Why PayPal and Stripe Can’t Come to Pakistan

The Untold Story of Regulatory Gridlock, Market Viability, and Capital Control

For over a decade, Pakistan’s 2.37 million freelancers and burgeoning technology sector have operated in a peculiar financial twilight zone. The country ranks fourth globally in freelance growth, exports $3.2 billion annually in IT services, and boasts 88 percent digital payment adoption in retail transactions. Yet two of the world’s most essential payment gateways, PayPal and Stripe, remain conspicuously absent. This absence forces Pakistani entrepreneurs into workarounds that cost the economy millions in leakage, limit global competitiveness, and perpetuate an informal payments ecosystem that undermines the very digitalization the government claims to champion. The question of why PayPal cannot come to Pakistan has generated countless government announcements, Senate committee hearings, and ministerial promises since 2018. The answer, however, is far more complex than official narratives suggest. It is a story of overlapping regulatory barriers, fundamental business model mismatches, deep-seated capital control anxieties, and a market that has learned to function despite institutional constraints rather than because of them. Understanding this story requires moving beyond the convenient explanations offered by officials and examining the actual incentive structures, regulatory frameworks, and economic calculations that keep these payment giants at arm’s length from one of Asia’s largest and most digitally ambitious economies.

Since 2024, there has been a partial shift at the margins: some Pakistani freelancers can now receive client payments that originate from PayPal accounts via intermediaries like Payoneer and other processors, without ever holding a PayPal wallet themselves. This development has created headlines and political talking points, but it does not change the underlying reality that neither PayPal nor Stripe has formally entered Pakistan, obtained local licensing, or made their full product stack available to users in the country.

The FATF Red Herring: A Convenient Scapegoat

The most commonly cited explanation for PayPal’s absence is Pakistan’s placement on the Financial Action Task Force grey list from June 2018 to October 2022. Government officials repeatedly invoked FATF restrictions as the insurmountable obstacle preventing international payment gateways from operating in the country. The IT Ministry officially announced in February 2022 that PayPal plans not to include Pakistan for the next two years as FATF objects to its payments. This narrative, while containing kernels of truth, obscures a more fundamental and uncomfortable reality. Pakistan exited the FATF grey list in October 2022, yet more than three years later, neither PayPal nor Stripe has established operations. The FATF itself warned Pakistan in 2024 that exit from the greylist does not grant immunity from global scrutiny on terror financing and money laundering, indicating ongoing concerns. However, the removal of Pakistan from enhanced monitoring eliminates the grey list designation as the primary barrier and raises an inconvenient question for government officials: if FATF was the obstacle, why has nothing changed now that Pakistan has been delisted?

The real money laundering concerns run deeper than FATF compliance and reveal anxieties that transcend any single regulatory framework. During a 2019 Senate hearing, Senator Rehman Malik noted that one case of money laundering could cause significant problems for PayPal and the company must have the backing of the government that it can secure its own interests. This statement reveals the core anxiety underlying the entire situation: in Pakistan’s institutional environment, a single high-profile money laundering incident involving PayPal could trigger regulatory backlash, reputational damage, and potential re-listing on FATF watch lists, risks that far outweigh the market opportunity. For an international company considering entry into an emerging market, such reputational and regulatory risk is existential. PayPal’s corporate structure, its public filings, and its regulatory compliance posture are built around maintaining pristine anti-money laundering credentials. Any breach, whether through corporate negligence or exploitation by criminal actors, could result in massive fines from the US Treasury Department’s Financial Crimes Enforcement Network, congressional scrutiny, and loss of banking relationships globally. In this context, operating in Pakistan is not simply a business decision. It is an enterprise risk calculation where the downside scenarios are genuinely catastrophic.

Pakistan’s Anti-Money Laundering Act of 2010, with subsequent amendments in 2015, 2016, and 2020, established stringent Know Your Customer and Customer Due Diligence requirements that appear robust on paper. The Financial Monitoring Unit, Pakistan’s financial intelligence unit, requires reporting of all suspicious transactions, mandatory NADRA biometric verification for accounts, and enhanced monitoring of politically exposed persons. While these regulations align with international standards on their face, their enforcement and implementation in a context where informal financial channels such as hawala and hundi remain deeply embedded in the economy creates a compliance nightmare for international payment processors. The informal remittance system continues to move substantial volumes of money outside official channels, estimates suggest between 20 and 40 percent of total remittance flows, creating an alternative financial infrastructure that operates largely beyond regulatory sight. For PayPal to operate successfully in such an environment, the company would need not only to comply with Pakistan’s regulations but also to somehow create technological and operational barriers that prevent its system from being exploited for illegal purposes. Given the sophistication of money laundering techniques and the ingenuity of actors motivated by high margins, this is an impossible standard. PayPal knows this, which is why the company has chosen to stay out entirely rather than attempt to build sufficient safeguards.

The Regulatory Gauntlet: High Costs, Low Returns

Beyond anti-money laundering concerns lies a labyrinth of regulatory requirements that make Pakistan an unattractive market for payment gateway operators and that reveal how regulatory barriers can function as effective prohibitions even when they appear nominally neutral. The State Bank of Pakistan’s Electronic Money Institution Regulations, issued in April 2019, establish a three-stage licensing process that can take years to complete and that carries no guarantee of eventual approval. The licensing journey begins with an in-principle approval, followed by pilot operations, and culminates in a commercial license. Data from the State Bank reveals that the average time from in-principle approval to pilot authorization is 295 days, nearly ten months. This timeline alone sends a signal that deters serious applications: international technology companies operate on venture capital cycles and quarterly earnings calendars where extended regulatory waiting periods translate directly into lost opportunity costs and pressure from investors asking why capital is tied up in a market that remains unresolved.

The real significance of the regulatory timeline became apparent when Checkout.com, a London-based fintech with 1.8 billion dollars in funding and deep regulatory experience across 50 countries, received in-principle approval in August 2022 but withdrew its application by April 2023, citing Pakistan’s deteriorating macroeconomic situation. This high-profile withdrawal was devastating to the narrative that Pakistan was “close” to hosting international payment gateways. Checkout.com was no startup with limited resources and regulatory naivete. The company had successfully navigated complex regulatory environments in emerging markets globally. Yet Checkout.com concluded that the combination of Pakistan’s regulatory burden and its macroeconomic instability made further investment unjustifiable. This withdrawal signaled to other international players, including PayPal and Stripe, that even well-capitalized firms with demonstrated competence in emerging market regulation find Pakistan’s environment prohibitive.

