Frequently Asked
PVARA Licensing Questions
Answered from the Virtual Assets Act 2026, the PVARA No Objection Certificate Regulations 2025 and the Sandbox Guidelines 2026 — with section references so every answer can be checked.
What is PVARA and do I need a licence to operate crypto in Pakistan?
PVARA is the Pakistan Virtual Assets Regulatory Authority, established under Section 6 of the Virtual Assets Act 2026, which succeeded the Virtual Assets Ordinance 2025. Section 50(1) of that Act requires anyone carrying on Virtual Asset Services by way of business in or from Pakistan to be a company incorporated in Pakistan and to hold a valid PVARA licence — both conditions, cumulatively. Under Section 54(1), wilfully providing an unlicensed Virtual Asset Service carries imprisonment up to five years, a fine up to PKR 50 million (~$179,000), or both.
Can a crypto exchange start operating in Pakistan on a PVARA NOC before the full licence?
Partly, and this is the fastest legal route in today. Under Regulation 2.3 and Regulation 17.1(a)(iii) of the PVARA No Objection Certificate Regulations 2025, an NOC holder that has completed FMU goAML registration may provide four designated AML-Registered Services — Exchange, Broker-Dealer, Custody, and Virtual Asset Derivative Services — before obtaining a full licence, subject to conditions imposed by the Authority and until the licence application is finally determined. The other six Schedule I categories require a full licence first. Regulation 19.1(e) allows PVARA to revoke the NOC if the holder fails to progress toward full licensing.
How long does the PVARA NOC application take?
Regulation 17.1 of the PVARA No Objection Certificate Regulations 2025 requires PVARA to issue or refuse an NOC within a period not exceeding 60 calendar days following assessment, and a refusal must come with written reasons. That clock starts only once the submission is complete, so documentation quality is the main variable. Regulatory Sandbox applicants run on a separate track with a 60 working-day evaluation from the conclusion of initial screening.
What capital is required for a VASP licence in Pakistan?
It depends on the licence category. The Draft Pakistan Virtual Asset Services Regulations 2026 set minimum paid-up capital from PKR 25 million (~$89,000) for Advisory Services up to PKR 1 billion (~$3.57 million) for Exchange Services and token issuance. These figures are in draft and must be confirmed at filing. Importantly, Sections 22(a) and 25 of the Virtual Assets Act 2026 attach the capital requirement to a Licensee, so it does not apply at the NOC stage. Paid-up capital is share capital held in the company's own name, not a fee paid to PVARA, and Section 25(4) allows risk-based exemptions for limited-scope or low-risk licensees.
Does an NOC holder need a registered office and local staff in Pakistan?
Not at the NOC stage. Section 20(6) of the Virtual Assets Act 2026 requires every Licensee to maintain a registered office in Pakistan and ensure at least one Key Individual ordinarily resident in Pakistan is vested with operational and decision-making authority. That obligation is drafted against a Licensee, so it attaches on full licensing, not on grant of the No Objection Certificate. Section 19(1) does separately require the NOC to be obtained before the process of local incorporation begins.
What tax reporting applies to a VASP in Pakistan?
Section 66 of the Virtual Assets Act 2026 provides that every licensed Virtual Asset Service Provider shall comply with the obligations imposed under the income tax statute it names as the "Income Tax Act, 2001", and any Rules or Regulations issued by the Federal Board of Revenue. Those FBR rules have not yet been notified, so there is currently no prescribed machine-readable VASP reporting format in Pakistan. Any adviser quoting a specific Pakistani reporting section number for virtual assets today is quoting something that has not been issued.
What is the difference between the PVARA NOC path and the Regulatory Sandbox?
The NOC and full licence path suits established exchanges with conventional products, and uniquely allows four AML-Registered Services to run before full licensing. The Regulatory Sandbox, operated under Section 35 of the Virtual Assets Act 2026 and the PVARA Sandbox Guidelines 2026, suits Web3 innovators testing novel products such as stablecoins, tokenisation, DeFi or remittance, and can produce a No-Action Letter. Applications are accepted year-round via Form I with an Annexure-A self-assessment. The Sandbox is the wrong door if live testing is not genuinely needed to answer a regulatory question.
Which crypto exchanges have received PVARA approval?
Binance and HTX were reported in media to be among the first global exchanges to receive PVARA No Objection Certificates in December 2025. PVARA does not maintain a public NOC holders list, so that reporting is unverified. Section 21(4) of the Virtual Assets Act 2026 does require PVARA to maintain and publish a register of full Licensees showing name, licence number, permitted services and current regulatory status, which will be the authoritative source once populated.
Are existing crypto businesses in Pakistan grandfathered under the Act?
No, but there is a transition window. Section 70 of the Virtual Assets Act 2026 gives any person providing Virtual Asset Services immediately before commencement of the Act six months to apply for a licence or cease those services. A person who files a complete application within that window may continue providing existing services, provided they comply with any interim directives issued by PVARA and continue to adhere to core obligations on customer asset protection and AML, CFT and CPF. The concession covers existing services only; it is not permission to launch new ones.