PVARA notifies crypto licensing rules with no fee set

Pakistan's Virtual Assets Regulatory Authority — PVARA, the regulator created by the Virtual Assets Act, 2026 — notified two sets of licensing regulations on 21 August 2026. Both were published in the Gazette of Pakistan Extraordinary, the government's official record, which is where an instrument like this takes legal effect. They are numbered S.R.O. 1419(I)/2026, the Pakistan Virtual Asset Services Regulations, 2026 as notified, at 77 pages, and S.R.O. 1420(I)/2026, the Activity Specific Regulations, 2026, at 101 pages. An S.R.O. is a statutory regulatory order — the number the government assigns to a notified instrument. Both were made under section 68 of the Act. S.R.O. 1419 states that it comes into force on the date of its notification in the Gazette, and the notification specifies no later date, so it is in force from 21 August 2026.

These rules are no longer in consultation and no longer in draft. They are notified and operative. They are not, however, complete: no fee amount is set anywhere in the 178 pages, the Rules that regulation 11(1) defers every fee to have not been published, and the risk disclosures that section 43(2) of the Act requires for marketing materials are still unprescribed.

Who has to act, and by when

The people this reaches first are companies that were already providing virtual asset services in Pakistan when the Act commenced. Regulation 5A(1) of S.R.O. 1419 (p8) requires any such person to apply to PVARA within six months of commencement, or cease providing the services.

The awkward part is what they must apply for. Section 70(1) of the Act says apply for a licence. Regulation 5A(1) says the same, but adds the words "and Regulation 6 of these regulations" — and Regulation 6 is the No Objection Certificate regulation, the preliminary approval stage that comes before incorporation and before a licence. Regulation 5A(2) then makes the safe harbour, which lets an applicant keep operating while its application is decided, conditional on "a complete application that satisfies the requirements of the No Objection Certificate application referred herein". PVARA's own licensing page resolves it in one direction: "Transitional Persons — operating since March 5, 2026 or before, must submit an NOC application by September 5, 2026, or cease operations, as required under Section 70 of the Virtual Assets Act, 2026." That is PVARA's published position as at 24 August 2026. The page carries no date of its own, and it has not always said this: when the Internet Archive captured it on 22 July 2026 the page contained no reference to transitional persons, to section 70, or to any September date. PVARA published that instruction some time in the month between. No capture exists between 22 July and 24 August 2026, so it cannot be tied to the notification on 21 August. The Act itself says licence; the regulation routes it through the NOC; PVARA says NOC.

Those words are new. In the draft Regulations PVARA published for consultation on 11 June 2026 — a separate document that shares its title with the notified instrument — regulation 5A(1) ended at "in accordance with section 70(1) of the Act", and the safe harbour in 5A(2) referred to "the application prescribed by the Authority" rather than to a No Objection Certificate application. The marketing pre-approval proviso does not appear in the draft at all, and neither does regulation 7(7), which lets a company that already holds an NOC apply directly for a licence. The routing of the section 70 deadline through the NOC regulation was written in between the draft of 11 June 2026 and the text notified on 21 August 2026.

The date carries the same split. The Act does not name a commencement date — it says it comes into force at once — and it received assent on 4 March 2026 and was published in the Gazette on 5 March 2026. Six months from those two dates is 4 or 5 September 2026, and neither notified S.R.O. resolves which: both were searched for "4 March", "5 March" and "March 2026" and contain none of them. PVARA has picked the Gazette date on its website. The statute has not. The Act's text was independently re-extracted from the National Assembly's own published PDF on 25 August 2026 — a second source, not CryptoPakistan's OCR copy — and returns the same two dates verbatim: assent "on the 4th March, 2026" and Gazette publication "MARCH 05, 2026". The wording is not in dispute; only which of the two dates the six-month clock runs from is.

One more line in regulation 5A(2) matters to anyone who keeps trading while waiting: an applicant that intends to conduct any marketing activity before its application is determined must first obtain PVARA's approval.