The financial barriers are equally daunting and operate as hard constraints rather than negotiable requirements. EMI regulations require a minimum paid-up capital of PKR 200 million, approximately 700,000 dollars. However, this represents only the baseline capital requirement. Additional mandatory costs include security deposits of varying amounts depending on transaction volume projections, system audits from reputable external auditors that must be conducted quarterly or semi-annually, ongoing compliance expenses including staff, technology, and external consulting, and infrastructure setup costs for secure servers, backup systems, and redundancy. While the frequently cited two million dollar total license fee is not explicitly documented in current regulations, industry sources and the Checkout.com experience suggest that total entry costs including capital requirements, infrastructure setup, legal expenses, and compliance systems over the first three years easily reach this threshold. For a company like PayPal, which operates on notoriously thin profit margins compared to competitors like Payoneer, these entry costs must be justified by substantial transaction volumes and revenue potential that simply do not exist in Pakistan. Research from the Pakistan Institute of Development Economics notes that PayPal is said to operate with minimum profit margins as compared to other online fund transfer systems like Payoneer, and such high cost for regulatory purposes would not fit in their business model. In other words, the regulatory costs are not merely high in absolute terms. They are so high relative to PayPal’s actual business model and margins that they cannot be absorbed, making entry mathematically impossible regardless of market growth potential.

The Market Viability Problem: Too Small, Too Risky, Too Late

The fundamental issue confronting any analysis of why PayPal has not entered Pakistan is not regulatory, though regulations matter greatly. Rather, it is the straightforward question of whether the market opportunity justifies the investment and ongoing operational costs. In May 2019, the National Incubation Centre Karachi director delivered a blunt assessment that PayPal never agreed to come to Pakistan in the first place because Pakistan’s market size is not good enough for the American company and credit card penetration is less than three million. While this statement was made several years ago and the market has grown since then, the assessment captures a fundamental truth that remains operative today. PayPal’s internal business case for entry requires not merely an absence of regulatory obstacles but active market conditions that support profitable operations at scale.

Pakistan’s credit card penetration rate of 0.22 percent as of 2021, meaning fewer than one in every 400 adults holds a credit card, creates a fundamental business model mismatch between PayPal’s operating model and Pakistan’s financial infrastructure. PayPal’s ecosystem is engineered to thrive on high-volume, low-friction consumer transactions linked to credit and debit cards. The company’s profit model is built on capturing margin from millions of small transactions, currency conversion spreads, merchant service fees charged to businesses, buyer protection premiums, and credit extension services. In markets with robust card penetration, PayPal can monetize not just transaction fees but also currency conversion spreads that can reach 2 to 3 percent per transaction, merchant services ranging from 2.9 percent plus per-transaction fees to more sophisticated pricing models, and credit services offered to regular users. Pakistan’s cash-dominated economy, where approximately 85 percent of transactions at point of sale remain cash-based, offers none of these advantages. Instead, PayPal would be forced to operate in a market where it cannot leverage its core business model, where the typical transaction size would be small, where the currency conversion opportunities are minimal due to low cross-border transaction volumes, and where credit extension services would be impossible due to lack of credit histories and high default risk.

The e-commerce infrastructure that would theoretically provide an alternative revenue stream for PayPal remains nascent and shows minimal growth momentum. As of Q1 FY24, Pakistan had only 6,889 registered e-commerce merchants across all banks and microfinance institutions. By Q2 FY25, this number had grown to approximately 7,310, a minimal increase of 421 merchants over a full year that hardly justifies major infrastructure investment by a company like PayPal. Point-of-sale terminal deployment, while growing, reached 179,383 devices by Q3 FY25, processing 99 million transactions worth PKR 550 billion quarterly. While these numbers represent progress from earlier baselines, they pale in comparison to markets where PayPal already operates profitably. For context, the United States alone processes tens of billions of card transactions quarterly. Even Bangladesh, a country with comparable population density but stronger financial inclusion, processes significantly higher transaction volumes through digital channels. For PayPal to justify infrastructure investment in Pakistan, the company would need to see a clear trajectory toward hundreds of billions of PKR in quarterly transaction volume. The current trajectory, growing at single-digit annual rates, provides no evidence that such volumes are within reasonable planning horizons.

Perversely, Pakistan’s existing freelancer community, the most vocal and economically valuable advocates for PayPal’s entry, has undermined the business case by successfully adapting to PayPal’s absence. The 2.37 million active freelancers have already developed sophisticated workarounds that, while imperfect and costly, function adequately for their purposes. These workarounds include opening accounts abroad through relatives or business partners, using Payoneer and Wise as intermediaries, forming US LLCs to access Stripe directly, and leveraging informal peer-to-peer networks to convert digital payments into local currency. As the IT Secretary informed a Senate committee in 2022, the major chunk of Pakistani clients have accounts in the UAE and other countries and the remaining customers in Pakistan are not making a business case for PayPal. This statement captures a critical insight: the market has bifurcated into those sophisticated enough and well-resourced enough to solve the PayPal problem themselves, and those who remain would constitute a low-value customer base inadequate to justify PayPal’s operational costs.

This creates a perverse market dynamic that economists recognize as a variant of the chicken-and-egg problem. The most sophisticated, highest-value users, those generating the estimated 3.2 billion dollars in annual IT exports, have already solved their payment problems through informal or semi-formal channels. What remains for PayPal to capture is a market segment that combines high compliance risk, due to weak financial infrastructure and limited documentation, with low revenue potential, due to smaller transaction sizes and limited card penetration. From PayPal’s perspective, entering Pakistan would require not merely building the infrastructure but also subsidizing it through years of operating at a loss to develop market penetration sufficient to achieve profitability. The company has rationally concluded that this capital allocation is inferior to deploying resources in markets like India, Brazil, or Southeast Asian countries where market conditions are significantly more favorable and where the infrastructure investment has already generated positive returns.

