PVARA Minimum Paid-Up Capital Requirements
Pakistan’s emerging virtual asset regulatory (PVARA) framework is introducing a capital-based licensing structure for Virtual Asset Service Providers . For entrepreneurs planning to establish a cryptocurrency exchange, custody business, broker-dealer, token issuer, investment platform, or other virtual asset enterprise, understanding the proposed minimum paid-up capital requirements is an essential part of regulatory planning.
The figures discussed in this article are based on Schedule I of the Draft Pakistan Virtual Asset Services Regulations, 2026. PVARA’s own consultation page confirms that the regulations were published as a draft for consultation and are subject to revision before the final regulations are notified.
PVARA – Pakistan Virtual Assets Regulatory Authority
Proposed PVARA Capital Requirements
Schedule I of the draft regulations proposes the following minimum paid-up capital:
| VASP Licence Category | Proposed Minimum Paid-Up Capital |
|---|---|
| Advisory Services | PKR 25 million |
| Broker-Dealer Services | PKR 100 million |
| Custody Services | PKR 200 million |
| Virtual Asset Management & Investment Services | PKR 200 million |
| Virtual Asset Transfer & Settlement Services | PKR 200 million |
| Lending & Borrowing Services | PKR 500 million |
| Virtual Asset Derivatives Services | PKR 500 million |
| Exchange Services | PKR 1 billion |
| Fiat-Referenced Token Issuance | PKR 1 billion |
| Asset-Referenced Token Issuance | PKR 1 billion |
These are the figures stated in Schedule I of the draft regulations.
PKR 1 Billion Proposed Capital for Crypto Exchanges
The most significant figure for many cryptocurrency entrepreneurs is the proposed PKR 1 billion minimum paid-up capital for Exchange Services.
A business intending to operate a regulated cryptocurrency exchange in Pakistan should therefore consider capitalization at the earliest stage of its legal and business planning.
However, capital should not be viewed in isolation. A prospective exchange will also need to consider governance, technology, cybersecurity, AML/CFT controls, customer-asset protection, risk management and other applicable regulatory requirements. PVARA’s consultation materials specifically identify governance, market conduct, client protection, technology, cybersecurity, operational resilience and AML/CFT/CPF as components of the proposed framework.
Advisory Services: Proposed PKR 25 Million
The proposed threshold for Advisory Services is PKR 25 million, making it the lowest capital requirement among the categories listed in Schedule I.
This illustrates an important principle of the proposed framework: the regulatory capital requirement varies according to the nature of the virtual asset activity.
Therefore, before applying for a licence, a business should carefully determine what services it will actually provide rather than simply selecting the most familiar VASP category.
Broker-Dealer Services: PKR 100 Million
The proposed minimum paid-up capital for Broker-Dealer Services is PKR 100 million.
Businesses providing brokerage or transaction-related services should examine their proposed activities carefully to determine whether their business model falls within the relevant PVARA category or potentially engages other regulated activities.
Custody, Investment Management and Transfer Services
The draft proposes PKR 200 million for each of the following:
- Custody Services
- Virtual Asset Management and Investment Services
- Virtual Asset Transfer and Settlement Services
These businesses may involve significant customer-asset, operational and financial risks. Consequently, capital is only one part of the regulatory preparation.
For example, a custody provider should consider how private keys, wallets, customer assets, access controls, security incidents and asset segregation will be managed.
Lending and Derivatives: PKR 500 Million
The proposed capital requirement rises to PKR 500 million for:
- Lending and Borrowing Services
- Virtual Asset Derivatives Services
These categories can involve more sophisticated financial and market risks. Applicants should therefore undertake a detailed legal classification of their products before launching them.
Particular attention should be given to leverage, collateral, derivatives structures, risk management and the possibility that a product could also engage another regulatory framework.
Token Issuance: PKR 1 Billion
The draft also proposes PKR 1 billion minimum paid-up capital for:
- Fiat-Referenced Token Issuance Services
- Asset-Referenced Token Issuance Services.
This is particularly relevant for stablecoin and asset-backed token projects.
A token issuer should not assume that meeting the capital requirement alone is sufficient. The legal structure should also address the nature of the token, reserves or backing, governance, redemption arrangements, disclosures and continuing regulatory obligations.
Capital Is Not the Same as Licensing Approval
One of the most important points I would emphasize as a cryptocurrency and fintech lawyer is that having the required capital does not automatically entitle an applicant to receive a PVARA licence.
The proposed framework is considerably broader.
PVARA’s consultation materials identify requirements relating to:
- Governance
- Fit-and-proper requirements
- Market conduct
- Client protection
- Technology
- Cybersecurity
- Operational resilience
- Risk management
- AML/CFT/CPF
- Safeguarding and segregation of client assets.
Internationally, this approach is consistent with the Financial Action Task Force (FATF) framework, under which jurisdictions are expected to license or register VASPs and supervise them in a manner addressing money-laundering and terrorist-financing risks.
