APG mutual evaluation identifying strategic AML/CFT deficiencies. Nepal remains on the grey list as of the June 2026 FATF plenary update, with a 6-point action plan outstanding.

Standing sub-brief · as of 4 July 2026 191 words · last cycle 2026-07-04

#### AML/CFT & Financial Crime

This module is sourced from the Sentinel.gi feed and is carried here as payments-sector context rather than original WPM illicit-finance analysis. FATF placed Nepal under increased monitoring (grey list) effective 21 February 2025, alongside Lao PDR. Nepal remains on the grey list as of the June 2026 plenary with a 6-point action plan outstanding, marking its second grey-listing after an earlier 2008-2014 stint. On the reporting-framework side, FIU-Nepal's STR/SAR Guidelines, updated July 2025, explicitly cover PSPs/PSOs as reporting entities, and under a 2024 amendment to the ALPA, the FIU may fine up to NPR 10 million for STR non-compliance - extending Nepal's AML reporting regime formally into the non-bank payments sector.

#### Outlook

The pace and substance of Nepal's progress against its outstanding 6-point FATF action plan is the central variable for this module and, by extension, for the correspondent-banking pressures documented in W12. For payments-sector readers, the relevant illicit-finance detail and any forward FATF-plenary developments should be tracked via the Sentinel.gi feed and, where applicable, FIM's own reporting; this module's role is limited to identifying the payments-sector consequences of that status, not to independently assessing AML/CFT risk.

no periodic updates on record for this sub-brief

** Sources and findings (10)**

1. T1 [https://www.nrb.org.np/departments/mlpsd/](https://www.nrb.org.np/departments/mlpsd/) retrieved 2026-07-04
2. T? FIM (sentinel.gi) per-JID baseline profile — Nepal — Nepal's AML/CFT regime rests on the Asset (Money) Laundering Prevention Act (ALPA, amended 2011-2019), the 2013 Proceeds and Instruments of Crime Act, and DMLI as sole ML/TF investigative authority under NRB supervision. FATF grey-listed since February 2025; EU and UK both list Nepal as a high-risk third country. Major vulnerabilities persist in hundi/MVTS, cooperatives, casinos, real estate, beneficial ownership verification, and virtual-asset enforcement despite a formal VASP prohibition.
3. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-005) — Enforcement: Department of Money Laundering Investigation (DMLI) — Former Finance Minister and UML vice-chair (five-time finance minister)
4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: OFSI listing
5. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: Department of Money Laundering Investigation (DMLI) / Nepal Police Central Investigation Bureau — Deepak Bhatta, chair of Infinity Holdings
6. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: Department of Money Laundering Investigation (DMLI) — Deepak Khadka, former Energy Minister
7. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: political-constraint
8. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: regulatory-failure
9. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap
10. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: capacity-deficit

### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-04

Nepali law prohibits foreign bank branch operation, so all cross-border settlement runs through correspondent banking arrangements maintained by Nepal's ~20 commercial banks (several of which are foreign joint-venture banks) with major international banks via SWIFT. The February 2025 FATF grey-listing has intensified de-risking pressure, with heightened due-diligence and documentation requirements on correspondent and trade-finance relationships flagged as an immediate risk.

Standing sub-brief · as of 4 July 2026 182 words · last cycle 2026-09-21

#### Correspondent Banking, Settlement & Access

The analytical spine of this module is the structural asymmetry between bank and non-bank access to international settlement infrastructure: because foreign banks cannot branch directly inside Nepal, every Nepali commercial bank's cross-border capability - and, indirectly, every non-bank PSP that relies on a bank for settlement - depends on correspondent-banking relationships with foreign banks. Nepal's FATF grey-listing has intensified correspondent-bank de-risking pressure, with heightened due diligence and expanded documentation requirements now attached to correspondent and trade-finance relationships. This is a direct commercial consequence of the W11 grey-listing rather than an independent development, and it is the primary channel through which AML/CFT status translates into day-to-day payments-sector friction.