The Bidirectional Payments Dilemma: Capital Control Anxiety

Perhaps the most underappreciated and theoretically significant barrier to PayPal and Stripe’s entry is the State Bank of Pakistan’s fundamental anxiety about bidirectional payment flows and what they represent for capital control and macroeconomic stability. According to PIDE research, from the SBP point of view, the exchange control regime and data privacy are the major obstacles in the way of PayPal entering the Pakistani market. According to the SBP, the PayPal funds transfer mechanism is based on the bidirectional way and therefore the outflow of foreign exchange may create extra pressure on the external sector of Pakistan. This statement, which appears almost bureaucratic in its phrasing, actually reveals a deep institutional conviction that modern payment systems pose a fundamental threat to how Pakistan manages its economy. The concern is not primarily about money laundering or regulatory oversight. It is about capital control itself and whether the State Bank can maintain the ability to regulate the flow of foreign currency in and out of the country.

This concern is not theoretical or based on hypothetical scenarios. Pakistan maintains strict foreign exchange controls governed by the Foreign Exchange Regulation Act of 1947, a law that remains in effect nearly eight decades after independence and that operationalized through the SBP Foreign Exchange Manual. All foreign currency transactions must flow through authorized dealers including commercial banks, exchange companies, or licensed money transfer operators. The central bank tightly monitors both inward and outward remittances, requiring purpose codes for every transaction. Individual outward remittances are limited to approximately 10,000 dollars annually without special permission. The entire architecture of Pakistan’s external sector management depends on maintaining tight control over which individuals and companies can move currency across borders and in what quantities. PayPal’s value proposition, instant and frictionless bidirectional money movement, directly threatens this control architecture at its foundations.

To understand the depth of this concern, one must recognize what PayPal actually does and how it differs fundamentally from traditional international payment systems. In countries where PayPal operates legitimately, users can maintain account balances, send money to other users with a click, receive payments from global clients in minutes, and withdraw funds to bank accounts on demand. All of this happens with minimal friction and without requiring the user to interact with traditional forex dealers or authorized banks. For Pakistan’s freelancers, this would mean the ability to maintain 100 percent of their earnings in US dollars within PayPal accounts, converting to Pakistani rupees only when they choose, and maintaining flexibility to move funds across borders if needed for business expenses. For the State Bank, this represents an unacceptable loss of visibility and control. Currently, freelancers can repatriate only 35 to 50 percent of their export earnings into specialized foreign currency accounts, with the remainder forced to convert immediately into rupees at official rates. PayPal would flip this calculation entirely: freelancers could keep 100 percent of earnings abroad, only bringing in what they choose and when they choose.

The capital flight concern driving this anxiety is rooted in historical experience and contemporary macroeconomic fragility. Pakistan has experienced significant capital flight, particularly during periods of macroeconomic crisis. The concept of reverse capital flight, where money previously moved abroad illegally returns disguised as legitimate remittances, is well documented by economists studying Pakistan’s balance of payments. Trade misinvoicing, where imports are over-invoiced and exports are under-invoiced or vice versa, creates two-way illegal capital movements that distort official statistics. The surge in remittances, which reached 17.6 billion dollars in H1 FY2024-25, surpassing exports at 16.5 billion dollars, has led economists and central bank officials to suspect that some portion represents previously flown capital returning home through legitimate channels. The ratio of remittances to exports, a metric that has historically hovered near 60 percent, suddenly reached 107 percent, suggesting something structural has shifted in the composition of inflows. Central bank officials fear that opening the floodgates to PayPal would accelerate this process, transforming what might currently be underground capital movements into transparent digital flows that reveal the true extent of underground economy activity and capital flight concerns.

Recent SBP actions underscore the intensity of this anxiety and reveal that the central bank is actively tightening controls rather than loosening them. In November 2024, the central bank issued new directives restricting cash dollar transactions, mandating that all foreign currency purchases for deposit into Foreign Currency accounts must be executed through account-to-account transfers rather than cash disbursements. Exchange companies can disburse a maximum of 500 dollars in cash, with larger amounts requiring extensive documentation, biometric verification, and stated purpose. These restrictions aim to curb undocumented dollar hoarding and capital flight, the very behaviors SBP fears PayPal would facilitate systematically and at massive scale. The trajectory of policy changes indicates that Pakistan is moving in the opposite direction from what would be required to welcome PayPal. Rather than liberalizing capital flows or simplifying forex access, the State Bank is implementing increasingly restrictive measures designed to channelize all transactions through visible, monitored pathways. This policy direction makes PayPal entry not merely difficult but fundamentally opposed to the institutional direction Pakistan’s central bank is taking.

Data Localization: The Emerging Digital Sovereignty Barrier

A newer but increasingly significant obstacle to PayPal and Stripe’s entry is Pakistan’s evolving data protection regime and the broader geopolitical context of digital sovereignty that frames it. The Personal Data Protection Bill 2023, currently under consideration and likely to be enacted in substantially similar form, imposes strict data localization requirements that would force payment processors to maintain infrastructure within Pakistan. The bill categorizes personal data into three tiers: regular, sensitive, and critical. Critical personal data must be processed exclusively on servers located within Pakistan with no exceptions for technology companies or international firms. Sensitive personal data requires maintaining some components locally, though the legislation fails to define what some means, creating legal ambiguity that discourages investment and makes compliance impossible to plan for with certainty. This framework, modeled partially on similar regulations in China and Russia, reflects Pakistan’s desire to assert digital sovereignty and prevent foreign access to citizen data, a concern that has legitimate roots in surveillance anxieties but that creates practical impossibilities for multinational technology companies.

