Saudi Arabia

Licensing, Authorisation & Market Access

Saudi Arabia's payments licensing perimeter underwent a structural reset this cycle. SAMA issued Circular No. 472047719 on 8 March 2026, replacing the 2021 Oversight Framework for Payment Systems and Their Operators with a revised framework governing how payment systems and their operators are authorised and supervised under the Payments and Payment Services Law. This is not a minor procedural update: a wholesale replacement of the oversight framework resets the baseline supervisory document against which every licensed payment-system operator in the Kingdom is assessed, and it typically signals that the regulator has accumulated enough operational experience under the prior framework to identify where the authorisation and supervisory requirements needed tightening or clarification.

The clearest practical expression of that shift is open banking's move from sandbox to licensed commercial activity. On 27 March 2026, SAMA granted Lean Technologies its first Major Payment Institution licence specifically for open banking, and SAMA formally announced the start of open-banking licensing on 30 March 2026. Until this point, open banking in Saudi Arabia had operated under a more constrained, sandbox-style arrangement; the Lean Technologies licence is the first instance of a firm being authorised to conduct open-banking activity as a standing commercial Major Payment Institution rather than as a sandboxed participant. This is a market-access event in the fullest sense: it establishes the authorisation pathway that subsequent open-banking entrants will follow, and it signals to the broader fintech sector that SAMA considers the open-banking use case mature enough to license at scale rather than continuing to pilot it indefinitely.

The scale of uptake that followed is notable. At Money20/20 Middle East in September 2026, SAMA's Governor stated that more than 307 entities now operate under the open-banking framework. That figure, delivered only months after the first licence was granted, indicates that the regulatory architecture built around Circular No. 472047719 and the Lean Technologies precedent was already supporting a substantial population of participants rather than a handful of early movers. It also suggests that a meaningful pool of firms had been positioning themselves for licensed open-banking status before the framework opened, consistent with a sandbox cohort having been readied for graduation into commercial licensing.

Taken together, the revised oversight framework and the open-banking licensing launch represent the most significant market-access development in the Saudi payments sector this cycle. The revised framework is the structural instrument; the open-banking licensing is its most visible downstream consequence. Firms assessing market entry into the Kingdom's payments sector should treat the March 2026 circular as the current authoritative statement of SAMA's oversight expectations for payment systems and operators, superseding the 2021 framework in its entirety, and should treat the Lean Technologies licence as the reference precedent for how an open-banking-focused Major Payment Institution application is likely to be assessed going forward.

Outlook

The pace at which open-banking licensing attracted participants, 307 entities within roughly six months of the first licence, suggests SAMA is likely to continue processing open-banking and other Major Payment Institution applications at a brisk tempo rather than treating Lean Technologies as an isolated flagship grant. Market participants should watch for further SAMA statements quantifying licensing uptake, and for any second or third wave of named licensees that would confirm the framework is scaling beyond its first mover. The revised oversight framework issued under Circular No. 472047719 should be read as the durable baseline against which future licensing activity will be assessed until SAMA next revises it; given the pace of change demonstrated this cycle, a further revision inside the next eighteen to twenty-four months is plausible, as scheduled, should the open-banking cohort's growth or risk profile prompt recalibration of the supervisory requirements.

Payment Corridor Dynamics

A concrete step in Gulf card-scheme interoperability took shape on 16 September 2026, when the Saudi Central Bank and the Qatar Central Bank signed a cross-border card-scheme interoperability agreement linking the Saudi domestic scheme, mada, with its Qatari counterpart, HIMYAN. The agreement was announced at Money20/20 Middle East, placing it in the category of a formally signed, publicly announced scheme-level arrangement rather than a mere statement of intent. For a corridor that handles substantial bilateral commercial, tourism and labour-remittance-adjacent card traffic between the two Gulf states, a direct scheme-to-scheme linkage is a material development: it allows cardholders enrolled in one domestic scheme to transact using the other's acceptance infrastructure without routing through an international card network as an intermediary, which has implications for transaction cost, settlement speed and the degree of domestic-scheme control each central bank retains over cross-border card flows passing through its jurisdiction.