The fee that has no amount

Regulation 11 of S.R.O. 1419 (p13) requires an applicant to pay "the processing fees, licensing fees, annual supervisory fees, renewal fees, and any other charges as published in the Rules". The Rules are a separate instrument. The application form the regulations prescribe, Form I, carries the gap openly: on p61 it asks for "evidence of payment of the prescribed processing fee in the amount of PKR [x]". The same gap sits in the form that comes after it: Form II (p70), the application for the licence itself, repeats the wording without change. Neither the form a Transitional Person files by 4 or 5 September 2026 nor the one that follows it states an amount. No PKR amount stated anywhere in either instrument is a fee. Twelve days from the date PVARA has published, there is no published amount to pay. Checked again on 25 August 2026 against PVARA's /regulations, /licensing and /news pages: none names or links a fee-setting Rules instrument, and none of the three contains the word "fee". There is still nowhere to look.

What the licence itself costs to hold

Schedule-I of S.R.O. 1419 (p72) sets minimum paid-up capital across its eleven numbered rows: Advisory Services PKR 15 million; Broker-Dealer Services PKR 75 million; Custody Services, Virtual Asset Management and Investment Services, and Virtual Asset Transfer and Settlement Services PKR 200 million each; Fiat-Referenced Token Issuance and Asset-Referenced Token Issuance PKR 300 million each; and Exchange Services, Lending and Borrowing Services, Virtual Asset Derivatives Services and Mining Related Virtual Asset Services PKR 500 million each.

Those figures are lower than the ones PVARA consulted on. Schedule-I of the draft Regulations (p72) — the pre-notification text, not S.R.O. 1419(I)/2026 — set Exchange Services at PKR 1 billion, both token issuance categories at PKR 1 billion, Advisory at PKR 25 million and Broker-Dealer at PKR 100 million. As notified, they are PKR 500 million, PKR 300 million each, PKR 15 million and PKR 75 million. Of the ten categories the draft priced, five were cut and five were left where they were. Mining Related Virtual Asset Services was already a licence category in the draft — at draft regulation 4(1)(j), with its own activity handbook — but carried no Schedule-I row and no capital figure; the notified Schedule-I prices it at PKR 500 million.

One requirement moved the other way. Draft Schedule-I (p73) carried an express power to grant a restricted licence with "proportionate prudential requirements (including reduced minimum paid-up capital)". That sentence does not appear in the notified Schedule-I. Notified regulation 7(5) still allows a limited-scope licence specifying scope, duration, conditions and exit criteria, but without the reduced-capital wording. What we cannot tell you is why any of this changed: PVARA committed to publishing its reasoning and has not.

Every category requires a company incorporated under the Companies Act, 2017 with at least three directors, and directors with at least five years of senior-management experience in the relevant category or a related field. Regulation 10(4) (p12) requires a registered office in Pakistan and one key individual resident in Pakistan with operational and decision-making authority, accountable to PVARA. Regulation 32(1) (p21) requires a licensee to hold net liquid assets equal to 1.2 times its adjusted monthly operating expenses at all times.

The regulations also reach offshore. Regulation 3(4) (p6) treats an activity as carried on "in Pakistan" where it targets, solicits, promotes to or onboards persons in Pakistan, including through a website or mobile app, payment rails, or services in PKR. Regulation 3(5) provides safe harbours: mere accessibility of a website or app in Pakistan is not enough where the operator does not market or onboard here, does not support PKR rails or Pakistan-targeted channels, and takes reasonable steps to prevent onboarding. Those four conditions are not the end of it. The same sub-regulation continues: "The Authority may nevertheless determine otherwise only where it has reasonable grounds, recorded in writing, that the Person has in substance targeted Persons in Pakistan or has a real and substantial connection with Pakistan." An offshore platform that satisfies all four conditions can still be brought inside the perimeter, on a determination PVARA must record and reason in writing.

On mining, S.R.O. 1420 regulation 2(3) (p88) states that Mining Services "do not include purely proprietary mining falling outside the licensing perimeter" — mining for your own account is outside. Regulation 3(5) of S.R.O. 1420 (p89) also reserves PVARA a power to require a person conducting "large-scale proprietary mining" to register or make declarations even where no licence is required, and "large-scale" is not defined in either instrument.