For US-based companies like PayPal and Stripe, data localization mandates create multiple compounding problems that go far beyond simple infrastructure investment. First, they require significant capital investment in local data centers and redundant infrastructure that many international companies consider uneconomical for smaller markets. Building a data center facility in Pakistan that meets enterprise-grade security and uptime standards represents a capital investment of tens of millions of dollars, an expenditure that PayPal would struggle to justify for a market with Pakistan’s current transaction volumes. Second, they fragment global data architecture in ways that reduce operational efficiency and increase ongoing costs. PayPal operates a globally integrated technology infrastructure where customer data, transaction records, and machine learning models are processed in centralized or regionally distributed data centers that serve multiple countries. Requiring a separate Pakistan-specific data infrastructure would mean duplicating entire systems, maintaining separate data pipelines, synchronizing data across geographies, and managing the regulatory complexity of multiple data residency requirements. Third, they create legal uncertainty about liability and compliance, particularly when local data protection laws conflict with US regulatory requirements like the CLOUD Act. The CLOUD Act, enacted in 2018, requires that US law enforcement can access data held by US companies regardless of where the data is stored. PayPal cannot store customer data in Pakistan and simultaneously guarantee to the Pakistani government that this data will not be accessed by US law enforcement. This represents a genuine legal conflict that has no clear resolution.

Data protection experts have noted that Pakistan’s data protection law imposes significant structural barriers for US technology companies and the strict localization mandate for critical personal data, paired with vague adequacy standards for cross-border transfers, forces firms to invest in redundant infrastructure and create bespoke compliance processes specific to the Pakistani market. These obligations are resource-intensive and raise legal uncertainty about whether and how data can be moved across borders. Notably, the bill includes explicit restrictions on data transfers to countries including Israel, Taiwan, Armenia, and India, provisions that reflect geopolitical considerations but further complicate compliance for multinational platforms with global routing architectures. For PayPal and Stripe, building a Pakistan-specific data infrastructure that complies with localization requirements while maintaining integration with global systems would be technically complex and economically unjustifiable for the market size. The regulatory framework essentially demands that international companies build infrastructure more expensive than the revenue they can generate from the market, a requirement that no profit-maximizing company can accept.

The Stripe Workaround: Exposing Regulatory Gaps

While PayPal remains entirely inaccessible from Pakistan, Stripe presents an interesting case study in regulatory arbitrage and how determined entrepreneurs find pathways around formal barriers. Pakistani entrepreneurs have discovered that by forming Limited Liability Companies in US states like Delaware, Wyoming, or New Mexico, they can legally access Stripe services without violating any laws or regulations. The process, while requiring technical sophistication and investment, has become sufficiently standardized that numerous service providers now offer packaged solutions. The process involves several steps including registering an LLC through formation services like Bizee or Doola at a cost of 200 to 500 dollars, obtaining an Employer Identification Number from the IRS through the standard application process, securing a US business address through a registered agent service that costs 50 to 100 dollars annually, acquiring a US phone number via services like Dingtone or Skype that cost a few dollars monthly, and opening a US business bank account through fintech platforms like Payoneer, Wise, or Mercury that accept remote applications from Pakistan. Once these elements are in place, Pakistani entrepreneurs can create legitimate Stripe accounts tied to their US entities and receive payments from global clients. The process typically takes two to four weeks and costs between 500 and 1,500 dollars in total, a modest investment relative to the business opportunities it unlocks.

This workaround operates in a legal grey zone that exposes the limitations of Pakistan’s regulatory framework and reveals uncomfortable truths about how modern regulatory systems can be circumvented. The arrangement is not fraudulent in any technical sense. The businesses are legitimately registered in the United States, all documentation is authentic, the Employer Identification Numbers are real, and the bank accounts are legal. However, the structure circumvents Pakistan’s Electronic Money Institution regulations, which ostensibly govern how Pakistani residents can access payment services. The SBP’s foreign exchange regulations require that export proceeds from services rendered by Pakistani residents be repatriated through authorized channels and reported for balance of payments statistics. When a Pakistani freelancer receives payments into a US LLC’s Stripe account and then transfers funds to Pakistan via wire transfer or Payoneer, they technically comply with inward remittance reporting requirements but operate entirely outside the EMI licensing regime. They neither require nor obtain permission from the State Bank to operate as a payment service provider. They navigate entirely around the regulatory infrastructure that Pakistan created specifically to govern payment services.

The existence and widespread use of this workaround reveals several uncomfortable truths that Pakistani officials and regulators would prefer not to acknowledge. First, it demonstrates that demand for international payment gateways is so intense that entrepreneurs will invest hundreds of dollars and navigate complex US corporate formation processes to access them. The willingness to incur this cost and complexity is a clear signal that the regulatory barriers to formal PayPal or Stripe entry are more onerous than alternative solutions. If Pakistani regulations were only moderately burdensome, most entrepreneurs would prefer the simplicity of domestic accounts. Second, it exposes the inadequacy of Pakistan’s own payment infrastructure and the complete lack of competitive alternatives. If local payment providers like Easypaisa, JazzCash, or other solutions offered feature parity with PayPal or Stripe, the LLC workaround would be unnecessary. Instead, these local solutions lack either the breadth of merchant integration, the currency conversion capabilities, the seller protection, or the global acceptance that PayPal or Stripe provide. Third, it highlights a fundamental regulatory gap that exposes the limits of national regulatory authority in a digital age. Pakistan can restrict which entities operate as payment service providers within its borders. Pakistan cannot prevent Pakistani citizens from establishing legitimate foreign entities to access services abroad. This gap cannot be closed without either authoritarian controls on freedom of establishment or restrictions on access to foreign services, neither of which is politically feasible in a democracy.

Interestingly, Stripe has occasionally terminated accounts created through this method, particularly those using Stripe Atlas, Stripe’s own company formation service, from Pakistan. Users report sudden account closures after three days, with Stripe citing business model concerns or geographic restrictions. This suggests that Stripe, like PayPal, views Pakistani-origin accounts as higher risk, even when technically compliant with US regulations. The company has implemented internal controls to identify and terminate accounts associated with Pakistan or Pakistani networks, indicating that the LLC workaround is officially known to Stripe and explicitly disfavored. This creates a precarious situation for Pakistani entrepreneurs who have invested in US entity formation: their accounts remain vulnerable to termination at any moment if Stripe’s risk assessment systems flag them. The workaround continues to function only because the detection mechanisms are imperfect and Stripe’s enforcement is inconsistent, but the company has clearly signaled that it is not a sustainable long-term solution.

