PVARA cuts capital minimums, drops small-entrant relief

The Pakistan Virtual Assets Regulatory Authority notified the Pakistan Virtual Asset Services Regulations, 2026 — S.R.O. 1419(I)/2026 — on 21 August 2026. Comparing that 77-page notified text against the 77-page draft PVARA published for consultation on 11 June 2026 — a separate document that shares its title with the notified instrument — shows every minimum paid-up capital figure in Schedule-I fell, some by as much as 70%. The same comparison shows something the headline cuts obscure: the draft's clause letting the Authority grant a restricted licence with reduced capital is gone from the notified text.

Both documents place their Schedule-I capital table on the printed page numbered "Page 72 of 77." That page number, in both PDFs, is the anchor for every figure below.

As of 24 August 2026, no archived capture of PVARA's consultation page or draft-document URLs existed on the Wayback Machine. A re-check on 26 August 2026 could not be completed — the Wayback CDX API was rate-limiting queries at the time.

The Pakistan angle

Lower minimums sound like an easier path in. For a well-capitalised applicant, they are. But the clause that gave a smaller, customer-capped applicant a route to a reduced figure did not survive the same revision. Read together, the notified Schedule-I is friendlier to an applicant who could already clear the draft's higher bar, and offers nothing to one who couldn't.

The capital cuts, category by category

Five of Schedule-I's ten priced categories changed between the draft and the notified text. Advisory Services fell from PKR 25,000,000 to PKR 15,000,000, a 40% cut. Broker-Dealer Services fell from PKR 100,000,000 to PKR 75,000,000, a 25% cut. Exchange Services fell from PKR 1,000,000,000 to PKR 500,000,000 — halved. Fiat-Referenced Token Issuance and Asset-Referenced Token Issuance each fell from PKR 1,000,000,000 to PKR 300,000,000, a 70% cut in both cases.

Five categories did not move: Custody Services, Lending and Borrowing, Virtual Asset Derivatives, VA Management and Investment, and VA Transfer and Settlement all remain at their draft figures in the notified text. The cuts are not a uniform easing of the schedule — they land on five specific categories.

A sixth change is a new price, not a cut. Mining Related Virtual Asset Services carries no Schedule-I row in the draft at all, though the licence category itself already existed there, defined in regulation 4(1)(j) as covering mining operations that provide services to third parties involving customer virtual assets or funds. The notified Schedule-I prices it for the first time, at PKR 500,000,000. The category is not new to the notified text; being priced is.

The relief that disappeared

Immediately after the Schedule-I table, the draft carries one sentence with no equivalent anywhere in the notified text: "The Authority may, under regulation 7(5), grant a restricted licence with proportionate prudential requirements (including reduced minimum paid-up capital) subject to customer caps, product restrictions, and enhanced safeguards." The phrase "reduced minimum paid-up capital" occurs zero times in the notified regulations. The notified Schedule-I closes with a governance-conditions line and moves directly into Schedule-II, Fit and Proper Criteria — the relief clause is not relocated, only absent.

What is not true is that the underlying licence power vanished with it. Regulation 7(5) itself survives, worded as "Limited-scope Licence. The Authority may grant a limited scope Licence where necessary to advance the primary objectives of the Act," on page 10 of the notified S.R.O. 1419(I)/2026. It is still cross-referenced twice elsewhere in the same instrument: regulation 20(4) permits "a lower proportion for limited scope licenses under regulation 7(5)," and regulation 34(11) lets the Authority "grant a limited scope licence under regulation 7(5) for issuance of an FRT or ART for a limited scope." What is gone is narrower than the power itself — only the explicit tie between a limited-scope licence and a reduced capital figure has been removed from Schedule-I.

Checked again on 26 August 2026, five days after notification: PVARA has still not published a statement of reasons for any change between the consultation draft and the notified text. This piece states what changed. It does not state why, because that has not been published anywhere PVARA has made available.

What this means for Pakistani users

For a Pakistani applicant weighing whether to seek a PVARA licence, the notified Schedule-I is a mixed signal. The headline minimums are lower than they were in June 2026 — an exchange applicant now needs PKR 500,000,000 rather than PKR 1,000,000,000, and an advisory applicant needs PKR 15,000,000 rather than PKR 25,000,000. But the one provision that would have let a smaller, customer-capped applicant enter at a figure below even those reduced minimums is no longer in the text. An applicant who could not clear the draft's higher bar and was counting on the restricted-licence route has, on the current text, no lower door to use instead.

Separately, two of PVARA's own application forms still carry unset costs. The processing-fee field in both Form I, the NOC application, and Form II, the licence application, reads "PKR [x]" rather than a fixed figure — one occurrence each, on pages 61 and 70 of the notified text. Whatever an applicant's Schedule-I capital requirement now is, PVARA has not yet told them what the paperwork itself will cost.

What we're watching

PVARA's consultation page commits to publishing the themes raised during consultation and its response, as step two of its stated process. Checked again on 26 August 2026, the same day this piece was finished: that page still shows only the process description, unchanged since before notification — no feedback statement has actually been published. If one appears, it may be the first place PVARA states a reason for the Schedule-I changes rather than leaving readers to infer one — this piece does not, because the primary text alone cannot support a reason.

We are also watching whether PVARA fixes the Form I and Form II fee placeholders, and whether any Rules under regulation 11(1) are published setting fee amounts more broadly.

Sources

• Pakistan Virtual Asset Services Regulations, 2026 — S.R.O. 1419(I)/2026, PVARA, notified 21 August 2026. https://pvara.gov.pk/documents/Pakistan%20Virtual%20Asset%20Services%20Regulations,%202026%20-%20Notified%2021%20August%202026.pdf
• Draft Pakistan Virtual Asset Services Regulations, 2026 — pre-notification text published for consultation 11 June 2026. Shares its title with S.R.O. 1419(I)/2026; this is the draft, not the notified instrument. https://pvara.gov.pk/documents/Draft%20Pakistan%20Virtual%20Asset%20Services%20Regulations%202026.pdf
• Pakistan Virtual Asset Services Regulations, 2026, regulation 31 (minimum paid-up capital, page 21 of 77) and regulation 7(5) (Limited-scope Licence, page 10 of 77) — same notified instrument as above. https://pvara.gov.pk/documents/Pakistan%20Virtual%20Asset%20Services%20Regulations,%202026%20-%20Notified%2021%20August%202026.pdf