On 9 January 2026, the Banque du Liban (“BDL”) issued Basic Decision No. 13790 (the “Decision”), establishing the first comprehensive regulatory framework for Electronic Payment Services Providers (“EPSPs”) in Lebanon [1]. The Decision applies to any institution intending to provide electronic payment services, expressly excluding banks, financial institutions, and exchange institutions from its scope.[2] Any such institution must obtain prior BDL approval to be licensed.[3]
Five Categories of Services
The Decision establishes five distinct categories of electronic payment services, each covering a defined scope of activity:[4]
Category A: E-Money. A service for storing funds that represent a specific financial balance in electronic wallets (E-Wallets). This is the most regulated category. E-Wallet balances are capped at USD 3,000 for natural persons and USD 30,000 for commercial companies. Monthly transfers may not exceed USD 10,000 for natural persons and USD 50,000 for companies, and are non-revolving within a single month.[5]
Category B: Local Money Transfer. A service for sending or receiving funds electronically within the country via a local network.
Category C: Cross-border Money Transfer. A service for sending or receiving funds electronically abroad through a contract with a foreign company.
Category D: Money Collection and Payment. A service for receiving money and paying bills and taxes (including university and school fees) in favor of ministries, public institutions, syndicates, mobile and landline telephone companies, universities, schools, and commercial institutions registered in the Commercial Register.
Category E: Payment Facilitators. Services related to e-technologies that facilitate electronic payments, including payment gateway services for collecting electronic payments and disbursing them to beneficiaries.
A licensed institution may provide one or more categories. Each additional category requires separate BDL approval and triggers an increase in the minimum capital requirement.
Capital and Legal Structure
The licensed institution must be a Lebanese joint-stock company (société anonyme libanaise) with nominal shares.[6] The minimum capital is LBP 50 billion (not less than USD 558,660) for each of Categories A through D, and LBP 25 billion (not less than USD 279,330) for Category E. These thresholds are cumulative.[7] The capital must be deposited in a special account at the BDL, with 15% permanently frozen and released only upon liquidation.[8]
E-Money: Fund Safeguarding
For Category A (E-Money), the Decision imposes a layered fund protection mechanism. Ninety percent of users’ E-Wallet funds must be deposited in a special and independent bank account in Lebanon, of which 50% is further transferred to a non-interest-bearing account at the BDL. The remaining 10% may be kept in cash. The institution is expressly prohibited from using E-Wallet funds for any purpose other than paying users, no lending, no financing, no investment.[9]
A critical point for users: payment accounts opened with EPSPs are not deposit accounts under Article 125 of the Code of Money and Credit, meaning they are not covered by the National Deposit Guarantee Institution.[10]
Other Notable Provisions
All data and information pertaining to customers and operations must be stored in Lebanon.[11] EPSPs are prohibited from issuing, dealing in, or facilitating dealings in virtual assets unless specifically authorized by BDL regulations.[12]
Why It Matters
Since the 2019 financial collapse, digital payment solutions have emerged to fill the vacuum left by a paralyzed banking sector, largely without regulatory oversight. Decision 13790 brings order to that space. The five-category licensing framework gives the BDL granular control over who does what, while the fund safeguarding requirements for E-Money services aim to prevent a repeat of the depositor crisis, albeit outside the formal deposit guarantee system. For a country rebuilding its financial infrastructure from the ground up, this is a necessary step.
Source: www.bdl.gov.lb
[1]Banque du Liban, Basic Decision No. 13790 of 9 January 2026 (Basic Circular No. 1 to Electronic Payment Services Providers), issued pursuant to Articles 70 and 174 of the Code of Money and Credit and Law No. 133 of 26 October 1999. Available at www.bdl.gov.lb.
[2]Article 1(3) of Decision 13790.
[3]Article 2(1) of Decision 13790.
[4]Articles 1(5) through 1(9) of Decision 13790.
[5]Article 35 (First)(2) and (3) of Decision 13790.
[6]Article 3(1) of Decision 13790.
[7]Article 4(1) of Decision 13790. Capital requirements are cumulative according to the number of categories (Article 4(2)).
[8]Article 4(4) and 4(6) of Decision 13790. Fifteen percent (15%) of the capital is frozen at the BDL and shall not be returned except upon liquidation (Article 4(7)).
[9]Article 35 (Second) of Decision 13790. The Institution must maintain at all times a ratio of at least 100% of E-Wallet balances in its accounts with banks and/or in cash (Article 35 (Second)(4)).
[10]Article 1(11) of Decision 13790. Payment accounts are not considered deposit accounts under Article 125 of the Code of Money and Credit, and users do not benefit from the National Deposit Guarantee Institution.
[11]Article 27 of Decision 13790.
[12]Article 17(3) of Decision 13790.