Government Initiatives: Rhetoric Versus Reality

Pakistani government officials have made repeated public commitments to bringing PayPal to the country, commitments that have echoed through IT Ministry announcements, Senate committee hearings, and Finance Ministry statements. Yet substantive progress remains elusive, and understanding the timeline of these efforts reveals a consistent pattern of optimistic announcements followed by quiet failures or misrepresentations. In January 2024, then-caretaker IT Minister Dr. Umar Saif announced with considerable fanfare that PayPal would enter Pakistan through a strategic partnership with Payoneer. The announcement generated considerable excitement in the freelancer community, with media outlets and social media discussing the imminent availability of PayPal to Pakistani users. However, within weeks, it became clear that Saif had fundamentally misrepresented the nature of the announcement. The minister had referenced a global partnership between Payoneer and PayPal that allows Payoneer users worldwide to add PayPal as a payment method option. This is a standard integration that many payment processors offer, allowing users to link multiple payment sources to a single account. The announcement was not Pakistan-specific access to PayPal accounts. It was not a regulatory breakthrough. It merely allowed foreign clients who pay Payoneer users to do so via their own PayPal accounts. Pakistani users still cannot create PayPal accounts, still cannot receive payments through PayPal, and still cannot use PayPal’s services. The misrepresentation revealed either profound ignorance about what PayPal actually offers or a deliberate attempt to create political credit for a development that provides no practical benefit.

In February 2025, Finance Minister Senator Muhammad Aurangzeb provided a written reply to the National Assembly confirming that the Ministry of IT and Telecommunication is actively engaging with PayPal to explore its entry into the Pakistani market and that the State Bank is willing to support PayPal within the framework of ongoing discussions. The language is carefully crafted to suggest forward momentum while remaining vague about actual progress. Crucially, Aurangzeb stated that no legal barriers are preventing PayPal or any other international payment gateway from operating in Pakistan, provided they comply with Electronic Money Institution and Foreign Exchange regulations. This statement is technically accurate in a legalistic sense but practically misleading in every substantive way. While there may be no absolute legal prohibition on PayPal operating in Pakistan, there are no laws explicitly titled “you must exclude PayPal,” the compliance requirements create such high barriers that they function as de facto prohibitions. The EMI licensing process, the capital requirements, the AML/CFT regulations, the data localization mandates, and the foreign exchange controls operate together to create a regulatory environment so burdensome that entry becomes economically irrational. Saying no legal barriers exist, provided they comply, is equivalent to saying there is no barrier to climbing Mount Everest provided you reach the summit. It is technically accurate while being practically meaningless.

In December 2024, a meeting of the Prime Minister’s Committee on IT Export Remittances highlighted that Pakistan is home to 2.32 million freelancers contributing 15 percent of IT exports, yet only 38,000 hold bank accounts. The committee emphasized the urgent need for access to global payment gateways like PayPal but offered no concrete action plan beyond forming yet another working group comprising representatives from FBR, SBP, the IT Ministry, and industry associations. This pattern of committee formation is itself a signal of institutional dysfunction. At some point, the number of committees becomes counterproductive. When a problem has been under study by multiple committees for over five years without resolution, additional committees do not represent progress. They represent an institutionalized substitution of discussion for action. The committees provide political cover for inaction by creating the appearance of engagement. They allow officials to claim momentum and serious effort. Yet the committees consistently recommend the same things: streamline regulations, improve coordination between agencies, engage with PayPal, consider sandbox approaches. That these recommendations are never implemented suggests either that implementation would require political capital that senior officials are unwilling to spend or that the recommendations are offered performatively with no genuine expectation of implementation.

This pattern of committees, working groups, ministerial statements, and misrepresented announcements but no implementation suggests that bringing PayPal to Pakistan is not actually a priority for either the company or, despite public rhetoric, the government. PayPal has made its economic calculus clear through years of inaction and official statements that Pakistan remains excluded from its expansion plans. The Pakistani government, meanwhile, appears more interested in being seen as trying to bring PayPal than in making the structural reforms that would actually attract the company. The structural reforms required would be significant: reducing regulatory barriers substantially, accepting bidirectional capital flows, guaranteeing data transfer rights, and potentially subsidizing initial operations to build market momentum. These reforms would require political capital, would potentially create controversy with nationalist constituencies concerned about sovereignty and capital flight, and would require genuine coordination between institutions that have not demonstrated capacity for such coordination. It is substantially easier to form a committee, make optimistic statements, and then later blame PayPal for not being ready to enter Pakistan than to implement the difficult reforms that might actually work.

Comparative Context: Why Somalia, Yemen, and Rwanda Have PayPal (Sort Of)

A puzzling aspect of PayPal’s absence from Pakistan is that it operates, albeit with severe functional limitations, in countries with far weaker institutional infrastructure, less developed banking systems, and in some cases active conflict. Yemen, Somalia, and Rwanda all appear on PayPal’s list of supported countries. This seems paradoxical at first glance. How can PayPal operate in war-torn Yemen, where banking infrastructure barely functions and government authority is contested, but not operate in relatively stable Pakistan, which has a functional central bank, banking system, and government? The answer lies in understanding the nature of PayPal’s operations in these countries and what functions it actually provides. They are classified as PayPal Zero countries, jurisdictions where users can send money out but cannot officially receive payments or hold account balances. In Rwanda and Uganda, for example, users can send money abroad to other PayPal users but cannot receive payments from clients or maintain account balances. In Yemen and Somalia, PayPal’s presence is largely vestigial, likely grandfathered from earlier, more stable periods when these countries had full PayPal functionality, with severe functional limitations that render the service nearly unusable for freelancers or businesses.

These limited-functionality accounts serve a specific purpose in PayPal’s global strategy: they allow diaspora communities to send remittances home without requiring the company to invest in local infrastructure, conduct extensive AML/CFT compliance work, or manage the regulatory relationships that full-featured operations demand. They do not provide the full suite of PayPal services that Pakistan’s IT sector demands. There is no merchant account functionality that allows businesses to accept payments on their websites. There is no payment gateway API integration for e-commerce platforms. There is no currency conversion service that allows users to maintain balances in different currencies. There is no comprehensive buyer or seller protection program that instills confidence in transaction counterparties. What PayPal offers in these countries is essentially a one-way money transfer tool that functions similarly to Western Union. For Pakistan’s 2.37 million active freelancers and thousands of e-commerce businesses, this level of functionality is entirely inadequate. Pakistani entrepreneurs need the ability to create merchant accounts, integrate PayPal payment buttons into their websites, receive payments from global clients automatically, and manage their funds with the flexibility that full PayPal accounts provide. Such comprehensive operations trigger the full weight of EMI regulations, AML/CFT compliance requirements, data localization mandates, and SBP oversight. The regulatory burden for providing full-featured PayPal services in Pakistan is precisely why it is not offered in limited fashion as in Somalia or Yemen.