This development should be read against the broader pattern of domestic card-scheme proliferation and bilateral linkage-building across the GCC. mada is Saudi Arabia's long-established domestic debit scheme, operated under SAMA's oversight; HIMYAN is Qatar's domestic equivalent. A bilateral interoperability agreement between the two, rather than reliance on a unified pan-GCC settlement mechanism, indicates that Gulf payment integration is currently proceeding through a network of bilateral scheme agreements rather than through a single centralised GCC-wide rail. This corridor-building approach allows each central bank to negotiate terms specific to its own scheme's risk tolerance and commercial priorities, at the cost of a more fragmented overall interoperability map across the region compared with a single unified scheme.

The mada-HIMYAN agreement sits alongside the licensing and oversight-framework developments described elsewhere this cycle, and together they describe a Saudi payments sector that is extending its reach in two directions simultaneously: domestically, through wider licensing of open-banking participants, and externally, through scheme-level agreements that extend mada's acceptance footprint beyond Saudi borders. Firms with card-acquiring or cross-border payment operations touching both Saudi Arabia and Qatar should treat the interoperability agreement as the first formal step toward reduced friction in that specific corridor, while recognising that operational implementation details, such as the settlement mechanics and timeline for full interoperability, were not disclosed at the September 2026 announcement.

Outlook

The mada-HIMYAN agreement is likely to be the first of several bilateral Gulf card-scheme interoperability arrangements SAMA pursues, given the precedent it sets for extending a domestic scheme's acceptance footprint without waiting for a unified GCC-wide settlement infrastructure. Whether SAMA or the Gulf Cooperation Council's broader institutional architecture moves toward a more centralised multilateral card-interoperability framework, rather than continuing with bilateral agreements corridor by corridor, is a question this cycle's evidence does not resolve, and market participants should treat any claim about a broader pan-GCC mechanism as unconfirmed until a primary announcement names one.

Product Innovation & Market Development

Open banking is the defining product-development story in Saudi Arabia's payments sector this cycle, and its trajectory is best understood as a transition from controlled experimentation to licensed commercial product. SAMA's licensing of Lean Technologies as the first Major Payment Institution authorised for open banking, on 27 March 2026, formally ended the period in which open-banking activity in the Kingdom was confined to sandbox-style testing. SAMA's own public announcement, on 30 March 2026, of the start of open-banking licensing confirms that this was a deliberate, programme-level regulatory decision rather than an isolated grant to a single favoured applicant.

The market's response to that regulatory opening has been rapid by the measure SAMA itself has offered: at Money20/20 Middle East in September 2026, the SAMA Governor stated that over 307 entities now operate under the open-banking framework. Whether all 307 are themselves licensed Major Payment Institutions, or whether the figure also captures firms operating as technical service providers, data recipients or other categories connected to the open-banking ecosystem, is not specified in the sourcing available this cycle, but the scale of the figure nonetheless indicates that the product category has moved well beyond a pilot cohort. An ecosystem of that size implies open banking has become a live distribution channel for account-information and payment-initiation products across the Saudi financial sector, rather than a capability held by a small number of early licensees.

This product-development shift did not occur in a vacuum. It followed directly from the March 2026 replacement of SAMA's payment-systems oversight framework (Circular No. 472047719), which reset the authorisation baseline against which open-banking and other payment-service applications are now assessed. Reading the oversight-framework revision and the open-banking licensing launch together, the product innovation observed this cycle is regulator-enabled rather than regulator-following: SAMA appears to have built the licensing pathway in anticipation of, or in close coordination with, the market readiness that then produced the 307-entity figure within months.

Outlook

The open-banking ecosystem's growth to over 307 entities within roughly six months of the first licensing grant suggests the product category is likely to continue expanding, with further announcements of licensed entrants plausible over the coming cycles. A useful signal to track will be whether SAMA begins publishing a more granular breakdown of the open-banking participant population, distinguishing licensed Major Payment Institutions from other categories of ecosystem participant, which would allow a clearer read on how much of the reported growth reflects genuine new licensing activity as opposed to technical integrations by firms already otherwise regulated.

Correspondent Banking, Settlement & Access

Settlement and correspondent access for payment-system licensees in Saudi Arabia tightened materially this cycle through two SAMA circulars operating on the compliance infrastructure that sits behind, rather than replacing, the licensing framework described elsewhere. The first requires payment-system licensees to integrate beneficial-ownership verification with the Wathq service, a requirement that took effect progressively from March 2026. The second, effective 1 October 2026, requires integration with the Security Council Resolutions Notification System, operationalising real-time sanctions-designation screening directly into payment-system rails.