What happens next

The nearest date is 4 or 5 September 2026 for the transitional application — PVARA's page says 5 September, the statute does not settle it.

There is a second clock, and it comes from the text of the instruments rather than from anything PVARA has said. The PVARA No Objection Certificate Regulations, at clauses 15.3(c) and 17.1(a)(iv), require an NOC holder to submit its licensing application "within three months of promulgation of VASP licensing regulations". Promulgation was 21 August 2026. S.R.O. 1419 contains no repeal provision at all, and its only transitional reference, regulation 7(7) (p10), permits an existing NOC holder to apply directly for a licence without setting a date. Read on their face, those clauses put an existing NOC holder's licensing application due on or about 21 November 2026. PVARA has published nothing adopting that date, and the NOC Regulations are drafted against the Virtual Assets Ordinance, 2025, which lapsed and is saved by section 74 of the Act. Checked again on 25 August 2026, four days after promulgation: PVARA's /news and /licensing pages contain no mention of "three months", "November" or the NOC Regulations at all. Nothing has changed since 21 August.

Once an application is in, S.R.O. 1419 sets the decision windows: an NOC decided within 60 days (regulation 6(3)) and valid for three months, extendable once by three (regulation 6(5)); a licence decided within 90 days, extendable by 60 (regulation 7(3) and 7(4)).

The regulations that produced all this went through a public consultation, reference PVARA/CON/001/2026, which opened on 11 June 2026 and closed on 2 July 2026 and is marked Closed on PVARA's site. That page also sets out what PVARA undertakes to do next: step 02 of its published process is a "Feedback Statement" in which "PVARA publishes the main themes raised, the changes made to the draft, and its reasoning where proposals were not adopted". No feedback statement for this consultation appeared on PVARA's consultation, consultations, news, regulations or virtual-asset-announcements pages as at 24 August 2026 — 53 days after the consultation closed, and three days after the regulations were notified.

Two things PVARA has not done. Regulation 9(6) (p11) requires it to "maintain and publish an up-to-date public register of Licensees". As at 24 August 2026 no such register was found at pvara.gov.pk, and PVARA has announced no licence grant. And section 43(2) of the Act, which requires marketing materials to carry risk disclosures in a form and manner prescribed by PVARA, is still unprescribed after 178 pages: the only reference in either instrument, regulation 28(4)(a) (p19–20), points back to what is "prescribed by the Authority" without prescribing it. No timetable has been published for the Rules, for a fee schedule, or for the section 43(2) disclosures.

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
• Pakistan Virtual Asset Services Activity Specific Regulations, 2026 — S.R.O. 1420(I)/2026, PVARA, notified 21 August 2026. https://pvara.gov.pk/documents/Pakistan%20Virtual%20Asset%20Services%20Activity%20Specific%20Regulations,%202026%20-%20Notified%2021%20August%202026.pdf
• Virtual Assets Act, 2026 (Act No. XIII of 2026), National Assembly of Pakistan; assent 4 March 2026, gazette 5 March 2026. https://na.gov.pk/uploads/documents/69aae92ebf61c_955.pdf
• PVARA No Objection Certificate Regulations, PVARA. https://pvara.gov.pk/documents/PVARA%20NO%20OBJECTION%20CERTIFICATE%20REGULATIONS.pdf
• PVARA licensing page as captured by the Internet Archive, 22 July 2026. https://web.archive.org/web/20260722144921/https://pvara.gov.pk/licensing
• PVARA licensing page, content as fetched 24 August 2026. https://pvara.gov.pk/licensing
• PVARA public consultation PVARA/CON/001/2026, content as fetched 24 August 2026. https://pvara.gov.pk/consultations/virtual-asset-services-regulations
• 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. https://pvara.gov.pk/documents/Draft%20Pakistan%20Virtual%20Asset%20Services%20Regulations%202026.pdf
• Draft PVARA Virtual Asset Services Activity-Specific Handbooks, 2026 — published for consultation 11 June 2026. https://pvara.gov.pk/documents/PVARA%20Virtual%20Asset%20Services%20Activity-Specific%20Handbooks%202026.pdf