The comparison with Bangladesh is also instructive and reveals that the barriers to PayPal entry transcend Pakistan-specific governance failures. Despite significantly outperforming Pakistan in financial inclusion metrics, a factor one might expect to make markets more attractive to PayPal, Bangladesh also lacks full PayPal access. Bangladesh has microfinance loans reaching BDT 1.8 trillion, higher savings and investment rates relative to Pakistan, more effective central bank policies supporting SME credit, and a large software export sector comparable to Pakistan’s. Yet Bangladesh also lacks the ability for residents to create PayPal accounts with full functionality. This suggests that the barriers to PayPal entry run deeper than regulatory quality or financial development metrics. They reflect structural issues about market size, regulatory complexity, and the risk-reward calculations that international payment processors make about emerging markets. If even Bangladesh, with better fundamentals in many respects, cannot attract PayPal’s full entry, then Pakistan’s lack of PayPal becomes less surprising. Both countries appear to occupy a no man’s land: too large and sophisticated to be addressed with limited diaspora-focused services, yet too small and risky to justify the full investment required for comprehensive operations.

The Real Insider Story: What’s Actually Happening

Synthesizing public statements, regulatory documents, industry interviews, and the trajectory of policy changes reveals the true dynamics preventing PayPal and Stripe from entering Pakistan. These dynamics are less about conspiracy or corruption than about a series of rational actors making decisions based on genuine constraints and legitimate concerns, yet those decisions align in ways that systematically prevent entry. PayPal has never seriously considered Pakistan a viable market for full-featured operations, despite government claims of ongoing negotiations and despite PayPal’s public commitment to financial inclusion. This assessment is not based on speculation. It is based on years of explicit statements, licensing decisions, and resource allocation choices. The 2019 statement from the National Incubation Centre that PayPal never agreed to come to Pakistan in the first place because Pakistan’s market size is not good enough captures the company’s actual assessment. The 2022 decision to exclude Pakistan for the next two years represented an official decision to not prioritize the market. More than three years later, there is no evidence that this decision has changed. The 2024 and 2025 government statements about ongoing discussions likely represent Pakistan’s continued outreach efforts rather than PayPal’s active engagement or serious consideration. PayPal’s business case for Pakistan entry was settled negatively years ago, and nothing in Pakistan’s macroeconomic situation, IT market development, or regulatory trajectory has changed enough to alter that assessment.

The State Bank of Pakistan fears losing control over capital flows and foreign exchange management more than it desires the innovation and consumer benefits that PayPal would bring. While SBP officials publicly express willingness to facilitate PayPal entry within the framework of existing regulations, the institution’s actual actions reveal a deep distrust of bidirectional payment flows and a commitment to capital control that supersedes all other considerations. The November 2024 directives restricting cash dollar transactions, the maintenance of tight foreign exchange controls, and the limits on how much foreign earnings freelancers can repatriate all reflect this priority structure. The trajectory of policy changes indicates that Pakistan is moving in the opposite direction from what would be required to welcome PayPal. Rather than liberalizing capital flows, simplifying forex access, or creating exceptions for payment processors, the State Bank is implementing increasingly restrictive measures designed to channelize all transactions through visible, monitored pathways that the central bank controls. For the SBP, allowing PayPal to operate would require accepting a level of capital mobility and loss of control that contradicts the institution’s fundamental approach to economic management. The central bank has made an implicit but clear choice that managing the balance of payments is more important than facilitating remittances or enabling the IT sector. From an institutional perspective, this is not irrational. It reflects genuine concerns about capital flight and the precarious state of Pakistan’s foreign exchange reserves. But it does mean that the State Bank is, for practical purposes, an opponent of PayPal entry rather than a supporter.

The existing workaround economy reduces pressure for formal solutions from all parties. The fact that Pakistani freelancers have successfully adapted by forming US LLCs, using Payoneer and Wise, maintaining accounts abroad through relatives and business partners, and accessing informal peer-to-peer networks means the most economically valuable segment has solved the problem for themselves. This reduces both political pressure on the government and market opportunity for PayPal. When the IT sector can generate 3.2 billion dollars in annual exports without PayPal, through a combination of workarounds and informal channels, the urgency for government action dissipates. The politicians who would otherwise face pressure from frustrated freelancers can point to the continued growth of the sector and claim that everything is functioning adequately. The freelancers themselves, particularly the most sophisticated and highest-earning ones, have made their own arrangements and need not pressure the government. What remains is a market segment of lower-value users who lack the resources to establish US entities and who rely on local solutions. For PayPal, this is precisely the wrong segment to target: higher compliance risk but lower revenue potential.

Formalization of payments through a transparent, regulated channel like PayPal would expose the true scale of informal and semi-formal cross-border flows and would likely reveal massive underreporting of current IT services exports. The stated figure of 3.2 billion dollars in annual IT services exports is almost certainly understated, with economists estimating true exports at potentially 4 to 5 billion dollars when informal channels are accounted for. If a significant portion of this suddenly routed through a transparent, regulated channel like PayPal, it would require reconciliation between the official export statistics and the actual documented payments. This reconciliation would inevitably reveal either that previous statistics were incomplete or that a large portion of what has been claimed as government-regulated exports actually occurs through informal channels. For government agencies that take credit for IT sector growth and for the SBP that incorporates these figures into balance of payments calculations, this revelation would be politically and institutionally awkward. The government and SBP may prefer the current ambiguous system, where they claim credit for rising IT exports while maintaining plausible deniability about the scale and actual mechanisms of these flows.