For the payment-system operators and licensees this affects, these are not abstract compliance obligations; they are conditions attached to continued settlement and correspondent access. A licensee that integrates beneficial-ownership verification and sanctions-screening capability into its systems is, in effect, demonstrating to SAMA and to any correspondent or sponsor bank relationship it depends on that it can meet the verification standard those counterparties require to continue extending settlement access. In a market where many payment-service providers depend on a bank or sponsor relationship for settlement finality rather than holding direct central-bank settlement access themselves, the tightening of these upstream verification requirements has a direct bearing on how comfortable sponsor banks are likely to be in continuing or expanding those relationships: a licensee operating under a more rigorous, system-integrated verification regime presents a lower de-risking concern to a sponsor bank than one relying on manual or ad hoc processes.

The timing of the sanctions-screening integration requirement, coming into force on 1 October 2026, places it squarely within the same calendar window as the broader oversight-framework revision and open-banking licensing expansion described elsewhere this cycle. Read together, SAMA's approach this cycle has been to widen who can access the payments market while simultaneously narrowing the tolerance for how those market participants demonstrate compliance with beneficial-ownership and sanctions-screening standards before they can rely on correspondent or settlement relationships. This is a structural feature of SAMA's current regulatory posture, not an isolated circular: it reflects a settlement-access regime in which market entry and compliance infrastructure are being tightened in parallel rather than sequentially.

Outlook

Payment-system operators and their sponsor-bank or correspondent counterparties should expect SAMA's emphasis on system-level, real-time verification and screening integration to continue, rather than being treated as a one-off compliance exercise satisfied by the Wathq and Security Council Resolutions Notification System integrations completed this cycle. Firms whose settlement arrangements depend on a sponsor-bank relationship are likely to face continued pressure to demonstrate equivalent system-integrated verification capability as the price of maintaining that access, particularly given the broader financial-integrity context in which these circulars sit.

Commercial Intelligence & Fintech

Saudi Arabia was reported as the leading jurisdiction in Q3 2026 MENA fintech and startup funding, with approximately 1 billion dollars deployed across 62 deals region-wide according to a MAGNiTT-sourced quarterly wrap-up published by Arab News in mid-October 2026. Within that regional picture, two Saudi Arabia-specific transactions were disclosed on 17 October 2026, both of undisclosed amount.

The first is a strategic investment by Foodics, a Saudi Arabia-domiciled company, into Funding Souq, also domiciled in Saudi Arabia and operating in the payments-adjacent space. The transaction is characterised as strategic rather than purely financial, which typically signals an intended commercial or operational relationship between investor and investee beyond a passive capital stake, though the specific nature of that relationship is not detailed in the reporting available this cycle. The amount of the investment was not publicly disclosed, and no further terms are available.

The second is an investment into COFE Tech, a Saudi Arabia-domiciled company, led by Phoenix Venture Partners, domiciled in the United Arab Emirates, with KSH Investments participating as a co-investor. As with the Funding Souq transaction, the amount was not publicly disclosed. The involvement of a UAE-domiciled lead investor in a Saudi Arabia-domiciled target is consistent with continuing cross-border Gulf capital flows into the Saudi technology and fintech-adjacent sector.

Both transactions were reported through the same Q3 2026 MENA funding wrap-up, which frames Saudi Arabia's overall investment performance for the quarter as a rebound, with Saudi Arabia leading the region by both deal value and deal count. Neither transaction carries any disclosed connection to payments licensing, conduct, safeguarding, stablecoin or AML/CFT regulatory activity; both are purely commercial-investment events as reported. No further detail on valuation, use of proceeds, or definitive closing status beyond the announcement itself is available for either transaction this cycle.

The absence of disclosed amounts for both transactions is itself a notable pattern rather than an isolated gap: undisclosed-value strategic and institutional rounds appear to be a recurring feature of Saudi Arabia's fintech investment reporting this quarter, which limits the precision with which aggregate sector investment figures for Saudi Arabia specifically, as distinct from the regional total, can be assessed.

Outlook

Continued investor interest into the Saudi Arabia fintech and adjacent-technology sector appears likely to persist into Q4 2026, consistent with the broader MENA funding-rebound narrative in which Saudi Arabia was named the leading jurisdiction for Q3 2026. Whether the Foodics-Funding Souq or Phoenix Venture Partners-COFE Tech transaction values will be disclosed in later reporting, and whether the strategic relationship between Foodics and Funding Souq will be elaborated in subsequent commercial announcements, remains to be seen as scheduled reporting continues through the remainder of 2026.