The Virtual Assets Act, 2026, the Pakistan Virtual Asset Services Regulations, 2026, and the three steps from NOC to licence.
Safi Ghauri, Managing Partner, Esquare Legal. Currently represents the world’s second-largest crypto exchange and several leading fintechs before PVARA.
The Virtual Assets Act, 2026 is in force. On 21 August 2026 PVARA notified the Pakistan Virtual Asset Services Regulations, 2026 (S.R.O. 1419(I)/2026) and the Pakistan Virtual Asset Services Activity Specific Regulations, 2026 (S.R.O. 1420(I)/2026). NOC applications are now made under the Services Regulations; the NOC Regulations, 2025 no longer apply to new applications.
Under section 70 of the Virtual Assets Act, 2026 and PVARA advisory PVARA/ADV/001/2026, persons who were providing virtual asset services on or before 5 March 2026 had to submit an NOC application by 5 September 2026 or cease operating. That date has passed. Other persons may apply for the Regulatory Sandbox or an NOC when they meet the requirements.
The Services Regulations apply to Virtual Asset Services carried on in or from Pakistan. An activity may be treated as carried on in Pakistan where it targets, solicits, promotes to or onboards persons in Pakistan, including through marketing on a website or app, payment rails, provision of services in PKR, or channels accessible to persons in Pakistan (Reg 3(4)). A website or app is not, of itself, treated as carried on in Pakistan merely because it can be reached there, if the operator does not market or solicit in Pakistan, does not onboard persons in Pakistan, does not support PKR rails or Pakistan-targeted channels, and takes reasonable steps to prevent onboarding where it does not intend to serve Pakistan (Reg 3(5)).
Wilfully providing an unlicensed virtual asset service is an offence punishable by imprisonment for up to five years, a fine of up to PKR 50 million, or both (Virtual Assets Act, 2026, section 54(1)).
Licensing runs in three steps under the Services Regulations, 2026.
A person intending to establish a company in Pakistan applies on Form I with the documents in its Annexure: applicant and board details, capital and liquidity attestation, a business plan with three-year projections including stress scenarios, the intended custody model, the jurisdictional delivery model (channels, geo-targeting and geo-blocking controls, group entities and outsourcing), and the fit-and-proper information for sponsors, the chief executive and directors. PVARA decides a complete application within 60 days, either granting an NOC with conditions or refusing with written reasons. An NOC is valid for three months and may be extended once by up to three months. It is not a licence and does not allow any service to be provided.
After the NOC, the applicant incorporates the Pakistani company under the Companies Act, 2017 (minimum three directors; 100% foreign shareholding is permitted) and completes registration with the Financial Monitoring Unit.
Within the NOC’s validity, the company applies for one or more licence categories with the updated Form I documents and the non-refundable processing fee. An application is complete only when PVARA confirms in writing that it has everything it needs, and the clock stops while PVARA waits for further information. PVARA decides within 90 days of completeness, extendable by up to 60 days for complex applications. Director and managing-director appointments need PVARA approval before they take office; PVARA must decide within 30 business days of a complete request.
Local presence (Reg 10(4)). A licensee must keep a registered office in Pakistan and at least one key individual resident in Pakistan with operational and decision-making authority who is accountable to PVARA for compliance.
Because both statutory periods run only from PVARA’s confirmation that an application is complete, elapsed time depends mainly on how quickly the file is made complete.
Minimum paid-up capital by licence category (Services Regulations, Schedule I).
| Licence category | Minimum paid-up capital (PKR) |
|---|---|
| Advisory Services | 15,000,000 |
| Broker-Dealer Services | 75,000,000 |
| Custody Services | 200,000,000 |
| Virtual Asset Management and Investment Services | 200,000,000 |
| Virtual Asset Transfer and Settlement Services | 200,000,000 |
| Fiat-Referenced Token Issuance Services | 300,000,000 |
| Asset-Referenced Token Issuance Services | 300,000,000 |
| Exchange Services | 500,000,000 |
| Lending and Borrowing Services | 500,000,000 |
| Virtual Asset Derivatives Services | 500,000,000 |
| Mining Related Virtual Asset Services | 500,000,000 |
Capital must be maintained at all times (Reg 10(3)). In every case the applicant is a Pakistani company with at least three directors. PVARA’s processing, licensing, annual supervisory and renewal fees are to be published in the Rules (Reg 11); processing fees are non-refundable.