Data localization has emerged as a technically legitimate but increasingly convenient justification for continued foreign payment gateway absence. The Personal Data Protection Bill 2023 genuinely does impose onerous data localization requirements that would be expensive for international companies to meet. These requirements are not fabrications or pretexts. However, the bill also provides officials with an institutional explanation for why PayPal cannot enter: it is not because the market is too small or the compliance burden is too high, but because data sovereignty concerns require localization that PayPal is unwilling to undertake. This framing allows officials to appear to support PayPal entry while simultaneously protecting themselves from the charge that they have failed to attract the company. They can blame PayPal’s unwillingness to build local data infrastructure rather than acknowledging that the regulatory environment overall, including data localization but also capital controls, EMI requirements, and market size, makes entry irrational for the company.

The Economic Cost: Quantifying the Loss

While precise quantification is difficult due to the informal nature of workarounds and the opacity of cross-border payments, the economic cost of PayPal and Stripe’s absence is substantial and operates across multiple dimensions of economic activity. Transaction cost burden represents only the most visible aspect of the total cost, but it is quantifiable. Freelancers using alternatives like Payoneer pay fees ranging from 1 to 3 percent for withdrawals, compared to PayPal’s 2.9 percent plus 0.30 dollars for standard transactions. However, the real cost comes from exchange rate spreads, which far exceed the transaction fees themselves. Payoneer’s currency conversion markup can reach 2 to 3 percent above the interbank rate, adding invisible costs to every transaction. For 3.2 billion dollars in annual IT exports, a 2 percent transaction cost penalty amounts to 64 million dollars in additional fees borne by Pakistani earners. Over a decade, this accumulates to 640 million dollars in excess costs paid to foreign intermediaries that would not exist if PayPal were available.

Delayed payments and the opportunity cost of capital tied up in payment pipelines represent a second category of loss that is harder to quantify but potentially more significant than transaction costs. Bank wire transfers, the most common formal channel for receiving payment remittances, typically take 3 to 7 days to clear and incur 25 to 50 dollars in fees per transaction. PayPal’s instant transfer capability would eliminate these delays entirely, improving cash flow for small businesses and freelancers. The opportunity cost of delayed payments operates through multiple channels: inability to pay suppliers who demand immediate payment, missed investment opportunities that require rapid capital deployment, working capital tied up in accounts receivable, and inability to respond quickly to market opportunities that require immediate funding. For a freelancer in Pakistan who receives payment from a US client but must wait a week for funds to clear, those delays might mean inability to pay local team members on time, forcing them to seek alternative contracts or payment arrangements. The macroeconomic effect, when aggregated across millions of transactions, likely reduces productivity and growth by measurable amounts, but the effect is diffuse and therefore underestimated in policy discussions.

Market access limitations directly reduce competitiveness for Pakistani entrepreneurs competing in the global freelance marketplace. On platforms like Upwork and Fiverr, which collectively represent a 10 to 15 billion dollar annual market for freelanced services, many high-value clients refuse to work with freelancers who cannot accept PayPal. Clients view PayPal as a security and trust signal that gives them confidence in the payment mechanism. A client may be willing to pay a Pakistani freelancer 100 dollars for a task but unwilling to do so unless the payment can go through PayPal. This is not because PayPal is objectively superior to Payoneer or Wise in security, but because PayPal is the market standard in developed countries and clients default to it. This limitation forces Pakistani freelancers to compete primarily for clients willing to use alternative payment methods, typically lower-budget projects or clients in developing countries with lower payment expectations. The lost revenue from projects that Pakistani freelancers would win if PayPal were available probably amounts to hundreds of millions of dollars annually.

Leakage and tax revenue loss accumulate through the informal and semi-formal channels that Pakistanis have developed to substitute for PayPal. The extensive use of foreign-registered LLCs and offshore accounts means significant IT export revenues never formally enter Pakistan’s banking system. While freelancers are required to declare foreign income for tax purposes, enforcement is notoriously weak when money flows through foreign entities incorporated in Delaware or Singapore. A freelancer can maintain an LLC account receiving 10,000 dollars monthly from US clients, report only a fraction of that to Pakistan’s tax authorities, and face low risk of audit or enforcement. The Federal Board of Revenue likely loses hundreds of millions in potential tax revenue from underreported IT service income. For a government struggling with tax collection rates below 12 percent of GDP, this lost revenue represents a significant drag on government capacity to fund infrastructure, education, and defense.

Foreign exchange tracking failures distort macroeconomic data and undermine the State Bank’s ability to conduct effective monetary policy. When freelancers keep earnings in US LLC accounts and selectively repatriate funds, the State Bank loses accurate visibility into actual export earnings. The official figure of 3.2 billion dollars in annual IT service exports almost certainly understates true services exports by 20 to 30 percent. This means balance of payments data is systematically distorted, making it harder for policymakers to understand the true source of inflows and the true sustainability of Pakistan’s external position. Central banks require accurate data to conduct effective policy. If the data consistently underestimates exports, then policy may be more restrictive than necessary, creating unnecessary drag on the economy.

What Would It Take? The Path Forward

For PayPal or Stripe to enter Pakistan at scale with full-featured services, several fundamental shifts would be required in regulatory, macroeconomic, and political domains. These shifts would need to occur simultaneously, suggesting that piecemeal reform is unlikely to succeed. Regulatory streamlining would need to compress the EMI licensing process from 10 or more months to 60 to 90 days maximum. The licensing process would need to shift from an adversarial model where regulators approach applications assuming fraud or danger until proven otherwise, to a partnership model where regulators work to enable compliant operations. Capital requirements should be risk-adjusted based on transaction limits and business model, rather than flat PKR 200 million minimums that treat all payment service providers identically. A sandbox approach, allowing limited pilot operations with lighter oversight, could demonstrate viability before full licensing commitments. This is a model that regulators in Malaysia, Singapore, and the UAE have used successfully to bring fintech companies into their markets. Pakistan’s SBP has discussed sandbox regulation but has not implemented it meaningfully.

