The Qatar Central Bank (“QCB”) has issued the much-awaited Buy Now Pay Later (“BNPL”) Regulations (“BNPL Regulations”) following the launch of its FinTech Strategy earlier this year. While BNPL products and services are currently being offered in Qatar, albeit on a limited scale, through licensed financial institutions in Qatar, the BNPL Regulations seek to regulate the provision of BNPL products and services via separately licensed BNPL service providers.
The BNPL Regulations are in effect from 6 August 2023.
What is BNPL?
BNPL is gaining traction throughout the Middle East and North Africa region. It is essentially a short term (no more than 12 months) interest free credit facility that allows a customer to split its transaction amount into instalment payments to allow repayment over a period of time to the BNPL service provider (“BNPL Product or Service”).
Scope of BNPL Regulations
The BNPL Regulations are applicable to any person providing BNPL Product or Service in Qatar (“BNPL Provider”) and such person must obtain a specific license from the QCB pursuant to the BPL Regulations. Under the BNPL Regulations, a BNPL Provider is lender that undertakes the credit risk of a BNPL Product or Service. Having said that, it should be noted that the BNPL Provider cannot provide or lend cash to the customers.
A BNPL Product or Service must meet all of the following criteria:
The BNPL Product or Service is provided to an individual customer resident in Qatar (age 18 or above) for the purchase of products or services from Qatar or non-Qatar based Merchants.
It is an interest free short term credit facility wherein payments are split into instalments spread over 12 months or less provided with or without a fixed service charge.
The BNPL Provider undertakes the complete credit risk of the provided facility.
It is an unsecured lending product.
The BNPL Regulations has applicability throughout the State of Qatar and applies to any BNPL Provider set up under the Ministry of Commerce and Industry (MOCI), the Qatar Financial Centre (QFC), the Qatar Science and Technology Park (QSTP), or any other free zone authority or commercial licensing entity.
The BNPL Regulations take into consideration the offering of both conventional and Shari’a compliant BNPL Products and Services, For Shari’a compliant structures, the BNPL Provider must appoint a Shari’a Advisor (subject to QCB approval) to advise on the relevant structures and characteristics of Shari’a compliant BNPL Products and Service offering.
Licensing
The BNPL Regulations stipulate that entities seeking to operate as BNPL Providers in Qatar must submit a license application to the QCB prior to undertaking any BNPL related activities.
The QCB has announced that it will start accepting applications for BNPL license in September 2023.
How Al Tamimi & Company can help?
We will be preparing a detailed overview of the regulations including the requirements for setting up and licensing under the BNPL Regulations.
Al Tamimi & Company is in a unique position to assist and guide our clients seeking to engage in BNPL activities in Qatar by leveraging our presence and capabilities throughout the Middle East and North Africa region where we regularly advise local and international financial and non-financial service providers on their diverse payment solutions and offerings, including BNPL services, in terms of setting up, licensing and compliance with local laws and regulations.
If you require further information, please feel free to reach out to Matthew Heaton and Muhammad Mitha from our Banking & Finance team at Al Tamimi & Company should you require advice on offering of BNPL services in Qatar.
Key Contacts
Matthew Heaton
Partner, Head of Office, Head of Banking & Finance - Qatar
m.heaton@tamimi.com
Muhammad Mitha
Senior Counsel
m.mitha@tamimi.com