Salahuddin, Saif & Aslam Attorneys at Law

Fintech & Financial Services

Lending & NBFC Licensing

SSA advises sponsors, fintechs and financial institutions on establishing and operating lending businesses regulated by the SECP.

We structure the proposed activity, prepare the NBFC licensing and supporting corporate materials, develop the regulator-facing business and financial feasibility, and carry the matter through regulatory observations and operational launch. For digital lending, we also work through the product, app, customer-protection, data and whitelisting requirements that sit alongside the underlying NBFC licence.

How SSA Supports the Mandate

From Regulatory Strategy to Implementation.

Our role is to turn the proposed business or transaction into the applications, documents, structures and operating arrangements required to move it forward.

The precise workstream is tailored to the product, licence category, ownership structure and stage of the business. Where a mandate also requires cross-border, technology, transactional or continuing compliance support, those elements are integrated into the engagement.

NBFC Establishment, NOC & Licensing

We advise on the appropriate lending licence and corporate structure, sponsor and management eligibility, ownership and control, fit-and-proper requirements and the sequence of regulatory approvals. SSA prepares the application materials and supporting corporate documentation and manages responses to SECP observations through the licensing process.

Business Plan & Financial Feasibility

We prepare regulator-facing business plans and financial models covering target market, lending products, pricing, funding, portfolio growth, disbursement and repayment assumptions, operating expenditure, staffing and technology costs. The projections include the financial statements, cash flows, break-even and sensitivity analysis needed to demonstrate that the proposed model is commercially and operationally coherent.

Digital Lending Apps & Whitelisting

For app-based lending, we advise on the SECP digital-lending framework and the process for inclusion on the approved whitelist. This includes the self-assessment declaration and the legal and compliance materials supporting the application, together with the relationship between the licensed NBFC and the digital application through which the product is offered.

Product, Pricing & Borrower Documentation

We structure consumer, SME, nano-lending, BNPL, earned-wage-access and embedded-finance products around the financing terms, pricing and charges, repayment mechanics, early settlement, collections and customer documentation. Borrower disclosures and the applicable borrower factsheet are integrated into the customer journey rather than treated as a separate compliance exercise.

Data, Technology & Customer Protection

We review digital onboarding, KYC and verification, consent, data permissions, credit assessment, bureau integrations, communications, information security, cloud and outsourcing arrangements. The legal framework is aligned with the technology actually used to originate, service and collect the lending product.

Foreign Sponsors & Ongoing SECP Compliance

For foreign-sponsored businesses, we coordinate ownership, foreign corporate documents, apostille or legalisation requirements and group arrangements with the licensing process. After authorisation, we support governance, regulatory reporting, product changes, outsourcing, ownership or management changes and continuing correspondence with the SECP.

Our Approach

One Regulatory Proposition, Carried Through the Business.

Structure the Route

We identify the regulatory perimeter, approvals and sequencing before the application or transaction is built.

Prepare the Work Product

We prepare and coordinate the applications, business and corporate materials, policies, contracts and supporting submissions required for the mandate.

Carry It Through

We support regulatory observations, implementation, launch and subsequent changes so the legal structure remains aligned with the operating business.

Let's Talk

Discuss Your Lending & NBFC Licensing Requirements.

Tell us where you are in the process and what you are trying to achieve.

Talk to our Fintech team