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Binance and HTX's PVARA Licence Deadline Falls Around 21 November

PVARA's own 2025 rules give Binance and HTX until about 21 November to seek a full licence. The regulator hasn't said so, and a miss need not be public.

Ammar Khan

Ammar Khan

5 min read
Binance and HTX's PVARA Licence Deadline Falls Around 21 November
Photo by Ali Khokhar / Unsplash

Key takeaways

  • The 2025 NOC Regulations give NOC holders three months from the licensing regulations, notified 21 August 2026, to apply for a licence.
  • That puts Binance and HTX, reported as NOC holders since December 2025, due around 21 November 2026.
  • PVARA has not stated the date. Its own website describes the 2025 Regulations as applicable only until the new rules arrived.
  • A missed date triggers a written notice and at least 30 business days to respond, not an automatic loss of the NOC.

Binance and HTX, two of the exchanges Pakistanis actually use to move between rupees and USDT, have a licence deadline that nobody has announced. It sits in the Pakistan Virtual Assets Regulatory Authority's No Objection Certificate Regulations 2025 (PVARA/REG/AML-REG/2025-1). Clause 15.3(c) requires a firm granted a no-objection certificate (NOC) to "submit the licensing application, in the form prescribed by the Authority, within three months of the issuance of the VASP licensing regulations." Clause 17.1(a)(iv) repeats the condition as a term of the grant itself.

For almost nine months that clause had nothing to count from. It does now. PVARA notified the Pakistan Virtual Asset Services Regulations, 2026, S.R.O. 1419(I)/2026, on 21 August 2026. They took effect the same day: regulation 1 brings them into force on notification, and the text sets no later date. Three months on is 21 November 2026, a Saturday.

Arab News reported on 12 December 2025 that PVARA had granted NOCs to Binance and HTX. According to that report, PVARA said the certificates did not amount to a "full operating license", and that both exchanges could prepare and submit full licence applications once licensing regulations were promulgated. PVARA's own news page links to the article under a different headline rather than carrying its own account of the grants, so the NOCs rest on press reporting that the regulator has endorsed by linking to it.

Why the date probably binds

The 2026 Regulations explicitly carry 2025 NOC holders forward. Regulation 7(7) says that where an NOC under the 2025 Regulations "has been granted, the applicant may directly apply for a License under regulation 7". Regulation 7(1) then requires that application to be made "within the validity period of an NOC".

The 2025 Regulations give an NOC no validity period of their own. There is no expiry and no lapse clause. The three-month window in clause 15.3(c) is the only time limit they set, so it is what fills that gap for a December 2025 NOC. The alternative doesn't work. The new rules' own NOC lifespan, three months plus one three-month extension under regulation 6(5), would have run out in June 2026, two months before there were any licensing regulations to apply under.

Regulation 5A(4) keeps approvals and permissions granted under the earlier Virtual Assets Ordinance "in full force and effect as if issued under the corresponding powers of the Act". That is the provision the grants survive under.

Why it is not settled

That saving comes with a condition. It applies only "to the extent not inconsistent with the Act or these Regulations, … until amended, replaced, or revoked by the Authority".

PVARA's regulations page also lists the 2025 instrument as "NOC Regulations-2025 (Applicable until the promulgation of services and activity regulations)". The line beneath it says all NOC applicants "should submit NOC application under Pakistan Virtual Asset Services Regulations". Read in context, that caption is about where new applications go, not about conditions already attached to NOCs granted in 2025. A clause written to start running on the day the new rules arrived cannot sensibly have lapsed on that same day. But PVARA has not said which reading it takes, so 21 November is our reading of its rules, not a date the regulator has published.

We also checked the companion instrument notified the same day, the Activity Specific Regulations (S.R.O. 1420(I)/2026). A search of its text finds no reference to NOCs or to the 2025 Regulations.

What happens if the date passes

Nothing happens automatically. Under regulation 6(7), where a firm incorporated under an NOC does not apply for a licence within the applicable period, PVARA "shall give the Person written notice and not less than thirty Business Days" to do one of three things:

  • submit the application;
  • ask for an extension for reasonable cause; or
  • confirm that it will not carry on a virtual asset service.

Only after that can PVARA refer the matter to the SECP, under regulation 6(8).

The 2025 Regulations point the same way. Clause 18(f) obliges an NOC holder to "apply for and progress diligently toward a full VASP License within the time period required by the Authority". Clause 19.1 lists failure to do so as a ground on which PVARA may revoke an NOC, with revocation "applied proportionately".

None of that has to be made public. A notice, an extension or a filing could all happen without an announcement.

What this means for Pakistani users

The obligation falls on the exchanges, not on their customers. What matters to users is whether they will be able to see the outcome, and at the moment they won't. Regulation 9(6) requires PVARA to "maintain and publish an up-to-date public register of Licensees". As of 14 September 2026 no register appears on pvara.gov.pk, and the newest item on PVARA's news page is still the December 2025 NOC report.

An NOC is also not a licence. Clause 2.2 of the 2025 Regulations says an NOC is approval for the firm's AML registration on the goAML portal, and permission to incorporate a local company. Neither exchange has publicly confirmed completing either step. We found no public statement from Binance or HTX on a licence application since 21 August.

For anyone holding balances on either platform, including funds locked in P2P escrow, the practical point is simple. Until a licence appears on a public register, a claim that either exchange is "PVARA licensed" is not one you can check. Our licence tracker will record the first entry when there is one.

What we're watching

  • Whether Binance or HTX announces a licence application before 21 November, and whether PVARA acknowledges one.
  • Whether PVARA publishes the register required by regulation 9(6). A first licence would be the first entry on it.
  • Whether PVARA clarifies how the 2025 Regulations apply to NOCs already granted, which would confirm or remove the November date.
  • The first NOC decisions under the new rules, due from early November for applications filed complete by the 5 September transitional deadline, which passed without a word from PVARA's portal.

Sources

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