Bidirectional flow acceptance represents perhaps the most fundamental shift required. The State Bank would need to accept intellectually and institutionally that modern digital payment platforms require two-way flows and that attempting to restrict these flows creates evasion and black markets rather than actually controlling capital. This means allowing freelancers and businesses to hold higher percentages of earnings in foreign currency accounts rather than forcing immediate conversion to rupees. It means permitting easier repatriation of funds for business expenses and supply chain payments rather than requiring specific approval for each transaction. It means trusting that transparent, monitored channels like PayPal are preferable to opaque informal transfers. This requires a fundamental philosophical shift from capital control to capital management, from an assumption that any outflow is suspect to an understanding that some capital outflows are necessary for economic activity. This shift would likely require either a change in SBP leadership or economic circumstances sufficiently dire that current policies are seen as having failed.

Data transfer guarantees would need amendment or clarification of the Personal Data Protection Bill to permit cross-border data flows for financial services, possibly through an adequacy determination or safe harbor mechanism. Payment processors cannot build Pakistan-specific data infrastructure for a market this size and at this stage of development. They need assurance that data can flow to regional hubs in Dubai, Singapore, or Mumbai where PayPal maintains regional processing centers. This would require the Pakistani government to essentially accept that some Pakistani citizen data will be processed outside Pakistan’s borders, a concession that many policymakers find fundamentally objectionable from a sovereignty perspective. Yet this is the price of participating in a global financial system built on integrated technology infrastructure.

Market incentives could theoretically offset low credit card penetration if the government deployed sufficient resources. The government could subsidize merchant acquisition fees for the first 50,000 businesses that integrate PayPal, creating a starter network effect that would bootstrap the market. Alternatively, PayPal could pilot operations focused solely on freelancer payments and B2B services export payments, entirely sidestepping the consumer e-commerce challenges that characterize Pakistan’s weak payment infrastructure. This would require PayPal to define Pakistan as a special-case market where it operates a partial service tailored to actual demand rather than its standard global service.

Government risk guarantee or indemnification could address PayPal’s money laundering liability fears. Pakistan could establish an indemnity fund or regulatory safe harbor, where the government assumes a portion of the financial risk for AML/CFT violations that occur despite PayPal’s good-faith compliance efforts. This would require the government to put its reputation and financial resources behind the commitment that it would not blame PayPal if money laundering occurred through the system. Few governments are willing to make such commitments, and few companies would find them credible even if offered.

None of these solutions appear imminent or even likely. The government continues to prioritize rhetoric over reform, announcing committees and expressing support while declining to make the substantive changes that would actually result in entry. The State Bank maintains its capital control paradigm with increasing rather than decreasing strictness. PayPal shows no indication of reconsidering its market assessment or engaging in serious discussions about entry terms. And Pakistani entrepreneurs continue to find workarounds, reduce pressure for systemic change, and allow the government to claim that the problem is not actually urgent.

Conclusion: A Stalemate by Design

The absence of PayPal and Stripe from Pakistan is not an accident, not an oversight, and not a temporary obstacle awaiting resolution. It is the logical and predictable outcome of incompatible incentive structures, misaligned priorities, and fundamental disagreements about the acceptable level of financial openness in an economy. Each party involved has genuine reasons for its positions, but those reasons align in ways that make entry impossible without unacceptable compromises.

PayPal sees a small, low-margin market where most valuable users have already found alternatives through US LLC workarounds and Payoneer intermediaries, where regulatory compliance costs are prohibitive, and where a single money laundering incident could trigger catastrophic consequences for the company globally. For the company, Pakistan presents downside risk without commensurate upside potential. This assessment is correct within PayPal’s business model and risk tolerance. The company is not making an error. It is making a rational decision based on accurate information.

Pakistan’s government wants the prestige and economic benefits of hosting international payment gateways but refuses to make the structural concessions that would actually attract them. Officials prefer to blame historical factors like FATF restrictions, external actors like PayPal’s supposed reluctance, or technical issues like inadequate infrastructure rather than confronting the reality that Pakistan’s own policy choices make entry unattractive. The IT Ministry wants PayPal but the State Bank does not want its financial system opened to the capital mobility that PayPal would bring. The Prime Minister’s committees want growth but are unwilling to tolerate the institutional change that growth requires. This fundamental lack of coherence at the highest levels of government means that while individual officials press PayPal for entry, the government as an institution is not actually prepared to welcome it.

The State Bank of Pakistan fears that enabling seamless bidirectional payments would undermine its ability to manage foreign exchange, would expose the true scale of informal capital flows, and would create pressure on reserves that the central bank is barely managing in the best circumstances. From a central banker’s perspective, particularly one managing an economy with precarious foreign exchange reserves, maintaining control trumps facilitating innovation. This is a genuine institutional position with real consequences for the central bank’s ability to manage the external sector. The fear is not paranoid or irrational. It is based on real experience with capital flight and real constraints on Pakistan’s external position. But it does mean that the State Bank is, for practical purposes, an institutional obstacle to PayPal entry.

Meanwhile, Pakistan’s IT sector continues to grow at 20 percent or more annually despite operating without PayPal. Freelancers continue to form US LLCs and file Articles of Organization with the Delaware Department of State. The workaround economy functions and permits billions of dollars in service exports to flow to Pakistan through channels that evade official scrutiny and avoid formal taxation. The economy functions, not optimally and with substantial leakage and inefficiency, but adequately. This absence of crisis, this ability of the system to muddle through despite serious impediments, reduces urgency for any party to compromise. When the status quo is unsatisfactory but not catastrophic, change becomes unlikely.

The question, then, is not whether PayPal will finally come to Pakistan in the near future. Available evidence strongly suggests it will not. The question is whether Pakistan’s IT sector can continue to thrive despite institutional failures, whether the LLC workaround economy can scale to 10 billion dollars in exports, whether the informal and semi-formal payment channels can continue to function without formal integration, and whether the government will eventually realize that digital-era competitiveness requires accepting levels of financial openness that make policymakers uncomfortable. For now, Pakistan’s freelancers remain trapped in a financial twilight zone, celebrated for their entrepreneurial spirit while systematically denied the infrastructure needed to compete on equal footing with peers in countries that welcome international payment processors. They have learned to succeed despite their country’s institutions, not because of them. This is a distinctly Pakistani form of resilience that both inspires admiration and saddens in equal measure, a demonstration of human ingenuity in overcoming obstacles that should not exist.

Sources

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