#### Outlook

Correspondent-access conditions are unlikely to ease materially until Nepal makes demonstrable progress against its FATF action plan; in the interim, expect continued elevated due-diligence and documentation burdens on Nepali banks' correspondent relationships, with second-order effects on the cost and speed of trade finance and cross-border settlement more broadly - including, potentially, the settlement arrangements underpinning newer real-time corridor infrastructure such as the UPI-NPI link covered in W5 and W13.

Periodic update · new data 2026-09-21

#### Correspondent Banking, Settlement & Access

A cross-border digital payment gateway between Nepal and India is anticipated through collaboration between India's National Payments Corporation of India (NPCI) and Nepal's NCHL and Fonepay. This development remains at the anticipated rather than confirmed-live stage, sourced from a single Tier-3 report, and carries Uncertain confidence accordingly. If it proceeds, it would represent a structurally significant addition to Nepal's cross-border settlement and access landscape, given the volume of remittance and cross-border retail-payment flow between Nepal and India.

The analytical spine for this module is the persistent asymmetry between bank and non-bank access to cross-border settlement infrastructure. A gateway built through collaboration between a national payments-infrastructure operator (NPCI) and Nepal's domestic clearing and switch operators (NCHL, Fonepay) would, if realised, extend interoperable cross-border access beyond what bank-only correspondent arrangements have historically provided, potentially narrowing -- though not eliminating -- the bank versus non-bank access gap for cross-border retail and remittance flows specifically.

No further detail on settlement mechanics, participating financial institutions, or an implementation timeline was available from this cycle's research; the development should be treated as a signal of directional intent between the two countries' payment infrastructure operators rather than an imminent operational capability.

#### Outlook

The key marker for the coming cycle is any confirmation that the anticipated NPCI-NCHL-Fonepay gateway has moved beyond collaboration discussions toward a defined implementation timeline or pilot. Given the single-source, Tier-3 sourcing on this development, corroboration from a second independent source would also materially raise confidence in this finding.

**Sources and findings (5)**

1. T1 [https://www.trade.gov/country-commercial-guides/nepal-trade-financing](https://www.trade.gov/country-commercial-guides/nepal-trade-financing) retrieved 2026-07-04
2. T3 [https://risk.lexisnexis.com/insights-resources/article/aml-terror-financing-risks-as-nepal-reenters-fatf-grey-list](https://risk.lexisnexis.com/insights-resources/article/aml-terror-financing-risks-as-nepal-reenters-fatf-grey-list) retrieved 2026-07-04
3. T3 [https://www.nepjol.info/index.php/JAAR/article/view/90349](https://www.nepjol.info/index.php/JAAR/article/view/90349) retrieved 2026-07-04
4. T2 [https://www.cgdev.org/sites/default/files/policy-responses-de-risking.pdf](https://www.cgdev.org/sites/default/files/policy-responses-de-risking.pdf) retrieved 2026-07-04
5. T3 [https://www.privacyshield.gov/ps/article?id=Nepal-US-Banks](https://www.privacyshield.gov/ps/article?id=Nepal-US-Banks) retrieved 2026-07-04

### W13 Commercial Intelligence (M&A, Investment & Product) limited signal Probable confirmed 2026-07-04

The trailing-12-month window (July 2025-July 2026) is dominated by the live cross-border UPI(India)-NPI(Nepal) rail launch (June 2026) via NIPL/NCHL and Fonepay, continuing consolidation momentum from the 2025 IME Pay-Khalti wallet merger, and Nepal's continued FATF grey-list status through the June 2026 plenary - all with significant knock-on commercial implications for payments-sector investment and market structure.

Standing sub-brief · as of 4 July 2026 133 words · last cycle 2026-10-18

#### Commercial Intelligence (M&A, Investment & Product)

The standout trailing-twelve-month commercial event for Nepal is the India-Nepal UPI-NPI cross-border real-time payment link, a product launch jointly credited to NPCI International Payments Ltd and Nepal Clearing House Limited. The link went live 6 June 2026, enabling instant P2P transfers via Virtual Payment Addresses rather than correspondent-banking rails that typically take 1-3 business days. Deal terms were not publicly disclosed for this product launch. This is classified here as a discrete commercial/product event distinct from the structural corridor analysis carried in W5, though the two are naturally read together.

