Pakistan: crypto and stablecoin regulation (as of 6 November 2026)

As of 2026-11-06

In Pakistan, virtual asset services are supervised by the Pakistan Virtual Assets Regulatory Authority (PVARA), established under the Virtual Assets Act, 2026. Under regulations notified on 21 August 2026, no person may provide a virtual asset service by way of business in or from Pakistan without a PVARA licence, which comes in 11 categories by our count of PVARA's FAQ, including two token-issuance categories. Regulation 5A(1): "Any Person providing Virtual Asset Services immediately before the commencement of the Act shall, within six (6) months of such commencement, apply to the Authority for a Licence under the Act or shall cease to provide such services"; under regulation 5A(2), where such a person "has submitted a complete application that satisfies the requirements of the No Objection Certificate application referred herein, it may continue to provide its existing Virtual Asset Services pending the determination of the application". PVARA's licensing page words the cut-off differently ("operating since March 5, 2026 or before").

Status: The Senate's list of bills it passed shows The Virtual Assets Bill, 2026 with a passage date of February 27, 2026, and the National Assembly's list of passed bills shows it against 3 March 2026. The Gazette of Pakistan Extraordinary of March 5, 2026 publishes Act No. XIII of 2026, which "received the assent of the President on the 4th March, 2026"; section 1(3) says "It shall come into force at once." Under section 68 of the Act, PVARA made the Pakistan Virtual Asset Services Regulations, 2026 (S.R.O. 1419(I)/2026) and the Pakistan Virtual Asset Services Activity Specific Regulations, 2026 (S.R.O. 1420(I)/2026), both dated Islamabad, August 21, 2026. PVARA's licensing FAQ says the Regulations came into force on their gazette notification, August 21, 2026. The earlier NOC Regulations, 2025 applied until then. PVARA's licensing page says firms operating since March 5, 2026 or before had to file an NOC application by September 5, 2026 or cease operations.

This page states what the official sources say. It is not legal advice. All sources are in English; the quotes are from the official texts.

Pakistan virtual asset rules: status as of 6 November 2026 (some rows read 10 November 2026)

Status	Rule	Since / from	Source
Published	The Virtual Assets Act, 2026 (Act No. XIII of 2026): the Gazette of Pakistan Extraordinary of March 5, 2026 publishes the Act, which "received the assent of the President on the 4th March, 2026"; section 1(3): "It shall come into force at once." The Senate's list of Acts of Parliament gives it an assent date of March 4, 2026 and a gazette publication date of March 5, 2026. The Senate's list of bills it passed shows The Virtual Assets Bill, 2026 with a passage date of February 27, 2026; the National Assembly's passed-bills list reads "Tuesday, 3rd March, 2026 The Virtual Assets Bill, 2026". PVARA says it was "established under the Virtual Assets Act, 2026".	5 March 2026 (Gazette); assent 4 March 2026	Gazette (Senate), Senate Acts, Senate bills, National Assembly, PVARA
In force	Pakistan Virtual Asset Services Regulations, 2026 (S.R.O. 1419(I)/2026). PVARA FAQ: "The Regulations come into force on the date of their gazette notification i.e. on August 21, 2026."	21 August 2026	Gazette text (PVARA), PVARA
Notified	Pakistan Virtual Asset Services Activity Specific Regulations, 2026 (S.R.O. 1420(I)/2026), read together with the Act and the Services Regulations. S.R.O. 1420(I)/2026 contains no commencement clause in the text read; PVARA's FAQ gives August 21, 2026 as the in-force date of "the Regulations", citing Services Regulations 1.	21 August 2026 (notified)	Gazette text (PVARA)
Replaced	PVARA NOC Regulations, 2025: "Applied until the Services and Activity Regulations were promulgated on 21 August 2026. NOC applications are now made under the Pakistan Virtual Asset Services Regulations, 2026."	Until 21 August 2026	PVARA
Deadline passed	"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."	5 September 2026	PVARA
Current (PVARA)	Advisory PVARA/ADV/001/2026: "Any agreement or announced pilot that results in, or directly enables, the provision of such services requires prior authorization from PVARA."	26 April 2026	PVARA

Key dates

Dates printed in the official texts cited on this page, earliest first.

Date	Issuers	Intermediaries	Status	Source	Checked
21 August 2026	–	PVARA lists the Pakistan Virtual Asset Services Regulations, 2026 as notified on 21 August 2026 (S.R.O. 1419(I)/2026): "Pakistan Virtual Asset Services Regulations, 2026 Notified 21 August 2026 · S.R.O. 1419(I)/2026"	Published	Pakistan Virtual Asset Services Regulations, 2026	6 November 2026
5 September 2026	–	PVARA: transitional persons operating since 5 March 2026 or before must submit an NOC application by 5 September 2026 or cease operations: "Transitional Persons — operating since March 5, 2026 or before, must submit an NOC application by September 5, 2026, or cease operations"	Published	PVARA licensing (transitional NOC)	6 November 2026

A dash means this site has no dated row for that role. It is not a statement that no rule applies.

