Licensing framework goes live after six-month legislative process

The Pakistan Virtual Assets Regulatory Authority (PVARA) has opened its licensing portal and notified the licensing regulations that bring virtual asset service providers under formal statutory supervision. The regulations, issued under the Virtual Assets Act 2026, establish 10 licence categories covering exchange, custody, broker-dealer, advisory, lending and borrowing, derivatives, discretionary asset management, transfer and settlement, token issuance, and mining-related services.

PVARA was constituted as a permanent statutory body by an act of Parliament in March 2026. The authority said it had moved from primary legislation to an operational licensing regime in less than six months, following a public consultation that ran from 11 June to 2 July 2026.

September 5 deadline carries legal consequences for non-compliance

Any person who was providing virtual asset services on or before 5 March 2026, when the Act commenced, is classed as a transitional person and must submit a no-objection certificate application by 5 September 2026. Under Section 70 of the Virtual Assets Act 2026, operating without submitting an application after that date is an offence.

PVARA said existing providers must submit their NOC applications by the deadline or cease operations. The authority targets a decision on each application within 60 calendar days of a complete submission.

Banking access replaces eight-year prohibition

Licensed providers will gain access to the formal banking system under State Bank of Pakistan Circular No 10 of 2026, issued on 14 April 2026. The circular permits regulated entities to open accounts for PVARA-licensed virtual asset service providers, including segregated client money accounts, replacing the prohibition that had been in place since 2018.

Banks remain prohibited from investing in, trading in, or holding virtual assets using their own capital or customer deposits. Their role is restricted to providing banking rails and transaction monitoring for authorised operators. Financial institutions must enforce anti-money laundering, know-your-customer and risk-profiling standards.

Two-stage application process for existing operators

The licensing process works in two stages. Transitional persons must first submit an NOC application, then after receiving preliminary approval, register with Pakistan's Financial Monitoring Unit, incorporate a local subsidiary under the Companies Act 2017, and finally submit a full licence application. Offshore exchanges with Pakistani users must establish a company in Pakistan to continue operating.

Applicants must meet minimum paid-up capital requirements set by licence category, put directors and key staff through a fit and proper test, and implement anti-money laundering systems covering customer checks, transaction monitoring and suspicious activity reporting. Cybersecurity arrangements and a business continuity plan are also required.

  • Step 1: Submit NOC application via the PVARA licensing portal with business plan and corporate documents.
  • Step 2: Upon receiving the NOC, register with the Financial Monitoring Unit's goAML portal.
  • Step 3: Incorporate a subsidiary company in Pakistan under the Companies Act 2017.
  • Step 4: Submit the full Virtual Asset Service Provider licence application once available.

Licensed firms must keep customer holdings separate from their own and cannot lend or pledge them without written consent. PVARA chairman Bilal bin Saqib said these obligations are now legal requirements rather than promises.

What the evidence does not yet establish: the specific minimum paid-up capital amounts for each licence category, the fee structure for applications, and the exact number of applications received before the deadline. While Decrypt reported that Binance and HTX already hold certificates, the timing and status of those clearances under the new regime are not fully detailed in the available sources.