A sandbox participant that completes testing to PVARA’s satisfaction may apply directly for a licence and does not need a separate NOC (Reg 7(6)); participation creates no entitlement to a licence. An applicant that already holds an NOC, or has applied under the NOC Regulations, 2025, may apply for the licence directly (Reg 7(7)). The sandbox suits products that do not map cleanly onto the licence categories. It is not a shortcut for an exchange, custody or token-issuance business that fits an existing category.
Assuming a foreign licence carries over. Neither the Regulations nor PVARA’s published FAQ provide for recognition of foreign licences. A VARA, MAS or MiCA licence is relevant evidence of track record, but the application is a full assessment of the applicant’s Pakistani operations.
Filing before the Pakistani build-out is planned. The NOC does not require the company to exist yet, but the licence application must follow incorporation within the NOC’s validity period. The proposed directors and key individual, a draft Pakistani AML/CFT manual, and the custody and delivery-model information Form I asks for need to be planned from the start.
Opaque ownership. PVARA looks through to ultimate beneficial owners and conducts substantive fit-and-proper assessments. Holding structures that obscure ownership lines will be flagged.
There are three steps. First, apply to PVARA for a No-Objection Certificate (NOC) on Form I. Second, after the NOC is granted, incorporate the Pakistani company and register with the Financial Monitoring Unit. Third, within the NOC's validity period, apply for one or more licence categories with the updated Form I documents and the non-refundable processing fee. Sandbox participants who complete testing successfully may apply for a licence directly without an NOC.
Under section 70 of the Virtual Assets Act, 2026 and PVARA advisory PVARA/ADV/001/2026, persons who were providing virtual asset services on or before 5 March 2026 had to submit an NOC application by 5 September 2026 or cease operating. That date has passed. Other persons may apply for the Regulatory Sandbox or an NOC when they meet the requirements.
PVARA must decide a complete NOC application within 60 days. An NOC is valid for three months and can be extended once by up to three months. PVARA must decide a complete licence application within 90 days, extendable by up to 60 days for complex applications. An application counts as complete only when PVARA confirms in writing that it has all required information, and the time stops running while PVARA waits for further information, so actual elapsed time depends mainly on how quickly the file is completed.
No. The NOC is for a person intending to establish a company in Pakistan for the purpose of applying for a licence. The company is incorporated after the NOC is granted, and the licence application must follow incorporation within the NOC's validity period. Foreign ownership of up to 100% is permitted, but the licensee must be a company incorporated under the Companies Act, 2017 with at least three directors, a registered office in Pakistan, and at least one key individual resident in Pakistan.
Eleven: Advisory Services; Broker-Dealer Services; Custody Services; Exchange Services; Lending and Borrowing Services; Virtual Asset Derivatives Services; Virtual Asset Management and Investment Services; Virtual Asset Transfer and Settlement Services; Fiat-Referenced Token Issuance Services; Asset-Referenced Token Issuance Services; and Mining Related Virtual Asset Services. A licence covers only the categories named in it, and an applicant may apply for more than one.
Yes, if they carry on the activity in or from Pakistan. Under Regulation 3(4) of the Services Regulations, an activity may be treated as carried on in Pakistan where it targets, solicits, promotes to or onboards persons in Pakistan, including through marketing, payment rails or services in PKR. A site that is merely accessible from Pakistan is not caught if the operator does not market or solicit there, does not onboard Pakistani persons, does not support PKR rails or Pakistan-targeted channels, and takes reasonable steps to prevent onboarding. Wilfully providing an unlicensed virtual asset service is an offence punishable by imprisonment for up to five years, a fine of up to PKR 50 million, or both (Virtual Assets Act, 2026, section 54(1)).
The Regulations and PVARA's published FAQ do not provide for recognition of foreign licences, and do not make a foreign licence a condition of the NOC. A licence from another regulator is relevant evidence of track record in the business plan and fit-and-proper material, but the Pakistani application is assessed in full on its own terms.
No. A participant that completes sandbox testing to PVARA's satisfaction may apply directly for a licence under Regulation 7 and does not need a separate NOC. Participation creates no entitlement to a licence, and the applicant must still meet every applicable requirement.
The PVARA Readiness Assessment is a fixed-scope review by Esquare Legal that maps your business to the licence categories and capital floors and produces a sequenced NOC-to-licence action plan.
This page is general information, current as at 8 October 2026, and follows Esquare Legal’s PVARA licensing guide. It is not legal advice and does not create a solicitor-client or barrister-client relationship. Verify all dates and requirements against pvara.gov.pk before acting.