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South Asia

Pakistan

From a 2018 banking ban to a full licensing law: PVARA now regulates a market the government puts at over 40 million users.

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Licences

What it takes to operate in Pakistan: 4 licences, who issues each, what it covers and who holds one.

PVARA Virtual Asset Service Provider (VASP) licence

PVARA · Virtual Assets Act, 2026; Pakistan Virtual Asset Services Regulations, 2026

Advisory, broker-dealer, custody, exchange, lending and borrowing, derivatives, asset management, transfer and settlement, token issuance and mining-related services offered in or from Pakistan.

What it takes
  • Local company under the Companies Act, 2017 with at least three directors
  • Minimum paid-up capital by category: PKR 15M advisory, 75M broker-dealer, 200M custody, 500M exchange, lending or derivatives
  • Prior NOC or successful sandbox exit, plus AML/CFT registration with the Financial Monitoring Unit
  • Segregation of client money and virtual assets, and Travel Rule data on transfers of USD 1,000 or more
  • Fit-and-proper directors with at least five years of senior experience
No public count

PVARA No Objection Certificate (NOC)

PVARA · Virtual Assets Act, 2026 (sections 19 and 70); Services Regulations, 2026 (regulation 6); earlier NOCs under the NOC Regulations 2025

Preliminary approval, not a licence to operate, that lets an applicant incorporate locally and apply for a licence within its validity; transitional firms that filed by 5 September 2026 may keep operating while it is decided.

What it takes
  • Form I application with business plan, three-year projections and disclosure of controllers and beneficial owners
  • Fit-and-proper information and affidavits for sponsors, directors and the CEO
  • Capital and liquidity attestation against the Schedule I minimums
  • Decision within 60 days of a complete application; valid for three months, extendable once by three months

Holders include

No public count

Fiat-Referenced and Asset-Referenced Token Issuance licence

PVARA · Virtual Assets Act, 2026 (sections 31 and 32); Services Regulations, 2026 (regulations 34 and 34A)

Issuing stablecoins referenced to a fiat currency, or tokens referenced to other assets, to users in or from Pakistan.

What it takes
  • Minimum paid-up capital of PKR 300 million
  • Reserve assets equal to 100% of outstanding redemption liabilities, held as a segregated reserve
  • Fiat-referenced reserves in high-quality liquid assets, with redemption at par without undue delay
  • Extra requirements for significant issuers
No public count

PVARA Regulatory Sandbox admission

PVARA · Virtual Assets Act, 2026; PVARA Incubation (Sandbox) Guidelines

Supervised live testing of an innovative virtual asset product within set scope, duration and customer limits.

What it takes
  • Test plan agreed with PVARA before admission
  • Reporting, safeguarding and disclosure duties throughout the test
  • Exit criteria to meet before applying for a full licence
No public count

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