Pakistan virtual asset key rules

Pakistan licence requirement, categories and minimum capital

Who needs a licence. Under the Services Regulations, "No Person shall, by way of business, engage in, or hold themselves out as engaging in, any Virtual Asset Service in or from Pakistan unless that Person" is a company incorporated under the Companies Act, 2017 or other Pakistani company law and "holds a valid Licence granted by the Authority under the Act for the relevant Category or Categories of Virtual Asset Services." (Gazette text)
Firms abroad. Under regulation 3(4)-(5), an activity can count as carried on in Pakistan "where it targets, solicits, promotes to, or onboard persons in Pakistan", including through marketing, payment rails or services in PKR, but not "solely because a website, application or other digital interface is accessible in Pakistan". (Gazette text)
Eleven categories and their capital. PVARA's FAQ names 11 licence categories (our count of FAQ question 10, checked 10 November 2026), including two token-issuance categories (Fiat-Referenced Token Issuance Services and Asset-Referenced Token Issuance Services), and "A person may apply for one or more Categories." Minimum paid-up capital runs from PKR 15,000,000 (Advisory) and PKR 75,000,000 (Broker-Dealer) through PKR 200,000,000 (Custody, Management and Investment, Transfer and Settlement) and PKR 300,000,000 (Fiat-Referenced and Asset-Referenced Token Issuance) to PKR 500,000,000 (Exchange, Lending and Borrowing, Derivatives, Mining Related), and the applicant must be a Companies Act, 2017 company "with a minimum of 3 directors". Regulation 32(1): a licensee "shall maintain at all times net liquid assets equivalent to 1.2 times of the adjusted monthly operating expenses to meet its obligations as they fall due, including during periods of stress." Regulation 32 ("Liquid financial resources"), paragraph (1), also says: "Where a Licensee holds more than one Licence Category, the applicable prudential floor shall be the highest requirement applicable to those Licence Categories, unless the Authority determines that an additional activity creates a separate and non-overlapping risk requiring an additional amount." Regulation 3(3): "A Licensee shall maintain at all times the minimum paid-up capital and any other prudential requirements applicable to its Licence Category or Categories as set out in Schedule I." Regulation 31(2): "Where a Licensee is authorized for more than one Licence Category, the Authority may, on a risk-based basis, specify in the Licence, or by Rules or Regulations made under the Act, or by applicable direction, circular, standard, directive, guideline or other written instrument issued under the Act, the methodology for determining the applicable minimum paid-up capital and any additional prudential add-ons (including for custody exposure, operational/technology risk, market risk, or cross-border risk), provided that the Licensee is afforded an opportunity to make representations except in urgent cases." For a licensee with more than one category, the floor under regulation 32 is the highest requirement of those categories, unless PVARA requires an additional amount for a separate risk. For paid-up capital, regulation 31(2) lets PVARA set, on a risk-based basis, the method for determining the minimum paid-up capital of a licensee with more than one category, in the licence or in rules, directions or other written instruments. (PVARA, Gazette text)
The NOC step. PVARA decides a complete No-Objection Certificate application "within sixty (60) days"; a NOC is valid for three months (plus up to three more), and "does not constitute a Licence or authorization to carry on any Virtual Asset Service". For a licence, the FAQ says "The Authority will decide a complete application within ninety (90) days." (Gazette text, PVARA)
Mining. "pure Virtual Asset mining, by itself, shall not constitute a Virtual Asset Service requiring a Licence under the Act". The next sentence: "Mining operations involving Customer Assets or Customer funds, or otherwise involving the provision of services to third parties on a professional basis ..., shall be treated as Virtual Asset Services and shall require licensing". So pure mining needs no licence under the Act; mining that involves customer assets or funds, or services to third parties on a professional basis, is a virtual asset service that needs a licence. (Gazette text)

Pakistan client-asset, custody and AML/CFT rules

Client money and client assets. A licensee that holds client money must keep it "in one or more segregated accounts designated for Clients" "with a bank licensed by State Bank of Pakistan" (regulation 104(1)), and "Client Virtual Assets are not owned by the Licensee." (regulation 109(2)). (Gazette text)
No use without consent. Regulation 33(2): "A Licensee shall not treat Customer Assets as its own assets and shall not use, pledge, encumber, lend, rehypothecate, or otherwise dispose of Customer Assets except as expressly permitted under these Regulations and with the Customer’s prior informed explicit consent". (Gazette text)
Proof of reserves. Under the Custody Services Regulations in S.R.O. 1420(I)/2026 (notified 21 August 2026; no commencement clause in the text read), "A Custodian shall maintain proof-of-reserves or equivalent assurance procedures sufficient to demonstrate on an ongoing basis that liabilities to Clients in respect of Client Virtual Assets are fully matched by safeguarded holdings or other equivalent arrangements." The methods named include "third-party attestation and cryptographic verification." (Gazette text)
Travel rule. "A Licensee shall comply with section 47 of the Act (Travel rule and record-keeping obligations)" and transmit originator and beneficiary "information for Virtual Asset transfers meeting or exceeding the threshold of PKR equivalent of USD 1,000" (regulation 100). (Gazette text)
Reports to the FMU and records. "Nothing in these Regulations shall be construed as limiting or replacing the obligation of a Licensee to submit STRs, CTRs or any other reports required under the AML Act, 2010 to the Financial Monitoring Unit." AML records are kept for the period the AML Act sets or, where none "is specified, for a period of at least seven (7) years." PVARA's regulations web page says "for a minimum of 10 years"; this page follows the gazetted regulation. (Gazette text)

