SAMA launches consultation to the Oversight Framework for Payment Systems and Their Operators: A Modernised Payments Framework in the Kingdom of Saudi Arabia

On 12 November 2025, the Saudi Central Bank (“SAMA”) released a draft update to its “Oversight Framework for Payment Systems and Their Operators” (“Oversight Framework”) for public consultation (the “Consultation”). The Oversight Framework is SAMA’s rules and instructions that supplement the laws and regulations governing payment systems in the Kingdom, setting out SAMA’s role in relation to governing payment systems.  The proposals set out in the Consultation aim to modernise the regulatory structure for payment systems and payment system operators by aligning the Oversight Framework with the Law of Payments and Payment Services by embedding international standards, such as the Principles for Financial Market Infrastructures (“PFMIs”) as issued by the Committee on Payments and Market Infrastructures (“CPMI”) and International Organization of Securities Commissions (“IOSCO”).

The Consultation is open for 15 days (until 27 November), and interested parties can submit their comments via the Istitlaa platform.

In this article, we explore some of the key changes proposed under the Consultation which, if enacted, may impact payment systems and payment system operators within or from the Kingdom.

Scope of Application

The Consultation seeks to clarify, and in certain aspects broaden, the perimeter of payment systems and entities subject to SAMA’s oversight. In particular, it (i) expands the scope of the oversight framework in line with international standards, (ii) sets out clearer criteria for the designation of systemically important and prominent payment systems and the tiered obligations that follow, and (iii) extends SAMA’s oversight to explicitly include critical payment systems (further explained below). As such, these businesses operating, or providing services within the Kingdom (whether directly or whether acting as third party service providers) should consider the impact of the Consultation on their business operations and whether any additional obligations may apply.

Formal Classification of Systemic Importance

The Consultation seeks to classify payment systems using a specific criteria and may be labelled “systemically important” (“SIPS”) if they meet certain thresholds (e.g., by volume, value, number of participants). The Consultation sets out how a system is to be classified, and under what conditions non-SIPS may transition to SIPS. This categorisation differs from the existing regime, where payment systems could be identified as systemically important, but the criteria were less formalised and not codified in a single methodology. If formally adopted, firms should consider the definition of SIPS and determine whether they currently, or in the future, meet these thresholds.

Supervisory Methodology

The Consultation proposes to formalise  the use of PFMIs in both self-assessments (by operators) and supervisory assessments (by SAMA). It includes the CPMI-IOSCO Principles for Financial Market Infrastructures as a baseline reference for regulatory outcomes, adapted to the Kingdom’s payment systems context and applied proportionately.

In practice, for SIPS, annual self-assessments against PFMI principles, or whenever there is a material change, will be required. Supervisory assessments by SAMA will verify these self-assessments and examine broader risk areas, including credit, liquidity, operational, and cyber risk.

Obligations for Operators

The Consultation aims to clarify that operators would be subject to a range of obligations covering risk identification, reporting, PFMI alignment, disclosure expectations, cyber-resilience, business continuity, and incident recovery. Firms will need to consider the wider regulatory framework and assess whether any changes are required to meet the proposed obligations under the Consultation.

Cross-Regulatory Coordination

The Consultation formalises a cooperation model between SAMA and the Capital Markets Authority for shared infrastructures and payment-linked financial market utilities. While coordination existed previously, it was not explicitly embedded in the framework. Cross-regulatory coordination will be helpful in developing the payments landscape in the Kingdom and ensuring consistency across all markets.

Looking Forward

This proposed update represents a further modernisation of SAMA’s supervisory model for payment systems by adopting  leading international practices. The proposed changes will align the Oversight Framework with international PFMI standards, allowing the Kingdom to capitalise on its growing market by providing a stable, global oversight framework.  SAMA is seeking to support stability, transparency, and innovation in the Kingdom’s payments infrastructure. By formalising oversight of not just large payment systems but also existing and emerging platforms, it is clear that SAMA is aiming  to mitigate systemic risk more effectively and is preparing for continued growth and innovation in payment services.

The Consultation window is open for stakeholders to submit comments, including payment operators, financial institutions, fintech firms, and the public. After the consultation, SAMA will consider feedback, revise the draft, and then finalise the framework.

Co-authored by James Isaacs