Cash Deposit Limit in Pakistan Raised to Rs3 Million: What the New Bank Reporting Rule Means for COD Sellers

What changed this week

The cash deposit limit that makes your bank file an automatic report in Pakistan is going up from Rs2 million to Rs3 million. Dawn reported on 28 October 2026 that the National Executive Committee (NEC) on anti-money laundering and countering the financing of terrorism, chaired by Finance Minister Muhammad Aurangzeb, approved raising the threshold for Currency Transaction Reports (CTRs) by Rs1 million, or 50 percent. If you run a COD store and your riders hand you cash, or you pay suppliers in cash, this is the rule that decides when your bank reports a cash transaction to the government's Financial Monitoring Unit (FMU).

Three more things came out of the same meeting, according to Dawn. The Pakistan Virtual Assets Regulatory Authority (PVARA) was added to the list of AML supervisors, alongside the State Bank, SECP, FBR, National Savings and Pakistan Post. Piracy was added as a predicate offence under the Anti-Money Laundering Act. And the Finance Minister asked for a clear roadmap with timelines to strengthen the FMU's analysis, including its artificial intelligence and machine learning work.

One important detail: the NEC sets this limit through a notification in the official gazette. Dawn's report does not say whether the Rs3 million notification has been issued yet or from which date it applies. Until your bank confirms it, assume the old Rs2 million figure is still in use.

What is a CTR, and what it is not

Many sellers hear 'report' and think 'trouble'. A CTR is not an accusation. It is a routine report that banks and other reporting entities must file for every cash transaction at or above the notified amount, whoever makes it. ProPakistani reported in July 2021 that the FMU directed banks and other reporting entities to file CTRs for cash transactions of Rs2 million or more, electronically through its goAML system, which has been used for all CTRs since 1 January 2020. The Rs2 million figure itself dates back to a Finance Ministry notification of 21 January 2015, according to an SBP circular.

The same FMU guidance said account-to-account transfers must not be reported as CTRs. In plain words, a CTR is about physical cash at a counter, not bank transfers. Your courier's COD payout that lands in your account by bank transfer is not a cash transaction.

The STR column matters more for most sellers than the new limit. Under Section 7(1) of the Anti-Money Laundering Act 2010, reporting entities must promptly report suspicious transactions. In April 2022, ProPakistani reported, the FMU told banks to file STRs when an account holder receives multiple small bank deposits from unknown and unrelated individuals. That directive was about terrorist financing, but look at it from a COD seller's side: a store that takes advance delivery charges or prepaid orders by bank transfer receives exactly that, many small transfers from strangers. FBR's red-flag guides for reporting entities also list transactions designed to evade reporting requirements. The FMU says a single red flag on its own is not a clear sign of wrongdoing, but you want your records to answer any question in one look.

Which online sellers does the Rs3 million limit touch?

Most Shopify and COD sellers in Pakistan never handle Rs2 or Rs3 million in cash in one go. Here is where cash actually moves in a typical online store, and whether the limit applies.

So the change matters for three kinds of sellers: those who deliver their own orders in Lahore, Karachi or Islamabad and bank the cash, those who buy stock from wholesale markets with cash, and those whose sale-season volumes push a single deposit or withdrawal past Rs2 million.

Example: when the old and new limits bite

Example (illustrative numbers, not from any real store). A Lahore clothing seller delivers in-city orders with two own riders and sends the rest through a courier. Own-rider orders average Rs2,800 and 80 percent are paid at the door.

Only the stock purchase crosses the line. Under the old limit, the Rs2.5 million withdrawal would be reported; under the new one, once notified, it would not. Either way, the report is routine. What would draw a real question is if this seller took Rs2.5 million out as Rs900,000 on Monday, Rs900,000 on Tuesday and Rs700,000 on Wednesday just to stay under Rs2 million. Breaking up cash to avoid the report is the kind of pattern red-flag guides describe. One honest transaction is better than three that look planned.

What to do this week

1. Ask your bank whether the Rs3 million CTR limit is in force yet. Until the gazette notification is issued, Rs2 million is still the figure.
2. Never split cash deposits or withdrawals to stay under the limit. If you need to pay a wholesaler Rs2.5 million, do it as one transaction, or better, pay by bank transfer or Raast so there is no cash transaction at all.
3. Keep business money in one account. Mixing family spending, committee payments and COD cash in one personal account makes your activity harder to explain. A separate account for the store keeps the story simple.
4. Make every customer transfer traceable. When customers pay an advance or a prepaid order by Raast, JazzCash or Easypaisa, ask them to put the order number in the transfer note. Then a list of small transfers from strangers matches a list of Shopify orders.
5. Match deposits to orders. For own-rider cash, keep a daily sheet: rider name, order numbers, cash collected, date deposited. For courier payouts, match each payout to delivered orders, as in our COD reconciliation sheet. RabbitROI's courier tracking updates automatically for Leopards, PostEx, DEX, Daewoo and Avix, which makes the delivered-orders list easier to pull.
6. Tell your bank what your business does. If your account is opened as a personal salary account and suddenly receives hundreds of small transfers, the bank will ask. Ask how to update your account profile to show you run an online store.
7. Move cash to digital where it costs you nothing. Dawn reports 48.3 million registered Raast IDs by December 2025 and 2.1 million merchants registered for Raast person-to-merchant payments. A customer who can pay a rider by QR is cash you do not have to carry or deposit.
8. For tax questions, such as how cash sales and withdrawals show up in your return, check with your accountant.

The bigger picture: cash is shrinking, records matter more

In a Dawn column published on 26 October 2026, Nadeem Hussain, chairman of the Pakistan Fintech Network, wrote that 92 percent of retail transactions in Pakistan now go through digital channels, and that Raast processed 646 million transactions worth Rs18.5 trillion between October and December 2025 alone. COD is still the way most online shoppers pay, but the money around it is going digital fast.

That shift cuts both ways for a seller. Digital money is safer than a bag of cash and leaves a clean trail. It also means every rupee leaves a trail, and the FMU is investing in AI tools to read those trails. A higher CTR limit means fewer routine reports for cash. It does not change what keeps a seller safe: one business account, transfers you can match to orders, and no tricks to stay under a limit.

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