FATF – Virtual Assets and VASPs
AML/CFT Compliance Will Be a Core Licensing Issue
A PVARA applicant should prepare for substantial AML/CFT compliance obligations rather than treating compliance as an issue to be addressed after licensing.
FATF’s current work on virtual assets emphasizes licensing and supervision, risk assessment, customer due diligence, suspicious transaction reporting and Travel Rule implementation. Its 2026 targeted update also identifies continuing risks involving fraud, stablecoins, P2P transactions, unhosted wallets and offshore VASPs.
For a prospective Pakistani VASP, the compliance programme should therefore be designed alongside the business model and technology architecture.
PVARA Licensing and Company Incorporation
Corporate structuring will also be an important component of licensing preparation.
The Securities and Exchange Commission of Pakistan provides the formal company incorporation framework and explains that incorporation involves submitting information concerning the company’s directors, subscribers, capital and corporate credentials.
A prospective VASP should therefore consider its corporate structure, shareholding, beneficial ownership, directors, capital structure and constitutional documents before proceeding with the regulatory application.
Banking Considerations for PVARA Applicants
Banking access is another important part of the new regulatory environment.
The State Bank of Pakistan issued BPRD Circular Letter No. 10 of 2026 concerning bank accounts for PVARA NOC holders and licensed VASPs. The circular permits limited-purpose accounts for entities holding PVARA NOCs to complete licensing formalities, while additional services and virtual-asset-related transactional activity are tied to obtaining a PVARA licence and satisfying the applicable conditions.
State Bank of Pakistan – BPRD Circular Letter No. 10 of 2026
This development is important because it demonstrates that PVARA licensing should be considered as part of a broader regulatory ecosystem involving corporate law, banking regulation and AML/CFT supervision.
Draft Regulations Must Not Be Treated as Final Law
The chart accompanying this article correctly identifies the figures as proposed thresholds under the 2026 draft regulations.
This distinction is legally important.
PVARA’s official consultation page expressly states that the draft regulations are not final and are subject to revision following stakeholder comments. It also states that the final regulations will subsequently be published and notified in accordance with the Virtual Assets Act 2026.
The draft itself states that the regulations are to come into force upon notification in the Official Gazette, or on such later date as may be specified.
Accordingly, entrepreneurs should not treat the proposed PKR 25 million, PKR 100 million, PKR 200 million, PKR 500 million or PKR 1 billion figures as permanently settled requirements without checking the final notified framework.
My Practical Advice to Prospective VASPs
In my experience advising cryptocurrency and fintech businesses, one of the biggest mistakes is to begin with the question: “How do I obtain the licence?”
The better question is:
“What exactly is my business model, and which regulatory activities will it perform?”
Before approaching PVARA, a prospective applicant should prepare a regulatory map covering:
- The proposed virtual asset services.
- The appropriate licence category.
- Required paid-up capital.
- Ownership and beneficial ownership.
- Directors and senior management.
- AML/CFT/CPF framework.
- KYC and KYB procedures.
- Technology and cybersecurity controls.
- Customer-asset safeguarding.
- Risk management.
- Business continuity.
- Regulatory reporting.
- Banking arrangements.
- Corporate and tax requirements.
This approach can help identify regulatory problems before substantial capital is committed.
Conclusion
Pakistan’s proposed PVARA capital framework represents a significant step toward a structured and supervised virtual asset industry.
The proposed thresholds range from PKR 25 million for Advisory Services to PKR 1 billion for Exchange Services and specified token-issuance activities.
For cryptocurrency exchanges and other VASPs, however, capital should be regarded as only one element of licensing readiness. The regulatory framework also contemplates governance, AML/CFT/CPF, cybersecurity, operational resilience, client protection and safeguarding requirements.
The most important legal qualification is that these figures remain tied to the draft 2026 regulations. Prospective applicants should verify the final notified requirements with PVARA before incorporating a business, raising capital, launching services or submitting a licence application.
For businesses planning to enter Pakistan’s regulated virtual asset market, early legal and regulatory structuring may be considerably more valuable than attempting to correct an unsuitable business model after the application process has begun.
Disclaimer
The information provided in this article is intended for general informational purposes only and should not be construed as legal or financial advice. Readers are encouraged to seek independent professional counsel tailored to their specific circumstances.
Author & Crypto Consultant
Shahid Jamal Tubrazy – Crypto & Fintech Law Consultant
Shahid Jamal Tubrazy is a recognized professional in the field of cryptocurrency and blockchain law, with specialized certification in Crypto Law from Duke University. As an experienced fintech lawyer, he provides comprehensive legal services across the digital asset ecosystem, including regulatory licensing, legal structuring for ICOs, STOs, DeFi projects, and DAOs.
He also offers expertise in crypto dispute resolution, mediation, negotiation, and mergers & acquisitions within the blockchain sector. With a strong portfolio of published work on blockchain regulation and cryptocurrency law, Shahid delivers practical legal insights to help clients navigate complex regulatory landscapes, ensure compliance, and achieve strategic growth in the evolving fintech industry.
📧 Email: shahidtubrazy@gmail.com
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