Virtual Assets & Crypto
PVARA licensing for crypto exchanges, custodians and wallet providers in Pakistan — from No Objection Certificate through to a full VASP licence under the Virtual Assets Act, 2026.
Virtual Assets & Crypto overview
Pakistan moved from having no dedicated crypto regulator to a full statutory licensing regime in under a year. The Pakistan Virtual Assets Regulatory Authority was created by presidential ordinance in July 2025, began accepting licence applications that September, and was placed on permanent statutory footing when Parliament passed the Virtual Assets Act, 2026. Every exchange, custodian, wallet provider, broker-dealer, token issuer, or asset manager offering virtual asset services in Pakistan now needs a PVARA licence to operate lawfully — and the penalties for skipping that step are real: up to PKR 50 million and five years’ imprisonment for operating unlicensed, with a separate penalty for unauthorised promotion of virtual assets. KBL & Associates advises applicants through the licensing process and the AML/CFT compliance framework that comes with holding a licence.
SECP Incorporation & Structuring
Entity structure and shareholding set up to satisfy PVARA’s fitness and propriety review, which for global applicants also checks for existing recognition in a major jurisdiction.
PVARA Licensing (NOC & VASP Licence)
Applying for the No Objection Certificate and the full Virtual Asset Service Provider licence through PVARA’s application portal.
AML/CFT & Banking Access
Building the KYC, transaction-monitoring and reporting framework PVARA requires, and structuring the banking relationship now that SBP permits banks to service licensed VASPs.
What counts as a Virtual Asset Service Provider
The Virtual Assets Act, 2026 defines VASPs broadly — it isn’t limited to exchanges.
Exchanges & Trading Platforms
Platforms facilitating the buying, selling or trading of virtual assets, including crypto-to-crypto and crypto-to-fiat exchanges.
Custodians & Wallet Providers
Any entity holding, safeguarding or administering virtual assets or the private keys that control them on behalf of clients.
Token Issuers, Brokers, Lenders & Asset Managers
Also covered: entities issuing tokens, broker-dealer operations, virtual asset lending and derivatives, and asset management or mining-related services offered to the Pakistani market.
The PVARA licensing procedure
The path from an unlicensed operation, or a new market entrant, to a fully licensed VASP.
Incorporate with SECP
Private Limited Company under the Companies Act, 2017, with a shareholding and governance structure that will hold up under PVARA’s fitness and propriety review.
Establish existing regulatory standing (for global applicants)
PVARA has required that licence applicants already hold recognition from a major jurisdiction such as the US, EU or Singapore — a genuinely new market entrant with no track record elsewhere faces a materially harder path.
Apply for a No Objection Certificate
File through PVARA’s licensing portal for an NOC, the first-stage authorisation that allows preparation for full licensing to proceed. Firms that were already operating in Pakistan before March 5, 2025 were required to file for an NOC by September 5, 2025 or suspend operations.
Build the AML/CFT compliance framework
Customer identity verification (KYC), ongoing transaction monitoring, recordkeeping, and suspicious-activity reporting aligned to FATF standards — PVARA requires this framework to be demonstrable, not just written policy.
Regulatory sandbox (optional route)
Entities wanting to test a product under supervision before full licensing can apply to PVARA’s Regulatory Sandbox rather than going straight to a full application.
Apply for the full VASP licence
Submit the complete licence application covering ownership, security architecture, custody arrangements, and operational standards for review by PVARA.
Structure the banking relationship
Now that SBP permits banks to open accounts for licensed VASPs, including segregated client-money accounts, this step is negotiated directly with an SBP-regulated bank once the licence is in hand.
Where this is heading
This framework is still being built out in real time. PVARA has already issued preliminary NOCs to major global exchanges including Binance and HTX, and is working with the State Bank of Pakistan to develop the banking infrastructure the sector needs. The Virtual Assets Act, 2026 also gives PVARA power to designate special virtual asset zones to attract blockchain businesses, though none have been named yet. Given how quickly this regulatory picture is moving, KBL & Associates is building this practice specifically to track it as new rules, fee schedules and guidance are issued.
Governing law & regulators
The statutes and regulatory bodies that actually govern virtual assets in Pakistan.
Statutory framework establishing PVARA and its powers to licence, supervise, suspend and revoke authorisation for virtual asset service providers.
pvara.gov.pk →PVARA’s application portal and licensing procedure for exchanges, custodians, wallet operators and token issuers.
pvara.gov.pk/licensing →Base incorporation statute; a VASP is a company incorporated under this Act before it is licensed by PVARA.
secp.gov.pk →Common questions, answered directly
Virtual assets are regulated, not banned. Since 2025, the Pakistan Virtual Assets Regulatory Authority (PVARA) licences exchanges, custodians, wallet providers and other virtual asset service providers under the Virtual Assets Act, 2026.
The process starts with SECP incorporation, followed by an application for a No Objection Certificate through PVARA’s licensing portal, building an AML/CFT compliance framework, and then applying for the full VASP licence.
Operating an unlicensed virtual asset service in Pakistan can carry penalties of up to PKR 50 million and five years’ imprisonment, with separate penalties for unauthorised promotion of virtual assets.
PVARA has generally required licence applicants to already hold recognition from a major jurisdiction such as the US, EU or Singapore, making the path harder for a genuinely new market entrant with no track record elsewhere.
Other practice areas
Foreign VASPs entering Pakistan
PVARA no-objection certificates, sandbox entry and full VASP licensing are instructed by exchanges, custodians and token issuers headquartered outside Pakistan. The AML/CFT framework and banking-relationship structuring are built alongside the licence application.
Overseas instructions are a routine part of the firm’s work rather than an exception. Where a matter also touches family law — guardianship, succession or a child’s documents — it is handled by the same firm rather than referred out. See child adoption and guardianship from Pakistan or all thirteen practice areas.