Pakistan stablecoin rules: fiat- and asset-referenced tokens

Full reserve. Regulation 34: "Reserve assets maintained under this regulation shall, be maintained at a level equal to one hundred percent (100%) of the Issuer’s outstanding redemption liabilities at all times, and shall be held as a segregated reserve." For a fiat-referenced token, regulation 34(4) says the reserve assets are high-quality liquid assets "or such other eligible assets as may be specified", and "the Issuer shall maintain mechanisms for redemption at par value without Undue Delay". (Gazette text)
No crypto backing. An asset-referenced "Token shall at all times be fully backed by the underlying assets and shall not be backed or derive its value from other Virtual Assets" (regulation 34(5)). (Gazette text)
Significant issuers. Under the issuance rules in S.R.O. 1420(I)/2026 (notified 21 August 2026; no commencement clause in the text read), an issuer is significant where the token's market capitalisation "exceeds five billion Pakistani Rupees (PKR 5,000,000,000)" or its Pakistan-based holders exceed five million; a significant issuer holds additional own funds of "three percent (3%) of reserve assets, capped at PKR 3 billion". (Gazette text)
Domestic payments only with SBP approval. Regulation 3(6): "Virtual assets shall not facilitate, or be used or recognized as, a means of payment for domestic commercial transactions, except where specifically approved by the State Bank of Pakistan pursuant to Section 9(1)(f) of the Act." The Act states: "For the avoidance of doubt, Virtual Assets are not legal tender". (Gazette text, Act, Gazette (Senate))
Pilots and announcements. PVARA's advisory of April 26, 2026 addresses announced agreements and pilots, "including the use of stablecoins for remittances and cross-border payments", and says: "Any agreement or announced pilot that results in, or directly enables, the provision of such services requires prior authorization from PVARA." (PVARA)

Pakistan virtual asset timeline

Date	Event	Source
27 February 2026	The Virtual Assets Bill, 2026: date of passage by the Senate, per the Senate's list of bills it passed	Senate bills
3 March 2026	The Virtual Assets Bill, 2026 appears on the National Assembly's passed-bills list	National Assembly
4 March 2026	Date of assent of the Virtual Assets Act, 2026 (Act No. XIII of 2026), per the Senate's list of Acts of Parliament	Senate Acts
5 March 2026	Gazette of Pakistan Extraordinary publishes the Act; section 1(3): "It shall come into force at once."	Gazette (Senate)
5 March 2026	PVARA's licensing page: transitional persons "operating since March 5, 2026 or before" must submit an NOC application by September 5, 2026	PVARA
26 April 2026	PVARA advisory PVARA/ADV/001/2026 on announced agreements and pilots, including stablecoins for remittances	PVARA
21 August 2026	S.R.O. 1419(I)/2026 and S.R.O. 1420(I)/2026 notified; the NOC Regulations, 2025 stop applying	PVARA
5 September 2026	Deadline for transitional persons to submit an NOC application or cease operations	PVARA

Not covered here

The Act is cited from the Gazette of Pakistan Extraordinary of March 5, 2026 (a scanned PDF hosted by the Senate) and from the Senate's and the National Assembly's lists. PVARA publishes the bill text "AS PASSED BY THE NATIONAL ASSEMBLY" (PVARA), not the gazetted Act; the two texts were compared only for sections 1, 3, 6, 70 and 74. The Gazette prints no separate commencement date, so this page gives none. The State Bank of Pakistan's own circulars could not be read (its site blocked automated access), so the SBP appears here only through regulation 3(6). Regulation 9(6) requires PVARA to publish a public register of licensees, but no register page was found on pvara.gov.pk, so this page gives no count of licensed firms. Licence fees print as "PKR [x]" in the published forms and are not given. PVARA's regulations web page says AML records are kept "for a minimum of 10 years"; this page follows the gazetted regulation. Tax treatment of virtual assets by the Federal Board of Revenue (FBR) is not covered.

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Sources

Updated: 2026-11-13 · Markdown version

Cite as: Pakistan: crypto and stablecoin regulation, achivx.org, https://achivx.org/regulation/pakistan/, as of 2026-11-06, CC BY 4.0