#### Outlook

Given the product's early-stage rollout with a select group of participating banks, the next commercial-intelligence milestones to track are formal participating-bank expansion announcements and any parallel product announcements extending similar real-time linkages to other Nepali corridors.

Periodic update · new data 2026-10-18

#### Commercial Intelligence & Fintech

The notable commercial event for Nepal this cycle is the launch of NPL11, a Curacao-licensed online casino and sports-betting platform, which went live on July 19, 2026 and integrated settlement through eSewa and Khalti, Nepal's two leading domestic payment service providers. The vendor's own announcement frames the integration as a user-experience choice, giving players payment methods they already use and trust, but the deal carries no publicly disclosed financial terms: the amount is not publicly disclosed, consistent with a product-release event rather than a funding or acquisition transaction.

This is a discrete commercial event rather than a structural market trend, and it should be read as such: a single platform's product launch and payment-integration choice, not a broader shift in Nepal's fintech or gambling-payments market structure. Its relevance to WPM's commercial-intelligence tracking lies in what it indicates about the willingness or ability of domestic payment service providers to integrate with offshore consumer platforms operating in categories, in this case online gambling, that are not licensed domestically. The specific counterparty-risk and AML implications of that integration are a financial-crime question outside WPM's analytical scope, but the commercial fact of the integration itself, and its implications for how domestic PSPs manage merchant-category onboarding more generally, are properly tracked here.

No other discrete commercial events, funding rounds, or product launches were identified for Nepal this cycle.

#### Outlook

Whether eSewa and Khalti maintain, modify, or discontinue the NPL11 integration is the item to watch for signal on how Nepal's leading digital wallets manage merchant-category risk for offshore consumer platforms operating outside domestic licensing perimeters. No further product-launch or funding activity is identified in the available material for this cycle.

**Sources and findings (5)**

1. T3 [https://techobserver.in/news/egov/india-nepal-upi-npi-cross-border-payments-launch-325089/](https://techobserver.in/news/egov/india-nepal-upi-npi-cross-border-payments-launch-325089/) retrieved 2026-07-04
2. T3 [https://www.medianama.com/2026/06/223-india-nepal-upi-payments-live/](https://www.medianama.com/2026/06/223-india-nepal-upi-payments-live/) retrieved 2026-07-04
3. T3 [https://www.newkerala.com/news/a/nepal-remains-fatf-grey-list-as-global-watchdog-462.htm](https://www.newkerala.com/news/a/nepal-remains-fatf-grey-list-as-global-watchdog-462.htm) retrieved 2026-07-04
4. T3 [https://ekantipur.com/business/2026/03/01/en/draft-amendment-to-the-nepal-rastra-bank-act-proposal-to-include-payment-system-operators-and-service-providers-in-financial-institutions-41-52.html](https://ekantipur.com/business/2026/03/01/en/draft-amendment-to-the-nepal-rastra-bank-act-proposal-to-include-payment-system-operators-and-service-providers-in-financial-institutions-41-52.html) retrieved 2026-07-04
5. T3 [https://thefintechtimes.com/how-fintech-is-growing-in-nepal-in-2026/](https://thefintechtimes.com/how-fintech-is-growing-in-nepal-in-2026/) retrieved 2026-07-04

** No modules match.**

Filters combine as OR inside a group and AND across groups.

## Editorial metadata

Provenance only. Nothing below gates publication or affects the render.

Editorial metadata for Nepal| Field | Value |
|---|---|
| `trust.lawyer_review.status` | never_reviewed |
| `trust.lawyer_review.reviewer` | no reviewer on record |
| ` trust.content_source` | ai_generated |

## Provenance and declared absence

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**Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning.

**Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "prepaid_emoney": "licensed-emi", "stablecoin": "emerging-regime"}}}`.

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