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What the IMF's tokenisation report asks of countries like Pakistan

The IMF's latest financial stability report devotes a chapter to tokenisation and names four things that hold it back. Pakistan, which wants to tokenise state assets, has started on two. Its own law leaves open who would regulate a tokenised bond.

The brass dial and steel bolts of an old bank vault door.
Photo by David Trinks on Unsplash

Key takeaways

  • The IMF's October Global Financial Stability Report puts publicly tokenised real-world assets at about $65 billion and says systemic risks from tokenisation are, for now, limited.
  • It names four constraints on growth: legal certainty, regulatory clarity, interoperability and settlement assets.
  • For emerging markets, it says tokenisation can skip old infrastructure but not "the broader process of capital market development itself".
  • Pakistan's Virtual Assets Act gives PVARA the lead on tokenising real-world assets, but also excludes securities regulated by the State Bank or the SECP. Which regulator would oversee a tokenised government bond is not settled in the text.

The International Monetary Fund's Global Financial Stability Report, published on 13 October, gives its third chapter to tokenisation: putting assets such as bonds, fund shares or property on shared digital ledgers.

The chapter does not mention Pakistan. But Pakistan has been one of the louder voices on tokenisation this year. Its finance ministry signed an agreement with Binance in December 2025 to explore tokenising "up to $2 billion" of sovereign bonds, treasury bills and commodity reserves. PVARA's chairman said this month that its sandbox is testing gold and property. We set out those plans, and PVARA's issuance rules, in our tokenisation explainer.

This piece takes the IMF's framework and checks Pakistan's rules against it.

What the IMF found

  • The market is growing but small. Public tokenised real-world assets reached about $65 billion by July 2026, excluding repos, private markets and stablecoins. Private platforms hold at least $8 billion more in tokenised bonds. Tokenised repo trades average $303 billion a day.
  • Benefits are showing up. Tokenised equity markets trade around the clock and allow fractional ownership. Because they are small, they are also "less liquid, more volatile, and more fragmented" than traditional markets.
  • Risks are limited for now. The question, the IMF says, is whether infrastructure, legal foundations and risk controls are adequate if tokenisation spreads.

The four constraints, and where Pakistan stands

The IMF wants laws that make clear who owns a token, what it is a claim on, and what happens in insolvency.

Pakistan's Virtual Assets Act, 2026, in the version passed by the National Assembly and posted by PVARA, goes some way:

  • Section 5(3) says regulation of "tokenization of real-world assets" vests "primarily" in PVARA, "in coordination with other relevant regulators where applicable".
  • The Act defines an asset-referenced token as a virtual asset that represents ownership rights, claims or income in underlying assets. Section 32(2) says such a token must be fully backed and may reference commodities, real estate or securities. A gold-backed token fits this category.
  • Section 32(1) lists "prioritized holder protections in insolvency" among an issuer's requirements.

On bonds, the text points two ways. Section 2(2)(b) says the Act does not apply to securities and other instruments "that fall within the regulatory jurisdiction of the State Bank of Pakistan or the Securities and Exchange Commission of Pakistan". Yet the Act's definition of a virtual asset excludes securities regulated under other laws "except where represented, issued, or transferred using distributed ledger technology". Section 9(1)(f) lets PVARA classify assets by substance, after consulting the State Bank or the SECP where an asset falls within their remit.

So a tokenised treasury bill could be argued to fall under PVARA, the State Bank or the SECP. The text of the Act leaves that open.

2. Regulatory clarity

The IMF recommends "same activity, same risk, same regulatory outcome", and sandboxes to inform rule-writing. It says sandboxes "should have clear objectives, realistic timelines, and a transparent process for translating lessons from testing into regulatory or legislative reforms".

PVARA has the tools. Section 35 of the Act provides for a sandbox, and section 9 requires PVARA to run sandboxes "in a transparent and accountable manner". Its licensing page sets out a sandbox-to-licence track. But it has not named the firms in its sandbox or published what they are testing, and its licensing page named no licensee when we read it on 26 October.

3. Interoperability

The IMF warns that tokenised markets are split across private, closed networks, and calls for interoperability between them. Pakistan's rules, as we have read them, focus on issuers, reserves and custody rather than on how networks connect. With no token yet issued under them, the question has not been tested.

4. Settlement assets

The IMF says tokenised securities should be settled "in safe and widely accepted forms of money". Without central bank money on the ledger, it warns, private options such as tokenised deposits or stablecoins could fill the gap and bring their issuers' risks with them.

In Pakistan, both routes are closed for now. PVARA's rules allow licensed issuers of rupee or dollar tokens, but no issuer is licensed. The State Bank's April circular lets banks serve only PVARA-licensed firms, so tokenised deposits for crypto settlement are not on offer either.

What the IMF says about emerging markets

The chapter has a direct message for emerging economies in general. It does not name Pakistan:

  • Tokenisation "may allow some emerging market and developing economies to 'leapfrog' legacy market infrastructure but not the broader process of capital market development itself."
  • Building the infrastructure, legal frameworks and supervisory skills has high fixed costs. "In low-turnover markets, whether the potential gains will outweigh the costs remains uncertain."
  • Authorities should build a broad investor base, benchmark pricing and secondary-market liquidity alongside the technology. "Otherwise, tokenization may add operational, cyber, and governance risks to shallow markets."

What this means for Pakistani users

  • No tokenised asset is on sale under Pakistan's rules yet. PVARA has licensed no issuer. Anyone selling a "PVARA-approved" bond, gold or property token today is making a claim no licence supports.
  • A token is only as good as the law behind it. The IMF's first constraint is legal certainty: what you own and what happens if the issuer fails. Pakistan's Act answers some of that for asset-backed tokens, but not yet for tokenised government debt.
  • Settlement matters to you too. If you cannot move rupees in and out through a bank, you depend on whatever private settlement the seller offers.

This is reporting on published documents, not investment or legal advice.

What we're watching

  • Whether PVARA, the State Bank or the SECP publishes guidance on who regulates tokenised government securities.
  • Whether PVARA names its sandbox participants and publishes what they are testing.
  • Any progress on the Binance agreement or the World Bank's tokenised bond and sukuk talks.

Sources

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