PVARA's crypto licences, and the capital each one needs
Pakistan's crypto licensing rules are not a draft. They took effect on 21 August and set a minimum capital for each kind of licence, from Rs15 million for advice to Rs500 million to run an exchange.
Key takeaways
- PVARA's Virtual Asset Services Regulations took effect when they were notified on 21 August 2026. They are not open for consultation.
- The Act lists 10 kinds of crypto service. The regulations split token issuance in two and set capital for 11 categories, from Rs15 million to Rs500 million.
- Exchanges, lending, derivatives and mining services for third parties each need Rs500 million.
- PVARA must decide a complete licence application within 90 days, which it can extend by 60.
In force, not in draft
Some reporting in early October described PVARA's licensing framework as draft regulations open to public comment. That is out of date. The Pakistan Virtual Asset Services Regulations, 2026 were notified in the Gazette as S.R.O. 1419(I)/2026 on 21 August 2026. A second instrument, the Activity Specific Regulations (S.R.O. 1420(I)/2026), was notified the same day and sets conduct rules for each kind of business.
The main regulations say they take effect on the date of their notification in the Gazette. PVARA's own legal framework page lists them as notified and in force, and says the 2025 No Objection Certificate rules applied only until 21 August. It lists no open consultation.
Ten services, eleven capital bars
Regulation 4 says PVARA issues licences in the categories set by Schedule I of the Virtual Assets Act, and a company can apply for more than one. The Act's schedule lists ten services. The regulations' own Schedule I sets a minimum paid-up capital for each, and splits one of them, token issuance, into fiat-referenced and asset-referenced tokens. That makes eleven rows:
| Licence category | Minimum paid-up capital |
|---|---|
| Advisory Services | Rs15 million |
| Broker-Dealer Services | Rs75 million |
| Custody Services | Rs200 million |
| Exchange Services | Rs500 million |
| Lending and Borrowing Services | Rs500 million |
| Virtual Asset Derivatives Services | Rs500 million |
| Virtual Asset Management and Investment Services | Rs200 million |
| Virtual Asset Transfer and Settlement Services | Rs200 million |
| Fiat-Referenced Token Issuance | Rs300 million |
| Asset-Referenced Token Issuance | Rs300 million |
| Mining Related Virtual Asset Services | Rs500 million |
For the first ten rows, Schedule I requires a company incorporated under the Companies Act, 2017, with at least three directors; that cell is left blank for mining. Regulation 31 says the minimum must be held "at all times", not just on the day of application. PVARA can also demand more capital than the minimum for a riskier business.
The mining category covers mining that provides services to third parties with customer assets or funds. The Act says "pure mining for own account is excluded". We explained that line in our mining guide.
How long it takes
A foreign firm that wants to set up a Pakistani company first applies for a No Objection Certificate. Under regulation 6, PVARA has 60 days to grant or refuse a complete application. A certificate "does not constitute a Licence" to run any crypto service. It lasts three months and can be extended once, by up to three more.
Within that window, the new company applies for the licence itself. Under regulation 7, PVARA must decide a complete application within 90 days, extendable by 60 for a complex case. The clock stops whenever PVARA asks for more information, so these are not guaranteed dates.
Fees are not in the regulations. Regulation 11 says processing, licensing and annual supervisory fees will be "as published in the Rules", and processing fees are non-refundable.
What this means for Pakistani users
- No one is licensed yet. As of our tracker's last check on 2 October, PVARA had licensed no company in any category. A platform's claim to be "registered" or "approved" in Pakistan should name a category and a licence, and you can check it against PVARA's public record.
- The capital bar filters out small local operators. A P2P desk or Telegram group cannot meet Rs200 million to Rs500 million. Most of the services Pakistanis use today will be either large licensed firms or unlicensed ones.
- Different services need different licences. An exchange licence does not cover lending, derivatives or issuing a stablecoin. A firm offering several of these needs each category.
- Advice is regulated too. Advisory Services is its own category, with a Rs15 million bar. The activity rules separate a "personalized recommendation" made to a particular client from general market commentary, research and education.
What we're watching
- PVARA's fee Rules, which the regulations refer to but which have not been published.
- The first licence granted in any category, and which one it is.
- The Binance and HTX licence applications, which fall due around 21 November.
Sources
- PVARA, S.R.O. 1419(I)/2026, Pakistan Virtual Asset Services Regulations 2026, Gazette of Pakistan, 21 August 2026: regulations 1, 4, 6, 7, 11 and 31, and Schedule I.
- PVARA, S.R.O. 1420(I)/2026, Pakistan Virtual Asset Services Activity Specific Regulations 2026, 21 August 2026.
- Virtual Assets Act, 2026, Schedule I (Virtual Asset Services), as published by PVARA.
- PVARA, Legal Framework page, accessed 7 October 2026.
- CryptoPakistan, PVARA licence tracker, checked 2 October 2026.
